DAQ-2024-010543

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DAQC-PBR046980001-24
Site ID 4698 (B1)
MEMORANDUM

TO: FILE – WESCO OPERATING, INC. – Cane Creek Unit 2-1

THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Manager

FROM: Paul Bushman, Environmental Scientist

DATE: September 18, 2024

SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION

INSPECTION DATE: September 12, 2024

SOURCE LOCATION: Lat: 38.57302 Long: -109.784166

Business Office:
Wesco Operating, Inc.
120 South Durbin Street
P.O. Box 1650
Casper, WY 82602

SOURCE TYPE: Tank Battery
Grand
API: 4301931396

SOURCE CONTACTS: Dave Weinert, Corporate Environmental Contact
Phone: [phone]
Email: [e-mail]
Jeff Miller, Local Contact
Email: [e-mail]

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. Federal Subpart: 40 CFR 60 Subpart JJJJ.

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SOURCE EVALUATION: Site Type: PBR-Controlled
Voluntarily controlled by flare, site powered by engine. The
source registered: 7,444 Estimated Oil BBL.
DOGM current 12 month rolling production is: 4,535 BBLs.
Utah Statute R307-506 requires a source with throughput
greater than 8,000 BBLs to have controls.

REGISTERED EQUIPMENT: Engine - Engine - Natural Gas 2-Stroke Lean Burn Make -
Arrow Model - C-106 Mfg Year - 2008 Horse Power - 32
Combustion - Natural Gas, Pneumatic, Tank
General Provisions VOC emissions are minimized as reasonably practicable by equipment design, maintenance and operation practices. [R307-501-4(1)] In Compliance. VOC emissions appeared to be minimized as reasonably as practicable. Air pollution control equipment is designed and installed appropriately, maintained and operated to control emissions. [R307-501-4(2)] Out of Compliance. A small emission leak was detected from a thief hatch during the inspection. An unsuccessful attempt was made to repair the thief hatch at the time of inspection. The thief hatch was replaced on September 17, 2024. No action is recommended at this time. Vessel vent lines are sloped away from the flare inlet or to a separation vessel (scrubber). [R307-501-2] In Compliance. Vessel vent lines were sloped away from the combustor inlet. 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. Combustor inlet appeared to be properly designed. Pneumatic Controllers 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. Flares Any flare has an operational auto-igniter. [R307-503-4] In Compliance. The enclosed combustor is equipped with an operational auto-igniter. Tank Truck Loading Truck loading is done by bottom filling or submerged fill pipe [R307-504(1)] In Compliance. Trucks are loaded via submerged filling.

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Oil and Gas Industry Registration Requirement
The source is registered with the DAQ. [R307-505-3(3)]
In Compliance. Source was properly registered at the time of inspection.

Storage Vessels
Thief hatches are kept closed and latched. [R307-506-4(1)]
In Compliance. Thief hatches were found closed and latched during the inspection.

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. Emissions are voluntarily controlled from tanks.

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. Records are kept as required. See attachments.

VOC Control Devices

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 source is voluntarily controlled. The enclosed combustor was operating with
no visible emissions, was equipped with an operational auto-igniter, and has a control efficiency of
95% or greater. See attachments.

Natural Gas Engines

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. The Arrow C-106 Pumpjack engine, SN: 303851c was stack tested on December
28, 2022. See DAQC-079-23.

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Affected engines are certified or have an initial performance test per 40 CFR 60.4244. [R307-510-4(2)]
In Compliance. The Arrow C-106 Pumpjack engine, SN: 303851c was stack tested on December
28, 2022. See DAQC-079-23.
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.
Engine certifications or initial performance tests required are kept for the life of the engine at the source.
[R307-510-5]
In Compliance.

Associated Gas Flaring

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 appeared to be properly routed during the inspection.

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 events were reported at the time of inspection.

Visible Emissions

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 observed from any point during the inspection.

Emission Inventory:

An emissions inventory has been submitted within the past three years. [R307-150-9(1)]

In Compliance.

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NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines [40 CFR 60 Subpart JJJJ]

In Compliance. The Arrow C-106 Pumpjack engine, SN: 303851c was stack tested on December 28, 2022. See DAQC-079-23. The engine is operated and maintained according to manufacturer's
specifications.

PREVIOUS ENFORCEMENT
ACTIONS: Compliance Advisory (DAQC-1215-22) issued September 14,
2022, for failing to stack test the Arrow C-106 engine.
Early Settlement Agreement (DAQC-142-23) issued February 2,
2023, addressing the above Compliance Advisory.

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to the site, the overall status is: Out of Compliance.
The source was found with a small leak coming from a thief
hatch during the inspection. The operator attempted to repair the
leak during the inspection, however, the thief hatch needed to be
replaced. The source replaced the thief hatch on September 17,
2024. No further action is recommended at this time.

RECOMMENDATION FOR
NEXT INSPECTION: None.

RECOMMENDATIONS FOR NSR: None.

ATTACHMENTS: Applicable supporting documentation included.
Combustor Type
Month Oil Gas Water Oil Gas Water Oil Gas Water Oil Gas Water Oil Gas Water Oil Gas Water Oil Gas Water Oil Gas Water
Aug-23 4 0 0 231 130 166 574 674 2747 34 1 0 927 536 482 0 0 0 18 0 0 391 58 135
Sep-23 180 11 0 281 123 147 88 152 619 307 2 0 913 673 613 0 1 204 13 0 0 379 56 58
Oct-23 77 3 0 318 110 187 350 399 1309 147 1 0 1185 684 975 313 293 325 21 0 0 375 58 68
Nov-23 90 30 0 483 206 200 523 466 1977 19 6 0 802 1500 694 227 259 231 23 5 0 368 56 60
Dec-23 77 2 0 586 210 145 603 441 2219 0 0 0 820 2859 576 15 118 192 21 3 0 390 58 65
Jan-24 29 1 0 242 310 111 565 643 2189 0 0 0 825 657 497 0 0 0 15 0 0 323 173 43
Feb-24 79 0 0 226 258 111 582 489 3138 0 0 0 1065 533 630 0 0 0 21 0 0 415 167 77
Mar-24 56 0 0 26 10 69 688 437 3168 0 0 0 1108 717 781 0 12 260 21 0 0 383 199 55
Apr-24 49 0 0 0 0 0 667 943 2884 0 0 0 1063 730 657 0 0 0 17 0 0 393 192 65
May-24 49 0 0 0 24 124 786 1240 3120 74 70 0 1687 1424 854 372 335 285 25 0 0 383 198 57
Jun-24 19 0 0 837 391 109 287 465 1152 246 397 0 1021 1881 892 239 189 297 15 0 0 365 199 72
Jul-24 28 0 0 478 312 103 821 1146 2880 105 255 0 1275 1762 524 188 213 175 21 0 0 370 199 37
Total 737 47 0 3708 2084 1472 6534 7495 27402 932 732 0 12691 13956 8175 1354 1420 1969 231 8 0 4535 1613 792
Cane Creek 24-1
48" HVECD
Cane Creek 24-2
48" HVECD
Cane Creek 12-1
48" HVECD
Cane Creek 36-3
48" HVECD
Cane Creek 2-1
60" ECD
Cane Creek 12-2
48" HVECD
Cane Creek 36-1
48" HVECD
Cane Creek 36-2
48" HVECD