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Home My WebLink AboutDAQ-2024-0051401 DAQC-PBR156830001-24 Site ID 15683 (B1) MEMORANDUM TO: FILE – UINTA WAX OPERATING, LLC – Szyndrowski 3.5-34-3-1E-H1 THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager FROM: Chris Jensen, Environmental Scientist DATE: February 20, 2024 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: February 14, 2024 SOURCE LOCATION: Szyndrowski 3.5-34-3-1E-H1 Lat: 40.186303 Long: -109.875085 Business Office: 5128 Apache Plume Road, Suite 300 Fort Worth, TX 76109 SOURCE TYPE: Tank Battery Uintah County API: 43047-55562 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 40 CFR 60 Subpart JJJJ. SOURCE EVALUATION: Site Type: PBR-Uncontrolled Voluntarily Controlled by Flare Site powered by Engine 2 DOGM current 12 month rolling production is: 7,118 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. 11 Oil and Gas Industry: General Provisions [R307-501] In Compliance. The source was inspected by AVO and with an OGI camera and was found to be well-kept with no visible or fugitive emissions. 13 Oil and Gas Industry: Tank Truck Loading [R307-504] In Compliance. The truck loading area is suitable for submerged loading and it is routine for truck drivers to load this way. 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 VCS upgrade is nearly complete. It is lacking electrical power and an actuator. Looks like the upgrades just begun. This should have had the inlet regulating valve etc. in previous years. 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. Monthly production totals were supplied. 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)] Out of Compliance. DOGM records show this well’s first production was September, 2016. This source is subject to these standards. A performance test was not produced or not kept by UWO. 40 Affected engines are certified or have an initial performance test per 40 CFR 60.4244. [R307-510-4(2)] Out of Compliance. A record of an initial performance test was not provided to the DAQ for inspection or not kept by UWO. 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. A record of an initial performance test was not provided to the DAQ for inspection or not kept by UWO. A search of the DAQ EZ-Search database did not return a stack test for this source. 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. 4 57 Applicable Federal Regulations: NSPS (Part 60) OOOOa: Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification or Reconstruction Commenced After September 18, 2015 [40 CFR 60 Subpart OOOOa] In Compliance. The production amounts stored in the tank battery may not have the PTE to be an affected facility according to this subpart. If not so, UWO did not produce documentation of monthly AVO inspections, monthly VCS inspections, LDAR reports, or design analysis for this battery, and would not be in compliance. The DAQ assumes that UWO does not believe they are subject to this subpart. There are no other affected facilities installed here. 59 NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines [40 CFR 60 Subpart JJJJ] In Compliance. The engine at this source is not certified. Stack testing may or may not have been performed but, the record retention time limit (under this subpart) for this testing has expired. The maintenance provisions are met. PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: Out of Compliance - UWO did not produce any supporting documentation for compliance with NSPS (60) OOOOa. They have just recently fell below the 8,000 BBL threshold for controls under Utah PBR Rules however, they may still have the potential to emit in excess of 4TPY, in which case recordkeeping is still required. The DAQ could not find, nor did UWO provide an initial performance stack test for an uncertified pumpjack engine (Arrow L-795). Utah PBR rules (R307-510) require lifetime retention of this test for engines installed after January, 2016. DOGM records show first production date reported was September, 2016. In consideration of the joint consent decree with the US EPA, still in negotiation with UWO, no further enforcement action is taken. 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: Email