DAQ-2024-007207

State of Utah
SPENCERJ. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor
Department of
Environmental Quality
Kimberly D. Shelley
Executive Director
DTVISION OF AIR QUALITY
Bryce C. Bird
Director
November 9,2023 DAQC-CA158030001-23
Site ID 1s803 (Bl)
Sent Via Certified Mail No. 70190700000208346306
Kaylene Bridwell, Senior Engineer
Uinta Wax Operating, LLC
5128 Apache Plume Road, Suite 300
Fort Worth,TX76109
Dear Ms. Bridwell,
Re: Compliance Advisory - Uinta Wax Operating, LLC - l4-25D-37 BTR, Duchesne County
On November 1,2023, a representative of the Utah Division of Air Quality (DAQ) conducted an
inspection of Uinta Wax Operating, LLC l4-25D-37 BTR located at latitude 40.184116, longitude
-110.627 828, Duchesne County.
The DAQ observed the following regulations of concern:
40 CFR (60) Subpart JJJJ - stationary spark ignition (SI) internal combustion engines (ICE) that
commence construction after June 12,2006
R307-510-4 - Natural Gas Engines
R307-511-4 - Associated Gas Flaring
These findings may be a violation of Utah Air Conservation Rules. Uinta Wax Operating, LLC
l4-25D-37 BTR 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.
195 North 1950 West. Salt Lake City, UT
Mailing Address: P.O. Box 144820. Salt Lake City, UT 84114-4820
Telephone [phone] . Fax [phone]. T.D.D. [phone]
w.deq.utdh.gov
Printed on l00o/o recycled paper
DAQC-CA.I58030001-23
Page2
Additional details about the abovo observations and regulations are included with this letter.
Please contact Chris Jensen at 435-828-0141 or [e-mail] if you have arry additional
questions.
Sincerely,
ft,:JA
Rik Ombach
Minor Source Oil and Gas Compliance Section Manager
RO:CJ:rh
oc: TriCounty Health Deparhnent
Alan Humpherys, UDAQ, Minor NSR Section Manager
DAQC-CA1s8o3oool-23
Page 3
Potential Violation(s)
On November 1,2023, an inspector from the DAQ attempted an inspection at Uinta Wax
Operating, LLC 14-25D-37 BTR located at latitude 40.184116, longitude -110.627828, Duchesne
County.
At the time of the inspection, the DAQ documented the following potential violation:
Requirement & Rule Comments & Observations
Engine certifications or initial performance tests required are kept
for the life of the engine at the source
[R307-510-s]
Out of Compliance: This is not kept or
presented to the DAQ inspector.
The following records are kept:
The time and date of event
Volume of emissions
Any corrective action taken for 3 years.
[R307-5 1 I -s( I )(a)(b)]
Out of Compliance: No records are being
kept. Uinta Wax Operating, LLC
personnel were not willing to make a
statement confirming that there was no
venting of associated gas to the DAQ for
the purposes of determining compliance
with this rule.
NSPS (Part 60) JJJJ: Standards of Performance for Stationary
Spark Ignition Internal Combustion Engines
[40 CFR 60 Subpart JJJJ]
Out of Compliance: Deficiencies in
performance testing and recordkeeping do
not support compliance with this subpart.
Affected engines are certified or have an initial performance test
per 40 CFR60.4244.
[R307-s 10-4(2)]
Out of Compliance: UWO did not have a
performance test on this engine or it did
not keep a record of it. The pump jack
engine is an Arrow A 90, 100+ hp and is
not US EPA certified.
Engines subject to R307-510 (does not have an AO, began
operations, installed or modified after January 1,2016) meet the
following limits:
[R307-s104(1)]
Maximum Ensine ho Emission Standards in e/hn-hr)
NO,CO VOC HC+NO,
>25 hp and < 100 hp 4.85 2.83
>100 hp 1.0 2.0 0.7
Out of Compliance: UWO did not provide
records of a performance stack test on a
non-certified engine to support
compliance with the emissions standards
listed in this rule. The well came into
production in March 2018. At this date
UWO must purchase an EPA certified
engine or conduct a performance stack test
on any non-certified engine relocated or
installed after January 2016, andmeet the
emissions standards published here.
DAQC-CA1s8030001-23
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 l9-2-ll5 of the Utah Code
Annotated provides that violators of the Utah Air Conservation Act andlor any order issued there
under may be subject to a civil penalty of up to $10,000 per day for each violation.
When considering if the potential violation(s) are resolved, the DAQ will consider the written
response to this CA. Responses may include information demonstrating compliance with the
regulations or an anticipated schedule from your company to become compliant with the
applicable regulations. Once received, the DAQ will review your response and the 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 shall be
considered in the escalation of subsequent enforcement action and 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 additional enforcement options.
Additionally, this CA does not constitute abar 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 Chris Jensen at 435-828-0141 or
[e-mail] if you would like to request a meeting or if you have any questions.
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STAH DIVISION OF AIR QUALITY
EOMPLIANCE SECTION
BOX 144820
T LAKE CITY UT 84I14.4820
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KAYLENE BNDWELL, SENIOR ENGINEER
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FORT WORTH, TX 76109
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