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Home My WebLink AboutDAQ-2024-0074021 DAQC-PBR101697001-23 Site ID 101697 (B1) MEMORANDUM TO: FILE – UINTA WAX OPERATING, LLC – RP Tribal 23N-31W-H2UB, 24N-31W-H6UB, H8UB THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager FROM: Chris Jensen, Environmental Scientist DATE: December 7, 2023 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: November 15, 2023 SOURCE LOCATION: RP Tribal 23N-31W-H2UB, 24N-31W-H6UB, H8UB Lat: 40.20009 Long: -109.95389 Business Office: 5128 Apache Plume Road, Suite 300 Fort Worth, TX 76109 SOURCE TYPE: Tank Battery Uintah County API: 4304756291, 4304756293, 4304756294 SOURCE CONTACTS: Aimee Cole, Local Contact Phone: 720-384-7365, Email: acole@finleyresources.com Kaylene Bridwell, Corporate Environmental Contact Phone: 405-496-7308, Email: kaylene.bridwell@uintawax.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: 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 Subpart JJJJ. 2 SOURCE EVALUATION: Site Type: PBR-Controlled Controlled by flare Site powered by Engine The source registered: 821,250 Estimated Oil BBL. DOGM current 12 month rolling production is: 333,234 BBLs. Utah Statute R307-506 requires a source with throughput greater than 8,000 BBLs to have controls. REGISTERED EQUIPMENT: Engine - Engine - Natural Gas 4-Stroke Rich Burn Make - Doosan Model - D14.6L Mfg Year - 2012 Horse Power - 449 Combustion - Natural Gas, Pneumatic, Tank 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 source was inspected by AVO and with an OGI camera and was found to be well-kept with no visible or fugitive emissions. 5 Air pollution control equipment is designed and installed appropriately, maintained and operated to control emissions. [R307-501-4(2)] In Compliance. An air assisted flare is installed and operating properly. The DAQ looked for design and installation parameters such as: the vessel vent line is sloped away from the inlet of the combustor, a two-phase scrubber is used to separate natural gas liquids or condensates, the combustor has a lit pilot with an auto-ignition device, and the inlet to the combustor is controlled by a pressure regulating device. 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 are sloped properly. 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] In Compliance. The expected components were found 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 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. Auto-ignition is managed by the ECD control box. 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. 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. 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, concerning these requirements, are found to be orderly and complete. 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 brand of flare that 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. 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. The DAQ is not pursuing compliance action if this has not been prepared for each individual source. 31 The monitoring plan addresses difficult-to-monitor and unsafe-to-monitor components. [R307-509-4(1)(b)] In Compliance. Consistent with the Emissions Monitoring Plan requirement 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. The records supplied by the operator met the standards required here. 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)] In Compliance. The operator supplied LDAR inspection forms for review. These inspections were conducted twice a year, no sooner than 4 months apart and no later than 7 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. An LDAR survey was completed on October 9, 2023. The survey found six leaking components. All of them were attempted at repair within the 5 days but one of them took 32 days to repair. Leaks found on April 13, 2023, took 40 days to repair. Leaks found on February 27, 2023, took 22 days to repair. Three leaks were found on December 17, 2022, that took 94, 34, and 94 days to repair. 36 Resurvey of the repaired components is completed within 30 days. [R307-509-4(1)(g)] Out of Compliance. See above. 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] Out of Compliance. These records were reported to have been kept but, the DAQ was not given access to them. UWO prepared a summary of the facts from the reports they have kept instead. The summary appears to be comprehensive and the DAQ accepted the summary this time. 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. There are two electric generators with Doosan 8.1 engines. These are known to the DAQ to be EPA certified. 40 Affected engines are certified or have an initial performance test per 40 CFR 60.4244. [R307-510-4(2)] In Compliance. 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. The stack vents vertically at both generators. 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)] 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. It appeared by interview that events where venting does occur are not being tracked or reported. The DAQ asked for a letter stating that there were no events where associated gas are vented to the atmosphere. This request was refused. UWO and the DAQ are considering this requirement in light of the Joint Consent Decree in progress. 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% 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. Applicable Federal Regulations: 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. Out of Compliance. This source has an Approval Order from the State of Utah with legal and enforceable limits. This source is then 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 except that UWO refused to provide evidence that an engineering design assessment of the vapor control system was conducted and certified as required in this subpart (60.5411a(d)(1)). Recent LDAR surveys found leaks that were not repaired within the 30 days allowed in this subpart. Some repairs are reported to have taken up to 94 days. Monthly AVO inspections for the closed vent system did not include an EPA method 22 evaluation of the control device. There are not other affected facilities installed. 59 NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines. In Compliance. The engines at this source have been certified compliant with NSPS (60) JJJJ. Maintenance is in place to maintain the certification. 7 PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: Out of Compliance – There were several leaking components found during the LDAR surveys conducted in the last year that were not repaired within the period allowed by either State of Utah Rules (15 days) or NSPS regulations (30 days). Considering the negotiations in progress with the USEPA and State of Utah on the Joint Consent Decree, UWO declines to provide an engineering design assessment for this source required by this subpart. In consideration of the Joint Consent Decree with the US EPA, still in negotiation with UWO, no enforcement action is taken. The infractions documented here will be submitted to the USEPA for potential inclusion to the Joint Consent Decree being negotiated at this time. RECOMMENDATION FOR NEXT INSPECTION: The DAQ has no recommendations for the next inspector other than what are customary. ATTACHMENTS: Email, engine maintenance records Well API 10/2023 Bastian Tribal 21-16-3-1W CTB 6907 Bastian Tribal 21-16-3-1W 43-013-54037 Bastian Tribal 22-13-3-1W 43-013-54038 Bastian Tribal 22-14-3-1W 43-013-54039 Bastian Tribal 27-03-3-1W 43-013-54040 Bastian Tribal 27-04-3-1W 43-013-54041 CPG Tribal Battery 49990 CPG Tribal 2-26-35-3-1W-H1 43-047-55650 CPG Tribal 26-2-3-1W 43-047-55760 CPG Tribal 26-3-3-1W 43-047-55762 CPG Tribal 26-6-3-1W 43-047-55763 CPG Tribal 26-7-3-1W 43-047-55758 CPG Tribal 26-8-3-1W 43-047-55757 RP Tribal 22N-31W & 27S-31W 856890 RP Tribal 22N-31W-H6UB 43-013-53479 RP Tribal 22N-31W-H4UB 43-013-53480 RP Tribal 27S-31W-H1UB 43-013-54269 RP Tribal 27S-31W-H2CP 43-047-57043 RP Tribal 27S-31W-H3UB 43-013-54271 RP Tribal 27S-31W-H4CP 43-013-54284 Meacham Tribal 16-24-13-3-1W-H1 CTB 24952 Meacham Tribal 16-24-13-3-1W-H1 43-047-55729 Meacham Tribal 1-25-36-3-1W-H1 43-047-55750 RP27S Battery H6UB & H8UB 294000 RP 27S-31W-H6UB 43-013-53478 Skoufos Tribal 14-22-15-3-1W-H3 43-013-53482 Skoufos Tribal 4-27-34-3-1W-H1 43-013-53483 RP 27S-31W-H8UB 43-013-53484 Skoufos Tribal 13-22-15-3-1W-H1 43-013-53486 RP Tribal 22N-31W-H7UB 43-013-53488 RP Tribal 23N-31W-H2UB, 24N-31W-H6UB, H8UB 333234 RP Tribal 24N-31W-H8UB 43-047-56291 RP Tribal 23N-31W-H2UB 43-047-56293 RP Tribal 24N-31W-H6UB 43-047-56294 Kendall Tribal 4-30-31-3-1E-H3 43-047-53988 14197 Badger 1-26-35-3-1W-H2 & 4-25-36-3-1W-H1 41623 Badger 01-26-35-03-01W-H3 43-047-55747 Badger 01-26-35-03-01W-H2 43-047-55748 Badger 01-26-35-03-01W-H4 43-047-55749 12 Month Rolling Production