HomeMy WebLinkAboutDAQ-2025-0003281
DAQC-PBR146990001-25
Site ID 14699 (B1)
MEMORANDUM
TO: FILE – UINTA WAX OPERATING, LLC – Kendall 11-8-3-1E
THROUGH: Rik Ombach, Minor Source Oil and Gas Section Manager
FROM: Stephen Foulger, Environmental Scientist
DATE: January 13, 2025
SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION
INSPECTION DATE: November 15, 2024
SOURCE LOCATION: Lat: 40.23609809 Long: -109.9100679
Business Office:
Uinta Wax Operating, LLC
5128 Apache Plume Road, Suite 300
Fort Worth, TX 76109
SOURCE TYPE: Tank Battery
Uintah
API: 4304752894
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, 40 CFR
60 Subpart OOOO.
SOURCE EVALUATION: Site Type: PBR-Controlled
Voluntarily Controlled by Flare, Site powered by Engine.
DOGM current 12 month rolling production is: 508.
Utah Statute R307-506 requires a source with throughput
greater than 8,000 BBLs to have controls.
/ + # ) * 0 ' " -
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REGISTERED EQUIPMENT: Tanks, Engine, Pneumatics
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. Pneumatic Controllers Truck loading is done by bottom filling or submerged fill pipe [R307-504(1)] In Compliance. Loading found properly engineered 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] Not Applicable. No continuous bleed pneumatic controllers found onsite at the time of inspection. Storage Vessels Thief hatches are kept closed and latched. [R307-506-4(1)] In Compliance. Thief hatches were reviewed with OGI camera at the time of inspection and found to be closed and latched. 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 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 monthly records were reviewed at the time of inspection and were found to be compliant. General Requirements Air pollution control equipment is installed appropriately, maintained and operated, pursuant to the manufacturers specifications, to control emissions. [R307-501-4(2)] Out of Compliance. Combustor found with no pressure regulator on inlet 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)] Out of Compliance. Emissions were found coming from a leaking T12 valve, in addition to emissions being produced at the combustor due to lack of inlet pressure regulator.
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Emission Inventory An emissions inventory has been submitted within the past three years. [R307-150-9(1)] In Compliance. This source was found properly reported in the DAQ emissions inventory. Oil and Gas Industry Registration Requirement The source is registered with the DAQ. [R307-505-3(3)] In Compliance. This source was found properly registered with the DAQ 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 information found properly updated at the time of inspection. Natural Gas Engines 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. Engines subject to R307-510 shall be certified or have an initial performance test per CFR 60.4244. [R307-510-4(2)] Not Applicable. This well was drilled prior to 2016 and the engine is assumed to also been installed prior to 2016. The DAQ assumes this source is not subject to these emissions standards. Engine certifications or initial performance tests required are kept for the life of the engine at the source. [R307-510-5] Not Applicable. This well was drilled prior to 2016 and the engine is assumed to also been installed prior to 2016. The DAQ assumes this source is not subject to these emissions standards. 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)] Not Applicable. This well was drilled prior to 2016 and the engine is assumed to also been installed prior to 2016. The DAQ assumes this source is not subject to these emissions standards. Federal Requirements NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines [40 CFR 60 Subpart JJJJ] In Compliance. Applicable records were reviewed at the time of inspection and found to be compliant. NSPS (Part 60) OOOO: Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution [40 CFR 60 Subpart OOOO] In Compliance.
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PREVIOUS ENFORCEMENT
ACTIONS: None in the past 5 years.
COMPLIANCE STATUS &
RECOMMENDATIONS: Out of Compliance. No action recommended at this time.
Operator has been instructed on corrective actions needed.
RECOMMENDATION FOR
NEXT INSPECTION: Recommend to increase inspection frequency.