DAQ-2025-000653

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DAQC-PBR146490001-25
Site ID 14649 (B1)
MEMORANDUM

TO: FILE – UINTA WAX OPERATING, LLC – Gavitte 15-23-3-1E

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

FROM: Stephen Foulger, Environmental Scientist

DATE: January 29, 2025

SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION

INSPECTION DATE: December 20, 2024

SOURCE LOCATION: Lat: 40.20214 Long: -109.8478

Business Office:
Uinta Wax Operating, LLC
6000 Western Place Suite 1000
Fort Worth, TX 76107

SOURCE TYPE: Tank Battery
Uintah County
API: 4304752987, 4304754717

SOURCE CONTACTS: Josh Morgan, Field Contact
Phone: [phone], Email: [e-mail]
Karen Pratt, Corporate Environmental Contact
Phone: [phone], Email: [e-mail]
Kaylene Bridwell, 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 OOOO.

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SOURCE EVALUATION: Site Type: PBR-Uncontrolled
No Flare Controls, Site powered by Engine.
DOGM current 12 month rolling production is: 6,224.
Utah Statute R307-506 requires a source with throughput
greater than 8,000 BBLs to have controls.

REGISTERED EQUIPMENT: Tanks, Engines, 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 leaks were detected coming from the produced water tank thief hatch and a T12 on the tank back burner. Pneumatic Controllers 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. 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. 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. Combustor was found removed only after production dropped to an appropriate level.

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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. Produced water tank thief hatch found leaking emissions 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 to be in compliance at the time of inspection. Emission Inventory An emissions inventory has been submitted within the past three years. [R307-150-9(1)] In Compliance. Emissions Inventory found properly submitted 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 with the DAQ 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)] Not Applicable. Engines on-site predate these requirements. Engine certifications or initial performance tests required are kept for the life of the engine at the source. [R307-510-5] Not Applicable. Engines on-site predate these requirements. 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. Engines on-site predate these requirements. Federal Requirements NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines [40 CFR 60 Subpart JJJJ] In Compliance. Maintenance records were reviewed at the time of inspection and found to be in compliance. 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 further action is recommended at this
time. Both small emissions leaks detected during the inspection
have been resolved.

RECOMMENDATION FOR
NEXT INSPECTION: Recommend to increase inspection frequency.

ATTACHMENTS: None.