DAQ-2025-000571

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DAQC-PBR101851001-25
Site ID 101851 (B1)
MEMORANDUM

TO: FILE – WEM OPERATING, LLC – Antelope Production Facility

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

FROM: Chris Jensen, Environmental Scientist

DATE: January 15, 2025

SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION

INSPECTION DATE: November 26, 2024

SOURCE LOCATION: Lat: 40.10068 Long: -110.2968
Duchesne County

Business Office:
WEM Operating, LLC
3319 North University Avenue Suite 200
Provo, UT 84064

SOURCE TYPE: Multi-well Tank Battery

API: 4301354527, 4301354528, 4301354529

SOURCE CONTACTS: Lynn Hadlock, Field Contact
Phone: [phone], Email: [e-mail]
Tyson Pond, Corporate Environmental Contact
Phone: [phone], 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 & 40 CFR
60 Subpart OOOOb.

# - $ . ) . )
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SOURCE EVALUATION: Site Type: PBR-Controlled
Controlled by flare, Site powered by Engine. The source did not
Register Oil Production.
DOGM current 12 month rolling production is: 318,423 BBLs
for a 5 month period.
Utah Statute R307-506 requires a source with throughput
greater than 8,000 BBLs to have controls.

REGISTERED EQUIPMENT: Engine - 4-Stroke Rich Burn Make: Caterpillar Model: G3508
ULB Mfg Yr: TBD Horse Power: 690 hp Fuel: NG, Pneumatic,
Tank General Provisions 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 detected by use of the USEPA Method 9. VOC emissions are, at all times, minimized as reasonably practicable by equipment design, maintenance and operation practices. [R307-501-4(1)] In Compliance. Each tank in the battery is controlled with an isolating valve and PRV. Thief hatches were found closed. The location is new, clean, and well kept. All equipment is installed as expected and an OGI camera inspection found no leaking components. 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. This source does not use continuous bleed natural gas-driven pneumatic controllers. The control function is performed by a SureFire BMS with electric actuators or instrument air at the treater. 8Flares Any flare has an operational auto-igniter and a continuously burning pilot flame. [R307-503-4] In Compliance. Steffes Air assisted candle stick flare is installed. 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. [R307-501-4(1)]] In Compliance. These required components are all present. 11 Tank Truck Loading 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. A vapor capture line is used during truck loading if subject to storage vessel emissions controls of R307-506-4(2). [R307-504-4(2)] In Compliance. This source has the required vapor capture line installed.
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14Storage Vessels Thief hatches are kept closed and latched. [R307-506-4(1)] In Compliance. All hatches were found closed at the start of the evaluation. 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 destroyed by a Steffes air assisted flare. Emissions from emergency storage vessels (NOT used as a storage tank) are controlled according to R307-506-4(2) - or - are only used in emergencies, are emptied within 15 days of receiving fluids and are equipped with a liquid level gauge. [R307-506-4(4)] In Compliance. No tanks are uncontrolled or used as an emergency tank. 22 Combustors and VOC Control Devices: Air pollution control equipment is installed appropriately, maintained and operated, pursuant to the manufacturers’ specifications, to control emissions. [R307-501-4(2)] In Compliance. This equipment is installed and operating as expected. Vessel vent lines are sloped to a cow belly 2 phase separator. All of the usual spark arrestors, gauge, and burner management system is in place. The flare has a continuous pilot flame. Vessel vent lines are sloped away from the flare inlet or to a separation vessel (scrubber). [R307-501-4(2)] In Compliance. 29 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. 32 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 is gathered to a sales line. An auto shut down device is installed in case of emergency or excessive pressure at the sales line. 35 Recordkeeping Requirements: The source is registered with the DAQ. [R307-505-3(3)] In Compliance.

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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. 41Emission Inventory: An emissions inventory has been submitted within the past three years. [R307-150-9(1)] In Compliance. This source is not yet required to have submitted to the latest survey as it did not exist at the time. Storage Vessels Monthly inspections are conducted according to 40 CFR 60.5416a(c) on the closed vent system, openings, thief hatches and bypass devices if emissions control is required, and defects are repaired within 15 days. [R307-506-4(5)] Out of Compliance. It was months before these evaluations began. No defects were found. Combustors and VOC Control Devices: 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 are kept at the local office for review. Monthly AVO and USEPA method 22 inspections are conducted on VOC control devices and associated equipment, and corrective actions are taken within 5 days and completed within 15 days. [R307-508-3(3)] In Compliance. Though late, these records are being kept at the local office. No corrective action was needed. 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 and USEPA method 22 inspections of the VOC control device(s), associated equipment and any repairs, for 3 years. [R307-508-4] In Compliance. These are kept at the local office for review. 43 Leak Detection and Repair: The source has a source specific emissions monitoring plan. [R307-509-4(1)(a)] In Compliance. The DAQ quickly reviewed the EMP. The monitoring plan addresses difficult-to-monitor and unsafe-to-monitor components. [R307-509-4(1)(b)] In Compliance. This component is present in the plan.
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Monitoring surveys are conducted to observe each fugitive emissions component for fugitive emissions. [R307-509-4(1)(c)] In Compliance. The EMP addresses each component and has a typical walk through map of the location. Initial monitoring surveys were within 60 days after startup for new sources. Subsequent surveys are semi-annual (no further than 7 months nor nearer than 4 months apart) 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)] Out of Compliance. These documents and initial performance surveys were not completed on time. 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. Fugitive leaks are attempted within 5 days and 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)] In Compliance. Resurvey of the repaired components is completed within 30 days. [R307-509-4(1)(g)] In Compliance. 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] In Compliance. Natural Gas Engines Engines subject to R307-510 shall be certified or have an initial performance test per CFR 60.4244. [R307-510-4(2)] In Compliance. The engine in the generator is certified. WEM has a copy of this on file. Engine certifications or initial performance tests required are kept for the life of the engine at the source. [R307-510-5] In Compliance. 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)] In Compliance. EPA certified this engine is compliant with NSPS (60) JJJJ standards. 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)] Not Observed. The DAQ forgot to check the stack height at the electric generator although it does vent vertically.

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Associated Gas Flaring 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 reported venting events or breakdowns. 68 Applicable Federal Regulations NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines. In Compliance. The engines at this source are EPA certified to meet the emissions standards of this subpart. The recordkeeping and maintenance provisions are also met to maintain the certification.
NSPS (Part 60) OOOOb: Standards of Performance for Crude Oil and Natural Gas Facilities for which
Construction, Modification or Reconstruction Commenced After December 6, 2022:
Not in Compliance. This source has an Approval (PBR) from the State of Utah with legal and
enforceable limits. A monitoring, repair, and record keeping program is in place that would satisfy
the requirements of 40 CFR (60) OOOOb for the collection of fugitive emissions components, closed
vent system, and storage vessel facilities. See above evaluations. These installations are installed as
expected and operating properly. There are other affected facilities installed like intermittent bleed
pneumatic controllers and diaphragm pumps but they either use instrument air for actuation or
electric motors and surefire BMS. A reciprocating compressor is installed and operated by J-W.
These have an exemption (in NSPS OOOOb) if installed on an oil well pad. No other affected
facilities like gas well unloading, dehydrators, or sweetening units are installed.
The planning documents like emissions monitoring, engine maintenance, and CVS design analysis
are now complete.
The initial performance inspections (LDAR, AVO, or Method 22) were not completed within 30
days of startup. Additionally, these routine inspections did not commence on time but were delayed
by months.

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PREVIOUS ENFORCEMENT
ACTIONS: None in the past 5 years.

COMPLIANCE STATUS &
RECOMMENDATIONS: Out of Compliance. The source was surveyed by AVO and with
an OGI camera and was found to be well-kept with no visible or
fugitive emissions. Requested records were gathered in a timely
manner for review at the local field office. There are generators
providing electricity for BMS and instrument air to operate
pneumatic diaphragm pumps moving waste fluids to a slop tank
and at the treaters. Each tank in the battery is controlled with an
isolating valve and PRV. The quality assurance measures
(LDAR, AVO, etc.) were not performed in the required first 30
days (NSPS 60 OOOOb) or the first 60 days (UAC
R307-509-4(d)(i)) nor did they meet the regular inspection
interval of quarterly for LDAR or monthly for AVO and Method
22 evaluations. These began approximately 5 months after
startup for the first time. The planning requirements like
emissions monitoring, engine maintenance, and CVS design
analysis are now complete (though not prepared before startup).
WEM is a new operator and this is their first startup of a
location. The DAQ performed compliance assistance and
stressed the importance of timely completion of inspections and
document preparation. The DAQ recommends no further
enforcement action be taken or a Warning Letter be issued to
WEM Operating to reinforce the importance of the monitoring
requirements.

RECOMMENDATION FOR
NEXT INSPECTION: The DAQ recommends watching for LDAR and AVO frequency
as this is a new company.

RECOMMENDATIONS FOR NSR: None

ATTACHMENTS: Warning letter