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HomeMy WebLinkAboutDAQ-2025-0007811 DAQC-PBR145980001-25 Site ID 14598 (B1) MEMORANDUM TO: FILE – UINTA WAX OPERATING, LLC – Deep Creek 13-24-3-1E THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager FROM: Stephen Foulger, Environmental Scientist DATE: February 3, 2025 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: December 20, 2024 SOURCE LOCATION: Lat:40.2022, Long: -109.838211 Uintah County Business Office: Uinta Wax Operating, LLC 6000 Western Place, Suite 1000 Fort Worth, TX 76107 SOURCE TYPE: Tank Battery API: 4304751920 SOURCE CONTACTS: Josh Morgan, Field Contact Phone: 817-231-8756, Email: JMorgan@finleyresources.com Karen Pratt, Corporate Environmental Contact Phone: 720-990-9927, Email: kpratt@finleyresources.com 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: / + # ) * 0 ' " - 2 General Emission Standards; and UAC R307-150: Emission Inventories. Federal Subpart: 40 CFR 60 Subpart OOOO. SOURCE EVALUATION: Site Type: PBR – Uncontrolled No Flare Controls, Site powered by Engine. DOGM current 12 month rolling production is: 1,965. Utah Statute R307-506 requires a source with throughput greater than 8,000 BBLs to have controls. REGISTERED EQUIPMENT: Tanks, Pneumatics, Engine. 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)] In Compliance. VOC emissions found properly minimized and controlled 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 on-site at the time of inspection. 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. 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. Source control was removed after production dropped to an appropriate level. 3 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 compliant at the time of inspection. General Requirements Air pollution control equipment is installed appropriately, maintained and operated, pursuant to the manufacturers specifications, to control emissions. [R307-501-4(2)] In Compliance. Control equipment found properly installed, maintained, and operated at the time of inspection. Emission Inventory: An emissions inventory has been submitted within the past three years. [R307-150-9(1)] In Compliance. Source found properly reported in the emissions inventory. Oil and Gas Industry Registration Requirement The source is registered with the DAQ. [R307-505-3(3)] In Compliance. Source 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)] Not Applicable. Engine on-site predates this regulation. Engines subject to R307-510 shall be certified or have an initial performance test per CFR 60.4244. [R307-510-4(2)] Not Applicable. Engine on-site predates this regulation. 4 Engine certifications or initial performance tests required are kept for the life of the engine at the source. [R307-510-5] Not Applicable. Engine on-site predates this regulation. 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. Engine on-site predates this regulation. Federal Regulations NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines [40 CFR 60 Subpart JJJJ] In Compliance. Engine maintenance records found properly kept at the time of inspection. NSPS (Part 60) OOOO: Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution [40 CFR 60 Subpart OOOO] In Compliance. PREVIOUS ENFORCEMENT ACTIONS: None in the past 5 years. COMPLIANCE STATUS & RECOMMENDATIONS: In Compliance. RECOMMENDATION FOR NEXT INSPECTION: Recommend to decrease inspection frequency. ATTACHMENTS: None.