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HomeMy WebLinkAboutDAQ-2025-0001721 DAQC-PBR159020001-25 Site ID 15902 (B1) MEMORANDUM TO: FILE – UINTA WAX OPERATING, LLC – Kendall Tribal 11-7-6-3-1E-H1 THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager FROM: Stephen Foulger, Environmental Scientist DATE: January 9, 2025 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: November 15, 2024 SOURCE LOCATION: Lat:40.23476, Long: -109.926886 Uintah County Business Office: Uinta Wax Operating, LLC 6000 Western Place, Suite 1000 Fort Worth, TX 76107-4664 SOURCE TYPE: Tank Battery API: 4304753153 SOURCE CONTACTS: 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. Federal Subpart: 40 CFR 60 Subpart JJJJ. SOURCE EVALUATION: Site Type: PBR – Controlled Voluntarily Controlled by Flare, Site powered by Engine. The source registered: 273750 Estimated Oil BBL. DOGM current 12 month rolling production is: 7,363. Utah Statute R307-506 requires a source with throughput greater than 8,000 BBLs to have controls. / + # ) * 0 ' " - 2 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 Visible Emissions Visible emissions are within the following opacity limits: VOC Control Devices and Gasoline engines 0%, Diesel engines 20%, Natural Gas Engines and Boilers, Treater burners & Tank burners 10%, Mobile source dust 10%. [R307-201-3] In Compliance. No visible emissions were observed at the time of inspection. VOC emissions are, at all times, minimized as reasonably practicable by equipment design, maintenance and operation practices. [R307-501-4(1)] In Compliance. Source found voluntarily controlled at the time of inspection. All natural gas-driven pneumatic controllers are in compliance with 40CFR 60.5390 or 60.5390a as applicable. Tagging and record keeping requirements are not required. [R307-502-4] In Compliance. No continuous bleed pneumatic controllers found in use at the time of inspection. Pneumatic Controllers Truck loading is done by bottom filling or submerged fill pipe [R307-504(1)] In Compliance. Truck loading found properly set up at the time of inspection. Storage Vessels Thief hatches are kept closed and latched. [R307-506-4(1)] In Compliance. Thief hatches found closed and latched at the time of inspection. Upon modification, the well site was re-evaluated against the thresholds of R307-506-4(2). [R307-506-4(6)] In Compliance. No modifications to the well site were found at the time of inspection. Records for each of the following are kept for three years: Monthly storage vessel vent system inspections (openings, thief hatches, pressure relief devices, bypasses, etc.), if controlled. 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. [R307-506-5] In Compliance. These records were reviewed and found compliant at the time of inspection. 3 General Requirements Air pollution control equipment is installed appropriately, maintained and operated, pursuant to the manufacturers specifications, to control emissions. [R307-501-4(2)] In Compliance. Emissions control equipment found properly maintained and installed at the time of inspection. Engine Requirements Engines subject to R307-510 shall be certified or have an initial performance test per CFR 60.4244. [R307-510-4(2)] Out of Compliance. These records were not supplied to the inspector even after requests were made. Engine certifications or initial performance tests required are kept for the life of the engine at the source. [R307-510-5] Out of Compliance. These records were not supplied to the inspector even after requests were made. Engines that were installed, relocated or modified after January 1, 2016 are required to show compliance with Table 1 of R307-510-4 through a performance test evaluation that is reviewed by the DAQ and found to be in compliance. [R307-510-4(1)] Out of Compliance. These records were not supplied to the inspector even after requests were made. Emissions Inventory Requirement An emissions inventory has been submitted within the past three years. [R307-150-9(1)] In Compliance. Source found properly reported in the emissions inventory. Oil and Gas Industry Registration Requirement The source is registered with the DAQ. [R307-505-3(3)] In Compliance. Source found properly registered at the time of inspection. 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. Source registration found properly updated at the time of inspection. Federal Requirements NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines [40 CFR 60 Subpart JJJJ] In Compliance. 4 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] In Compliance. PREVIOUS ENFORCEMENT ACTIONS: None in the past 5 years. COMPLIANCE STATUS & RECOMMENDATIONS: Not in Compliance. No further action recommended at this time. Engine records have not been kept properly. Uinta Wax Operating, LLC has been made aware of this issue and instructed on needed corrective actions. RECOMMENDATION FOR NEXT INSPECTION: Recommend to increase inspection frequency. ATTACHMENTS: None.