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Home My WebLink AboutDAQ-2024-004808 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-1172-23 Site ID 15510 (B1) Sent Via Certified Mail No. 70190700000208346184 Kaylene Bridwell, Senior Engineer Uinta Wax Operating, LLC 5128 Apache Plume Road, Suite 300 Fort Worth, TX 76109 Dear Ms. Bridwell, Re: Compliance Advisory – Uinta Wax Operating, LLC, Utah Administrative Code (UAC)R307-501, R307-508, R307-511, 40 CFR Part 60 Subpart OOOOa (NSPS (60) OOOOa), Uintah County On October 18, 2023, a representative of the Utah Division of Air Quality (DAQ) conducted a Full Compliance Evaluation of Uinta Wax Operating, LLC Babb 6-24-2-1E Production Tank Battery. The DAQ observed a leaking thief hatch on the center tank of the battery and an enclosed combustor (ECD) that was not combusting as expected to achieve 95% destruction efficiency and did not have all of the expected components installed for proper operation. All of which may be a violation(s) of UAC R307-501, UAC R307-508, or NSPS (60) OOOOa. Uinta Wax Operating, LLC is required to comply with the above regulations. No reply is due to the DAQ concerning this matter unless there is additional information you would like to have considered. This Compliance Advisory will be submitted to the USEPA for potential inclusion in the Joint Consent Decree being negotiated at this time. Additional details about the above observations and regulations are attached to this letter. Please contact Chris Jensen at 435-828-0141 or chrisjensen@utah.gov if you have any questions about this letter. Sincerely, Rik Ombach, Manager Minor Source Oil and Gas Compliance Section RO:CJ:rh cc: TriCounty Health Department December 2, 2023 DAQC-1172-23 Page 2 Potential Violation(s) On October 18, 2023, an inspector from the DAQ observed Uinta Wax Operating, LLC at Babb 6-24-2-1E Production Tank Battery in rural Uintah County, Utah. At the time of the inspection the DAQ documented the following potential violation(s): • A leaking thief hatch on the center storage tank in the battery was not sealed and properly seated, operated with no detectable emissions, nor maintained to minimize emissions. • An ECD was found to be operating less than normally expected and not likely meeting the 95% destruction efficiency standard as evidenced by: a low combustion chamber temperature, no visible flame from the rails, and persistent and trailing OGI images from the top of the exhaust stack. These conditions suggest unburned hydrocarbons. • The expected components (pressure regulating valve & pressure gauge) for proper operation, or those listed by the manufacturer, (ensuring minimum inlet pressures for 95% destruction efficiencies) of the ECD were not installed. • The recordkeeping requirements of associated gas venting events were not presented to the DAQ and are assumed not kept. AO Conditions/Rules UAC R307-501-4 (1)(a) “All crude oil, condensate, and intermediate hydrocarbon liquids collection, storage, processing and handling operations, regardless of size, shall be designed, operated and maintained so as to minimize emission of volatile organic compounds to the atmosphere to the extent reasonably practicable.” (2)(a) “All air pollution control equipment shall be operated and maintained pursuant to the manufacturing specifications or equivalent to the extent practicable and consistent with technological limitations and good engineering and maintenance practices.” (c) “In addition, all such air pollution control equipment shall be adequately designed and sized to achieve the control efficiency rates established in rules or in approval orders issued under R307-401 and to handle reasonably foreseeable fluctuations in emissions of VOCs during normal operations. UAC R307-508-3 (1) “A VOC control device required by Rule R307-506 or R307-507 must have a control efficiency of 95% or greater.” UAC R307-511-5 (1) “The owner or operator shall maintain records for emergency releases under Subsection R307-511-4(1).” (a) “The time and date of event, volume of emissions and any corrective action taken shall be recorded.” DAQC-1172-23 Page 3 40 CFR (60) OOOOa 60.5411 (c)(2) “You must design and operate a closed vent system with no detectable emissions, as determined using olfactory, visual, and auditory inspections or optical gas imaging inspections as specified in § 60.5416a(c).” 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 Chris Jensen at 435-828-0141 or chrisjensen@utah.gov if you would like to request a meeting or if you have any questions about this letter.