The URL can be used to link to this page

Home My WebLink AboutDAQ-2024-0045801 DAQC-PBR154500001-23 Site ID 15450 (B1) MEMORANDUM TO: FILE – UINTA WAX OPERATING, LLC – Gardner State 1-26-3-2E THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager FROM: Chris Jensen, Environmental Scientist DATE: November 13, 2023 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: November 8, 2023 SOURCE LOCATION: Gardner State 1-26-3-2E Lat: 40.198074 Long: -109.729312 Business Office: 5128 Apache Plume Road, Suite 300 Fort Worth, TX 76109 SOURCE TYPE: Tank Battery Uintah County API: 4304755108 SOURCE CONTACTS: Aimee Cole, Local Contact Phone: 720-384-7365, Email: acole@finleyresources.com Kaylene Bridwell, Corporate Environmental Contact Phone: 405-496-7308, Email: kaylene.bridwell@uintawax.com OPERATING STATUS: Operating PROCESS DESCRIPTION: Oil and gas products are brought to the surface. These products go through a separator where the oil and any water products are sent to storage tanks and the gas is used to power equipment on site (pump jack engine, tank heater, separator, flare, combustor, etc.) Any remaining gas is sent to a pipeline that feeds a local gas plant. The oil and process water in the storage tanks is loaded into tanker trucks and hauled off site for processing and disposal. APPLICABLE REGULATIONS: Utah Administrative Code (UAC) R307-500 Series for the Oil and Gas Industry, and UAC R307-201: Emission Standards: General Emission Standards; and UAC R307-150: Emission Inventories, and NSPS (60) JJJJ. 2 SOURCE EVALUATION: Site Type: PBR-Uncontrolled Voluntarily Controlled by Flare Site powered by Engine DOGM current 12 month rolling production is: 5,217 BBLs. Utah Statute R307-506 requires a source with throughput greater than 8,000 BBLs to have controls. REGISTERED EQUIPMENT: Arrow model L-795 pumpjack engine. 8 Pneumatic Controllers 9 Continuous bleed natural gas-driven pneumatic controllers are in compliance with 40 CFR 60.5390 or 60.5390a as applicable. Exemptions to tagging and record keeping requirements apply to controllers existing before December 1, 2015. [R307-502-4] In Compliance. This source does not use continuous bleed natural gas-driven pneumatic controllers. 15 Oil and Gas Industry Registration Requirement 16 The source is registered with the DAQ. [R307-505-3(3)] In Compliance. 17 Registration has been updated within 30 days of a company name change, removal or addition of control devices, or termination of operations. [R307-505-3(3)] In Compliance. 18 Storage Vessels 19 Thief hatches are kept closed and latched. [R307-506-4(1)] In Compliance. All hatches were found closed at the start of the evaluation. 23 Upon modification, the well site was re-evaluated against the thresholds of R307-506-4(2). [R307-506-4(6)] In Compliance. The DAQ did not identify any modifications or unauthorized equipment. 24 Records for each of the following are kept for three years: Storage vessel vent system inspections (openings, thief hatches, pressure relief devices, bypasses, etc.), if required Monthly crude oil throughput Emission calculations, actuals and sampling data when used to justify an exemption to storage vessel rules Emergency storage vessel usage (dates used, emptied, and volumes), if not controlled per R307-506-4(2)[R307-506-5] In Compliance. No tanks are uncontrolled or used as an emergency tank. 3 38 Natural Gas Engines 39 Engines subject to R307-510 (does not have an AO, began operations, installed or modified after January 1, 2016) meet the following limits: Maximum Engine hp Emission Standards in (g/hp-hr) NOx CO VOC HC+NOx >25 hp and < 100 hp - 4.85 - 2.83 >100 hp 1.0 2.0 0.7 - [R307-510-4(1)] In Compliance. This well was drilled before 2016, and the pumpjack engine is subject to the performance standards in NSPS (60) JJJJ. 40 Affected engines are certified or have an initial performance test per 40 CFR 60.4244. [R307-510-4(2)] In Compliance. UDAQ was able to locate a stack test, submitted by the previous owner, for this source in D2. 41 Affected engine exhaust vents are vertical and unrestricted. Stacks are 8' or greater if the site horsepower rating is 151 to 305 Stacks are 10' or greater if the site horse power rating is 306 or greater. [R307-510-4(3)] In Compliance. 42 Engine certifications or initial performance tests required are kept for the life of the engine at the source. [R307-510-5] Out of Compliance. This document is not kept by UWO. 46 Visible Emissions 47 Visible emissions, except for unavoidable irregularities that do not exceed three minutes, are within the following opacity limits: Installations constructed on or before 4/25/1971 40% Installations constructed after 4/25/1971 20% Gasoline engines 0% Diesel engines manufactured after 1/1/1973 20% Diesel engines manufactured before 1/1/1973 40% Note: Required VOC control devices shall have no visible emissions per R307-508-3.[R307-201-3] In Compliance. No visible emissions were detected. 55 Emission Inventory: 56 An emissions inventory has been submitted within the past three years. [R307-150-9(1)] In Compliance. The operator submitted for the 2020 emissions inventory. PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. 4 COMPLIANCE STATUS & RECOMMENDATIONS: Out of Compliance – UWO is not maintaining the initial performance stack test for the pumpjack engine onsite. A Kimray valve was found leaking on the associated gas line in the treater shed. In consideration of the joint consent decree with the US EPA, still in negotiation with UWO, no further enforcement action is taken. The infractions documented here will be added to the complaint. RECOMMENDATION FOR NEXT INSPECTION: The DAQ has no recommendations for the next inspector other than what are customary. The DAQ recommends the inspection frequency of this source be reduced. ATTACHMENTS: None