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HomeMy WebLinkAboutDAQ-2024-007310 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 903-3978 www.deq.utah.gov Printed on 100% recycled paper State of Utah Department of Environmental Quality Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor DAQC-282-24 Site ID 14862 (B1) Sent Via Certified Mail No. 70112970000188367512 Justin Ray Price River Terminal P.O. Box 146 Wellington, UT 84542 Sent Via Certified Mail No. 70112970000188367529 Josh McQueen Price River Terminal 3215 West 4th Street Fort Worth, TX 76107 Dear Mr. Ray and Mr. McQueen: Re: Compliance Advisory – Price River Terminal, LLC - Oil Transloading Facility – Condition I.5 of Approval Order DAQE-AN148620003-20, 40 CFR 60.113b(a)(2), and 40 CFR 60.113b(a)(4) – Carbon County, UT On March 14, 2024, a representative of the Utah Division of Air Quality (DAQ) conducted an inspection of Price River Terminal, LLC Oil Transloading Facility in Wellington, UT. The DAQ observed volatile organic compounds leaking out of both the 88,300-barrel and the 120,000-barrel tanks which may be a violation of Condition I.5 of Approval Order DAQE- AN148620003-20, 40 CFR 60.113b(a)(2), and 40 CFR 60.113b(a)(4). Price River Terminal, LLC is required to comply with the above regulations. A written response to this letter is required within ten (10) business days of receipt of this letter. / % Û Þ Û Ù Û Ý DAQC-282-24 Page 2 Additional details about the above observations and regulations are attached to this letter. Please contact Kyle Greenberg at 385-306-6533 or kgreenberg@utah.gov if you have any questions about this letter. Sincerely, Rik Ombach, Manager Minor Source Oil and Gas Compliance Section RO:KG:jl cc: Southeast Utah Health Department DAQC-282-24 Page 3 Potential Violation(s) On March 14, 2024, an inspector from the DAQ observed Price River Terminal, LLC Oil Transloading Facility in Carbon County, UT. At the time of the inspection, the DAQ documented the following potential violations of volatile organic compounds leaking out of both the 88,300-barrel and the 120,000-barrel tanks. AO Conditions/Rules Condition I.5 of Approval Order DAQE-AN148620003-20: At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance p erformed on equipment authorized by this AO shall be recorded. 40 CFR 60.113b(a)(2): For Vessels equipped with a liquid-mounted or mechanical shoe primary seal, visually inspect the internal floating roof and the primary seal or the secondary seal (if one is in service) through manholes and roof hatches on the fixed roof at least once every 12 months after initial fill. If the internal floating roof is not resting on the surface of the VOL inside the storage vessel, or there is liquid accumulated on the roof, or the seal is detached, or there are holes or tears in the seal fabric, the owner or operator shall repair the items or empty and remove the storage vessel from service within 45 days. If a failure that is detected during inspections required in this paragraph cannot be repaired within 45 days and if the vessel cannot be emptied within 45 days, a 30-day extension may be requested from the Administrator in the inspection report required in § 60.115b(a)(3). Such a request for an extension must document that alternate storage capacity is unavailable and specify a schedule of actions the company will take that will assure that the control equipment will be repaired or the vessel will be emptied as soon as possible. 40 CFR 60.113b(a)(4): Visually inspect the internal floating roof, the primary seal, the secondary seal (if one is in service), gaskets, slotted membranes, and sleeve seals (if any) each time the storage vessel is emptied and degassed. If the internal floating roof has defects, the primary seal has holes, tears, or other openings in the seal or the seal fabric, or the secondary seal has holes, tears, or other openings in the seal or the seal fabric, or the gaskets no longer close off the liquid surfaces from the atmosphere, or the slotted membrane has more than 10 percent open area, the owner or operator shall repair the items as necessary so that none of the conditions specified in this paragraph exist before refilling the storage vessel with VOL. In no event shall inspections conducted in accordance with this provision occur at intervals greater than 10 years in the case of vessels conducting the annual visual inspection as specified in paragraphs (a)(2) and (a)(3)(ii) of this section and at intervals no greater than 5 years in the case of vessels specified in paragraph (a)(3)(i) of this section. DAQC-282-24 Page 4 The purpose of a Compliance Advisory (CA) is to document observations made by the DAQ. You are responsible for complying with the Utah Air Conservation Rules. There are possible administrative and civil penalties for failing to do so. Section 19 -2-115 of the Utah Code Annotated provides that violators of the Utah Air Conservation Act and/or any order issued there under may be subject to a civil penalty of up to $10,000 per day for each violation. The written response to this CA will be considered in resolving the deficiencies documented in this letter. It may include information demonstrating compliance with the regulations or a schedule to bring your company back into compliance with the applicable regulations. The DAQ will review your response and this CA may be revised as a result of that review. Failure to respond in writing within ten (10) business days of receipt of this CA will be considered in any subsequent enforcement action and the assessment of penalties. Possible DAQ actions to resolve a CA include: No Further Action Letter, Warning Letter, Early Administrative Settlement with reduced civil penalty, Settlement Agreement with civil penalty, or Notice of Violation and Order to Comply. This CA does not limit or preclude the DAQ from pursuing enforcement options concerning this inspection. Also, this CA does not constitute a bar to enforcement action for conditions that the DAQ did not observe or evaluate, or any other conditions found during future inspections. A meeting may be requested to discuss this CA. Please contact Kyle Greenberg at 385-306-6533 or kgreenberg@utah.gov if you would like to request a meeting or if you have any questions about this letter.