The URL can be used to link to this page

Home My WebLink AboutDAQ-2024-0045441 DAQC-PBR155110001-23 Site ID 15511 (B1) MEMORANDUM TO: FILE – UINTA WAX OPERATING, LLC – Tryon 10-19-2-1E THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager FROM: Chris Jensen, Environmental Scientist DATE: November 6, 2023 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: November 1, 2023 SOURCE LOCATION: Tryon 10-19-2-1E Lat: 40.294334 Long: -109.926569 Business Office: 5128 Apache Plume Road, Suite 300 Fort Worth, TX 76109 SOURCE TYPE: Tank Battery Uintah County API: 43-047-55178 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) OOOOa. SOURCE EVALUATION: Site Type: PBR-Controlled Controlled by flare Site has Line Power 2 DOGM current 12 month rolling production is: 19,250 BBls. Utah Statute R307-506 requires a source with throughput greater than 8,000 BBLs to have controls. REGISTERED EQUIPMENT: 3 General Provisions 4 VOC emissions are minimized as reasonably practicable by equipment design, maintenance and operation practices. [R307-501-4(1)] In Compliance. The expected components were found installed. 5 Air pollution control equipment is designed and installed appropriately, maintained and operated to control emissions. [R307-501-4(2)] Out of Compliance. A suggested pressure valve has not been installed. This ECD is a Cimarron brand combustor and the DAQ has seen the manufacturers' 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. 6 Vessel vent lines are sloped away from the flare inlet or to a separation vessel (scrubber). [R307-501-2] In Compliance. The vent lines to the ECD are sloped properly. Lines to the candlestick flare run along the ground but this one is used for flaring of associated gas under pressure. 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. No pressure regulating installed. 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 10 Flares 11 Any flare has an operational auto-igniter. [R307-503-4] In Compliance. This task is managed by the ECD control box. 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. 3 14 A vapor capture line is used during truck loading if subject to storage vessel emissions controls of R307-506-4(2). Effective 7/1/2019 for sources existing before 1/1/2018, and upon construction for new sources. [R307-504-4(2)] In Compliance. This source has the required vapor capture line installed. 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. 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 Cimarron 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 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. These inspections were conducted twice a year. 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, in excess of seven months apart as required by 40 CFR (60) OOOO and this requirement. 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)] Out of Compliance. The latest survey found 3 leaking components. A thief hatch was repaired that day. The other two, a bull plug on the casing at the wellhead, and a regulator in the treater shed did not show, on the form, that a second repair was attempted, a repair was successful, or that it was verified so. 36 Resurvey of the repaired components is completed within 30 days. [R307-509-4(1)(g)] Out of Compliance. UWO did not produced any documentation of a successful repair during the records search portion of the evaluation. 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. 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. 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)] Out of Compliance. UWO was unable to provide any records in support of compliance with this rule and was unwilling to provide a statement of 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. 6 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] Out of Compliance. This source has an Approval Order from 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. There are however, deficiencies in the installation of the ECD. Namely an inlet pressure regulating valve is not installed. The recordkeeping procedures are lacking in that second or final attempts at repair of leaking components are not recorded. A final verification of a successful repair is not recorded. UWO did not present an engineering design analysis for this VCS installation. See above evaluations. There are not other affected facilities installed. PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: Out of Compliance - The February 9, 2023, survey returned leaking components; a thief hatch, little Joe regulator in the treater shed, and a bull plug on the well casing. The leaks were unable to be repaired at first attempt except for the thief hatch repair which was successful. There were no records of a second attempt or verification of a successful repair on the other leaks. The latest survey was completed on September 17, 2023, in excess of the 7 months allowed between surveys and found similar leaks as before. The required inlet pressure regulating valve is not installed. UWO failed to produce an engineering design analysis for this installation. On November 6, 2023, UWO was able to produce other documentation of a successful repair and verification the next day after discovery of the leaks. The DAQ recommends that UWO answer a Compliance Advisory for the components not installed on the ECD. 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 Remain the same. ATTACHMENTS: None.