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HomeMy WebLinkAboutDAQ-2025-0003301 DAQC-PBR147050002-25 Site ID 14705 (B1) MEMORANDUM TO: FILE – UINTA WAX OPERATING, LLC – Womack 5-8-3-1E THROUGH: Rik Ombach, Minor Source Oil and Gas Section Manager FROM: Stephen Foulger, Environmental Scientist DATE: January 3, 2025 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: November 15, 2024 SOURCE LOCATION: Lat: 40.23861 Long: -109.914695 Business Office: Uinta Wax Operating, LLC 5128 Apache Plume Road, Suite 300 Fort Worth, TX 76109 SOURCE TYPE: Tank Battery Uintah API: 43-047-52887 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: 1,752. Utah Statute R307-506 requires a source with throughput greater than 8,000 BBLs to have controls. / + # ) * 0 ' " - 2 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. 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 two leaking T12 valves, in addition to emissions being produced at the combustor due to lack of inlet pressure regulator. 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. 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. 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. 3 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)] Natural Gas Engines In Compliance. Source information found properly updated at the time of inspection. 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 in 2014. The Arrow pump jack engine installed here is assumed to have been installed pre-2016 and not likely 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 in 2014. The Arrow pump jack engine installed here is assumed to have been installed pre-2016 and not likely 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 in 2014. The Arrow pump jack engine installed here is assumed to have been installed pre-2016 and not likely subject to these emissions standards. 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. 4 PREVIOUS ENFORCEMENT ACTIONS: Compliance Advisory issued in April of 2024. COMPLIANCE STATUS & RECOMMENDATIONS: Not Compliant. No action recommended at this time. Operator has been instructed on corrective actions needed. RECOMMENDATION FOR NEXT INSPECTION: Increased, more frequent.