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Home My WebLink AboutDAQ-2024-0045431 DAQC-PBR155100001-23 Site ID 15510 (B1) MEMORANDUM TO: FILE – UINTA WAX OPERATING, LLC – Babb 6-24-2-1E THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager FROM: Chris Jensen, Environmental Scientist DATE: October 23, 2023 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: October 18, 2023 SOURCE LOCATION: Babb 6-24-2-1E Lat: 40.29613 Long: -109.83279 Business Office: 5128 Apache Plume Road, Suite 300 Fort Worth, TX 76109 SOURCE TYPE: Tank Battery Uintah County API: 4304755270 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, 40 CFR 60 Subpart OOOOa and 40 CFR 60 Subpart JJJJ. ) 0 2 SOURCE EVALUATION: Site Type: Minor Source Controlled by flare Site powered by Engine (generator) DOGM current 12 month rolling production is: 15,764 BBLs. Utah Statute R307-506 requires a source with throughput greater than 8,000 BBLs to have controls. REGISTERED EQUIPMENT: Generator with a Doosan engine. 3 General Provisions 4 VOC emissions are minimized as reasonably practicable by equipment design, maintenance and operation practices. [R307-501-4(1)] Out of Compliance. The thief hatch on the center tank is leaking. There were no other fugitive emissions found. 5 Air pollution control equipment is designed and installed appropriately, maintained and operated to control emissions. [R307-501-4(2)] Out of Compliance. The enclosed combustor does not have an inlet pressure regulating control valve installed. The burner tips on the combustor rails do not exhibit a flame or signs of complete combustion. A thief hatch on the center tank is leaking. This condition likely is contributing to the poor operation of the ECD. 6 Vessel vent lines are sloped away from the flare inlet or to a separation vessel (scrubber). [R307-501-2] In Compliance. Line is sloped correctly. 7 Flare inlet lines are equipped with a fire arrestor, pressure gauge, inlet pressure regulating valve and other components according to the engineering design, the manufacturers specifications or good practices for safety and emissions control. [R307-501-2] Out of Compliance. A suggested pressure regulating valve has not been installed. This ECD is a Cimarron brand combustor and the DAQ has seen the manufacturer’s requirement of a pressure regulating valve and gauge listed in all of the installation booklets it has reviewed. This source is not combusting properly. It has a very low (nearly undetectable) rail flame and a persistent plume exiting the stack suggesting incomplete destruction of hydrocarbons. 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 10 Flares 11 Any flare has an operational auto-igniter. [R307-503-4] In Compliance. A control box is installed that performs this function. 3 12 Tank Truck Loading 13 Truck loading is done by bottom filling or submerged fill pipe. [R307-504(1)] In Compliance. The truck loading area is suitable for submerged loading and it is routine for truck drivers to load this way. 14 A vapor capture line is used during truck loading if subject to storage vessel emissions controls of R307-506-4(2). Effective July 1, 2019, for sources existing before January 1, 2018, and upon construction for new sources. [R307-504-4(2)] In Compliance. 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. No updates needed. 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. 20 VOCs from storage vessels are recycled, recovered or controlled by a device that is compliant with R307-508. Exempt if < 8000 bbls crude oil per year, < 2000 bbls condensate, or if uncontrolled emissions are < 4 tons VOC per year. [R307-506-4(2)(a)] In Compliance. Tank emissions are routed to an enclosed combustor. 21 Emissions from emergency storage vessels are controlled according to R307-506-4(2), or are only used in emergencies, are emptied within 15 days of receiving fluids and are equipped with a liquid level gauge. [R307-506-4(4)] In Compliance. There are no emergency storage vessels installed at this source. 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. The recordkeeping procedures of the operator are found to be orderly and complete. These records were reviewed at the local office. 4 25 VOC Control Devices 26 The VOC control device(s) required by R307-506 or R307-507 has a control efficiency of 95% or greater, operates with no visible emissions and has an operational auto-igniter according to R307-503. [R307-508-3(1)] In Compliance. The ECD is a Cimmaron brand combustor and has been certified by the US EPA. 27 Monthly AVO inspections are conducted on VOC control devices and associated equipment, and corrective actions are taken within 15 days. [R307-508-3(3)] In Compliance. The operator supplied inspection forms for review. These inspections were conducted monthly as required by 40 CFR (60) OOOO and this requirement. The operator indicated on the monthly inspection records that they use the EPA method 22 to detect visible emissions. 28 The following records are kept: VOC control device efficiency, for life of the equipment Manufacturer operating and maintenance instructions for VOC control devices, for life of the equipment AVO inspections of the VOC control device(s), associated equipment and any repairs, for 3 years. [R307-508-4] In Compliance. 29 Leak Detection and Repair 30 The source has an emissions monitoring plan. [R307-509-4(1)(a)] In Compliance. A field wide plan was produced to the DAQ for review during the records portion of the evaluation. 31 The monitoring plan addresses difficult-to-monitor and unsafe-to-monitor components. [R307-509-4(1)(b)] In Compliance. Requirement consistent with the Emissions Monitoring Plan required for compliance with NSPS (60) OOOO. 32 If emissions control is required, monitoring surveys are conducted to observe each fugitive emissions component for fugitive emissions. [R307-509-4(1)(c)] In Compliance. Requirement consistent with the Emissions Monitoring Plan required for compliance with NSPS (60) OOOO. 33 Initial monitoring surveys were within 60 days after startup for new sources. Subsequent surveys are semi-annual for regular components, annual for difficult-to-monitor components, and as required by the monitoring plan for unsafe-to-monitor components. [R307-509-4(1)(d)] Out of Compliance. The operator supplied LDAR inspection forms for review. These inspections were conducted twice a year but, one survey was conducted sooner than 4 months apart as required by 40 CFR (60) OOOOa. 34 Monitoring surveys are done with OGI equipment or by Method 21. [R307-509-4(1)(e)] In Compliance. The operator uses a Flir GF 320 OGI camera. 5 35 Fugitive leaks are repaired within 15 days unless infeasible, unsafe, etc., as stated in the rule, which require repair within 24 months per the rule. [R307-509-4(1)(f)] In Compliance. The supplied inspection forms showed that the November 2022, survey found a leaking component that was repaired and verified that day. 36 Resurvey of the repaired components is completed within 30 days. [R307-509-4(1)(g)] In Compliance. 37 The following records are kept: The emissions monitoring plan, for life of the site LDAR inspections, repairs and resurveys, for 3 years [R307-509-5] 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. Generator with a Doosan engine has regular maintenance and retains its certification. This is a continuous use generator and does not require evaluation as an emergency use generator. 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] In Compliance. 43 Associated Gas Flaring 44 Associated gas is routed to a process unit for combustion, a sales pipeline or an operating VOC control device, except in an emergency. An emergency release is unanticipated, temporary, infrequent, unavoidable, =24 hrs. and is not due to operator negligence. Low pressure gas from working loss, breathing loss and oil flashing is not "associated gas". [R307-511-4(1)] In Compliance. Associated gas is gathered to a sales line. 6 45 The following records are kept: The time and date of event Volume of emissions Any corrective action taken for 3 years. [R307-511-5(1)(a)(b)] In Compliance. No records of venting were presented. The emergency bypass in the treater shed has been removed and the piping has been capped. 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. 57 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] Out of Compliance. The leaking thief hatch does not meet the standard of "closed, sealed, and properly seated" as stated in this regulation. 60.5411(b)(2). The operator was not able to present a system design analysis for this installation. 60.5411(d)(1). The installation does not have the manufacturer’s required pressure regulating valve or gauge installed. This VCS will likely not meet the 95% destruction efficiency standard and does not meet the intent of designed, operated, or installed properly. This source is permitted by rule with the State of Utah with legal and enforceable limits. This source is exempt from OOOOa for the collection of fugitive emissions components. A monitoring, repair, and record keeping program is in place that would satisfy the requirements of 40 CFR (60) OOOOa for the collection of fugitive emissions components, closed vent system, and storage vessel facilities. See above evaluations. There are not other affected facilities installed. 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 has been certified as NSPS JJJJ compliant. The recordkeeping and maintenance provisions are also met to maintain the certification. See above evaluations. 7 PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: Out of Compliance - The leaking thief hatch does not meet the standard of closed, sealed, and properly seated (NSPS 60.5411(b)(2)) and maintained to minimize emissions (UAC R307-501). The operator was not able to present a system design analysis for this installation. NSPS 60.5411(d)(1). The installation does not have the pressure regulating valve or gauge, required by the manufacturer, installed. This VCS will not likely meet the 95% destruction efficiency standard (UAC R307-508-3) and does not meet the intent of designed, operated, or installed properly. UAC R307-501-2. Uinta Wax was unable to show that they have been keeping records of events where associated gas was vented to the atmosphere. The DAQ recommends Uinta Wax Operating answer to a Compliance Advisory. 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.