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Home My WebLink AboutDAQ-2024-0071061 DAQC-CI155300001-23 Site ID 15530 (B1) MEMORANDUM TO: FILE – UINTA WAX OPERATING, LLC – Deep Creek 3-25-3-1E THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager FROM: Stephen Foulger, Environmental Scientist DATE: May 26, 2023 SUBJECT: PARTIAL COMPLIANCE EVALUATION, Minor, Uintah County INSPECTION DATE: April 28, 2023 SOURCE LOCATION: 40.198594 -109.833514 Uintah, UT 84000 SOURCE CONTACTS: Lauren Brown, VP. Environmental & Regulatory Phone: (713) 808-9406 Email: lauren@xclresources.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: Approval Order (AO) DAQE-AN155300001-16, dated January 14, 2016 SOURCE EVALUATION: Name of Permittee: Permitted Location: Uinta Wax Operating, LLC - Deep Creek 3-25-3-1E 5128 Apache Plume Road, Suite 300 40.198594 -109.833514 Fort Worth, TX 76109 Uintah, UT 84000 SIC Code: 1311: (Crude Petroleum & Natural Gas) Section I: GENERAL PROVISIONS I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] Status: In Compliance. 2 I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] Status: In Compliance. Review of tank battery showed facility to be in compliance at the time of inspection. I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] Status: In Compliance. I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8] Status: Partial compliance evaluation was conducted at this time records were unevaluated. I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] Status: In Compliance. I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] Status: In Compliance. No reported breakdowns. I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] Status: In Compliance. Upon review of emission inventory source found in compliance. Section II: SPECIAL PROVISIONS II.B Requirements and Limitations II.B.1 Site-Wide Requirements II.B.1.a The owner/operator shall notify the Director in writing when the equipment listed in this AO has been installed and is operational. To ensure proper credit when notifying the Director, send your correspondence to the Director, Attn: Compliance Section. If the owner/operator has not notified the Director in writing within 18 months from the date of this AO on the status of the construction and/or installation, the Director shall require documentation of the continuous construction and/or installation of the operation. If a continuous program of construction and/or installation is not proceeding, the Director may revoke the AO. [R307-401-18] Status: In Compliance. 3 II.B.1.b The owner/operator shall not allow visible emissions from any stationary point or fugitive emission source on site to exceed 10 percent opacity. [R307-401-8] Status: In Compliance. No emissions exceeded 10 percent opacity at the time of inspection. II.B.1.b.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-201-3] Status: In Compliance. II.B.1.c The owner/operator shall only use natural gas as fuel in the pump-jack engines, boilers and heaters on site. [R307-401-8] Status: In Compliance. II.B.2 Tank Requirements II.B.2.a The owner/operator shall not produce more than 271,852 barrels (1 barrel = 42 gallons) of crude oil per rolling 12-month period. [R307-401-8] Status: In Compliance. 352 BBLs of crude were produced in the preceding 12-month period. II.B.2.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the twentieth day of each month using the most recent 12 months of production data reported to the Utah Division of Oil, Gas and Mining. Records of crude oil production shall be kept for all periods when the plant is in operation. Crude oil production shall be determined by process flow meters and/or sales records. [R307-401-8] Status: In Compliance. II.B.2.b The owner/operator shall load the tanker trucks on site by the use of submerged loading. [R307-401-8] Status: In Compliance. The truck loading area is suitable for submerged loading and it is routine for truck drivers to load this way. II.B.2.c The owner/operator shall keep the storage tank thief hatches closed and latched except during tank unloading or other maintenance activities. [R307-401-8] Status: In Compliance. All hatches were found closed at the start of the evaluation. II.B.2.d The owner/operator shall inspect the thief hatches at least once every three months to ensure the thief hatches are closed, latched, and the associated gaskets, if any, are in good working condition. Records of thief hatch inspections shall include the date of the inspection and the status of the thief hatches. [R307-501] Status: Partial compliance evaluation was conducted at this time records were unevaluated. II.B.3 Pump-Jack Engine Requirements II.B.3.a The stationary engine on site shall comply with 40 CFR 60.4233(d), 40 CFR 60.4233(e), 40 CFR 60.4243(f), 40 CFR 60.4245(a) and 40 CFR 60.4245(b). [40 CFR 60 Subpart JJJJ, R307-401-8] Status: In Compliance. II.B.4 Leak Detection and Repair Requirements II.B.4.a The owner/operator shall conduct a leak detection inspection for each valve(s), flange(s) or other connection, pump(s), compressor(s), pressure relief device(s) or other vent(s), process drain(s), open-ended valve(s), pump seal(s), compressor seal(s), and access door seal(s) or other seal 4 containing or contacting a process stream with hydrocarbons that is associated with each of the approved emission units listed in Section II: Special Provisions. Leak detection inspections shall be conducted according to the following schedule: A. No later than 90 days after startup or 180 days from the date of this AO. B. At least once every 12 months after the initial leak detection inspection. [R307-401-8] Status: Partial compliance evaluation was conducted at this time LDAR records were not evaluated. II.B.4.b Inspections shall be conducted in one of two ways; 1. An analyzer that meets U.S. EPA Method 21, 40 CFR Part 60, Appendix A 2. An optical gas imaging instrument as defined in 40 CFR 60.18(g)(4) The optical gas imaging instrument must meet requirements specified in 40 CFR 60.18(i)(3). Any emissions detected with an optical gas imaging instrument shall be considered a leak in need of repair unless the owner/operator evaluates the leak with an analyzer meeting U.S. EPA Method 21, 40 CFR Part 60 and the analyzer reading is less than 500 ppmv. A reading of 500 ppmv or greater shall be considered a leak in need of repair. Emissions detected from tank gauging, load-out operations, venting of pneumatics, properly operating pressure relief valves, or other maintenance activities shall not be considered leaks. [R307-401-8] Status: Partial compliance evaluation was conducted at this time LDAR records were not evaluated. II.B.4.c The owner/operator is exempt from inspecting a valve, flange or other connection, pump or compressor, pressure relief device, process drain, open-ended valve, pump or compressor seal system degassing vent, accumulator vessel vent, agitator seal, or access door seal under any of the following circumstances: A. The contacting process stream only contains glycol, amine, methanol, or produced water. B. Monitoring could not occur without elevating the monitoring personnel more than six feet above a supported surface or without the assistance of a wheeled scissor-lift or hydraulic type scaffold. C. Monitoring could not occur without exposing monitoring personnel to an immediate danger as a consequence of completing monitoring. D. The item to be inspected is buried, insulated in a manner that prevents access to the components by a monitor probe, or obstructed by equipment or piping that prevents access to the components by a monitor probe. [R307-401-8] Status: Partial compliance evaluation was conducted at this time LDAR records were not evaluated. 5 II.B.4.d If a leak is detected at any time, the owner/operator shall attempt to repair the leak no later than 5 calendar days after detection. Repair of the leak shall be completed no later than 15 calendar days after detection, unless parts are unavailable or unless repair is technically infeasible without a shutdown. The owner/operator shall inspect the repaired leak no later than 15 calendar days after the leak was repaired to verify that it is no longer leaking. If replacement parts are unavailable, the replacement parts must be ordered no later than 5 calendar days after detection, and the leak must be repaired no later than 15 calendar days after receipt of the replacement parts. If repair is technically infeasible without a shutdown, the leak must be repaired by the end of the next shutdown. If a shutdown is required to repair a leak, the shutdown must occur no later than 6 months after the detection of the leak unless the owner/operator demonstrates that emissions generated from the shutdown are greater than the fugitive emissions likely to result from delay of repair. [R307-401-8] Status: Partial compliance evaluation was conducted at this time LDAR records were not evaluated. II.B.4.e Records of inspections and leak detection and repair shall include the following: A. The date of the inspection B. The name of the person conducting the inspection C. Any component not exempt under II.B.4.c that is not inspected and the reason it was not inspected D. The identification of any component that was determined to be leaking E. All records shall be maintained for optical gas imaging instrument as per 40 CFR 60.18(i)(4)(vi) F. The date of first attempt to repair the leaking component G. Any component with a delayed repair H. The reason for a delayed repair 1. For unavailable parts: i. The date of ordering a replacement component ii. The date the replacement component was received 2. For a shutdown: i. The reason the repair is technically infeasible ii. The date of the shutdown iii. Emission estimates of the shutdown and the repair if the delay is longer than 6 months I. Corrective action taken J. The date corrective action was completed K. The date the component was verified to no longer be leaking 6 L. The records of each component exempt under II.B.4.c 1. Type of component 2. Description of qualifying exemption [R307-401-8] Status: Partial compliance evaluation was conducted at this time LDAR records were not evaluated. Section III: APPLICABLE FEDERAL REQUIREMENTS In addition to the requirements of this AO, all applicable provisions of the following federal programs have been found to apply to this installation. This AO in no way releases the owner or operator from any liability for compliance with all other applicable federal, state, and local regulations including UAC R307. AREA SOURCE RULES EVALUATION: The following Area Source Rules were evaluated during this inspection: Oil and Gas Industry: General Provisions [R307-501] Status: In Compliance. A survey with an OGI camera revealed no emissions leaks. Oil and Gas Industry: Pneumatic Controllers. [R307-502] Status: In Compliance. This source does not use continuous bleed natural gas-driven pneumatic controllers as described in 40 CFR § 60.5365(d)(1). Oil and Gas Industry: Tank Truck Loading [R307-504] Status: In Compliance. The truck loading area is compliant with submerged loading standards. This source is currently exempt from the installation of a vapor capture line by registration with an Approval Order. Oil and Gas Industry: Flares. [R307-503] Status: In Compliance. This source is currently exempt from the installation of a flare by registration with an Approval Order. 7 EMISSION INVENTORY: The emissions listed below are an estimate of the total potential emissions (PTE) from Uinta Wax Operating, LLC - Deep Creek 3-25-3-1E on the Approval Order (AO) DAQE-AN155300001-16, dated January 14, 2016. PTE are supplied for supplemental purposes only. Criteria Pollutant PTE tons/yr Actual tons/yr CO2 Equivalent 1363.00 Not reported Carbon Monoxide 8.30 1.87 Nitrogen Oxides 4.11 1.35 Particulate Matter - PM10 0.15 .05 Particulate Matter - PM2.5 0.15 .05 Volatile Organic Compounds 11.41 1.78 PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN155300001-16, dated January 14, 2016: This source was found in compliance at the time of inspection. HPV STATUS: Not Applicable. RECOMMENDATION FOR NEXT INSPECTION: Decreased/less frequent. The source has no previous enforcement action and has dropped below 8,000 bbls of annual production. ATTACHMENTS: