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Home My WebLink AboutDAQ-2025-0006461 DAQC-PBR102052001-25 Site ID 102052 (B1) MEMORANDUM TO: FILE – UINTA WAX OPERATING, LLC – Gray Pad THROUGH: Rik Ombach, Minor Source Oil and Gas Section Manager FROM: Stephen Foulger, Environmental Scientist DATE: January 27, 2025 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: December 6, 2024 SOURCE LOCATION: Lat: 40.22872 Long: -109.90389 Business Office: Uinta Wax Operating, LLC 5128 Apache Plume Road, Suite 300 Fort Worth, TX 76109 SOURCE TYPE: Tank Battery Uintah County API: 4304757012, 4304757014, 4304757015, 4304757015, 4304757018 SOURCE CONTACTS: Karen Pratt, Corporate Environmental Contact Phone: 720-990-9927, Email: kpratt@finleyresources.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 Controlled by flare, Site powered by Engine. The source registered: 955,868 Estimated Oil BBL. DOGM current 12 month rolling production is: 140,752. Utah Statute R307-506 requires a source with throughput greater than 8,000 BBLs to have controls. / + # ) * 0 ' " - 2 REGISTERED EQUIPMENT: Engine - 6 Doosan 21.9L, 460hp Field Gas, 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 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. Several small VOC emissions leaks were detected 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 on-site at the time of inspection. Flares Any flare has an operational auto-igniter and a continuously burning pilot flame. [R307-503-4] In Compliance. Flare found with operational auto-igniter and a continuously burning pilot flame at the time of inspection. 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. Flare inlet lines found properly engineered at the time of inspection. Tank Truck Loading Truck loading is done by bottom filling or submerged fill pipe [R307-504(1)] In Compliance. Truck loading found properly engineered at the time of inspection. 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. Vapor capture line found available for use 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. 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. VOCs found properly routed and controlled at the time of inspection. 3 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 emergency storage vessels found on-site at the time of inspection. Combustors and VOC Control Devices: Air pollution control equipment is installed appropriately, maintained and operated, pursuant to the manufacturer’s specifications, to control emissions. [R307-501-4(2)] In Compliance. Control equipment found properly installed, maintained, and operated at the time of inspection. Vessel vent lines are sloped away from the flare inlet or to a separation vessel (scrubber). [R307-501-4(2)] In Compliance. Vessel vent lines found properly sloped at the time of inspection. 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 found properly routed at the time of 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 associated gas flaring reported at the time of inspection. 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)] In Compliance. Monthly inspections found properly conducted and recorded. Leaks found addressed within 15 days. Emission Inventory: An emissions inventory has been submitted within the past three years. [R307-150-9(1)] In Compliance. This is a new source that has not been subject to an emissions inventory at the time of inspection. Leak Detection and Repair: The source has a source specific emissions monitoring plan. [R307-509-4(1)(a)] In Compliance. Monitoring plan reviewed and found to be compliant at the time of inspection. The monitoring plan addresses difficult-to-monitor and unsafe-to-monitor components. [R307-509-4(1)(b)] In Compliance. Monitoring plan addresses these areas of concern. 4 Monitoring surveys are conducted to observe each fugitive emissions component for fugitive emissions. [R307-509-4(1)(c)] In Compliance. Monitoring surveys reviewed and found to be properly conducted at the time of inspection. 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)] In Compliance. Monitoring surveys found properly conducted at the time of inspection. Monitoring surveys are done with OGI equipment or by Method 21. [R307-509-4(1)(e)] In Compliance. Monitoring surveys were found to be conducted using OGI cameras. 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. Fugitive leaks found properly addressed at the time of inspection. Resurvey of the repaired components is completed within 30 days. [R307-509-4(1)(g)] In Compliance. Repaired components found properly resurveyed. 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. LDAR records found properly kept at the time of inspection. 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 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. Engine exhaust vents found vertical and at the appropriate height. Engines subject to R307-510 shall be certified or have an initial performance test per CFR 60.4244. [R307-510-4(2)] In Compliance. Engine certification found in compliance at the time of inspection. 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. Engine certification found in compliance at the time of inspection. 5 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 were found in compliance at the time of inspection. 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. Monthly AVO's found properly conducted. 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 records were reviewed and found to be compliant at the time of inspection. NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines [40 CFR 60 Subpart JJJJ] In Compliance. Engine maintenance found properly conducted and records maintained at the time of inspection. PREVIOUS ENFORCEMENT ACTIONS: None in the past 5 years. COMPLIANCE STATUS & RECOMMENDATIONS: Out of Compliance. No further action recommended at this time. Some small leaks were detected and were promptly addressed. RECOMMENDATION FOR NEXT INSPECTION: Recommend to increase inspection frequency. ATTACHMENTS: None.