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HomeMy WebLinkAboutDAQ-2024-0041691 DAQC-PBR154510001-23 Site ID 15451 (B1) MEMORANDUM TO: FILE – UINTA WAX OPERATING, LLC – Ouray Valley State 10-36-5-19E THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager FROM: Chris Jensen, Environmental Scientist DATE: October 19, 2023 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: October 18, 2023 SOURCE LOCATION: Ouray Valley State 10-36-5-19E Lat: 40.336793 Long: -109.737391 Business Office: 5128 Apache Plume Road Suite 300 Fort Worth, TX 76109 SOURCE TYPE: Tank Battery Uintah County SOURCE CONTACTS: Kaylene Bridwell, Senior Engineer Kaylene.bridwell@uintawax.com Ph. 405-496-7308 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 40 CFR 60 Subpart OOOO. SOURCE EVALUATION: Site Type: Minor Source Controlled by flare Site powered by Engine ) 0 2 DOGM current 12 month rolling production is: 5,331 BBLs. Utah Statute R307-506 requires a source with throughput greater than 8,000 BBLs to have controls. REGISTERED EQUIPMENT: 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 12/1/2015. [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. 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. 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 source has an Ajax E565 engine installed. It is EPA certified as NSPS (60) JJJJ compliant. 3 40 Affected engines are certified or have an initial performance test per 40 CFR 60.4244. [R307-510-4(2)] In Compliance. An engine maintenance plan was followed that maintains the certification. 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. The stack vents vertically. 42 Engine certifications or initial performance tests required are kept for the life of the engine at the source. [R307-510-5] In Compliance. 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. 60 NSPS (Part 60) OOOO: Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution [40 CFR 60 Subpart OOOO] In Compliance. This source does not likely have the production to have the potential to emit in excess of 6 TPY of VOCs. The tank battery is then not an affected facility. However, a monitoring, repair, and record keeping program is in place that would satisfy the requirements of 40 CFR (60) OOOO for a tank affected facility. There are no other affected facilities that are installed. PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: In Compliance - This source was found to be clean and well-kept with no visible or fugitive emissions. The source was inspected by AVO and with an OGI camera and found to be free of leaks. The operator’s representatives were pleasant and cooperative. Requested records were provided in a timely manner and reviewed at the local field office. 4 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