DAQ-2025-000788

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DAQC-PBR101694001-25
Site ID 101694 (B1)

MEMORANDUM

TO: FILE – UINTA WAX OPERATING, LLC – RD Tribal 23N-31E-H1UB, 24N-31E-H7UB

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:40.19839, Long: -109.84022
Uintah County

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

SOURCE TYPE: Tank Battery
API: 4304757033, 4304757034

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.

/ + # ) * 0 ' " -
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SOURCE EVALUATION: Site Type: PBR – Controlled
Controlled by flare, Site powered by Engine. The source registered:
547500 Estimated Oil BBL.
DOGM current 12 month rolling production is: 71,081.
Utah Statute R307-506 requires a source with throughput
greater than 8,000 BBLs to have controls.

REGISTERED EQUIPMENT: Engine - Natural Gas 4-Stroke Rich Burn Make - Doosan Model -
D14.6L Mfg Year - 2012 Horse Power - 449 Combustion - Natural
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)]

In Compliance. VOCs found properly minimized 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 pneumatics 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 continuously burning pilot flame.

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.

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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 controlled or recycled at the time of inspection.

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)]

Not Applicable. No emergency storage vessels found on-site 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 and repairs found properly conducted 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 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 records reviewed and found in compliance at the time of
inspection.

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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. 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)]

Not Applicable. No associated gas flaring was reported 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 submitted in the emissions inventory.

Leak Detection and Repair:

The source has a source specific emissions monitoring plan. [R307-509-4(1)(a)]

In Compliance. Source monitoring plan reviewed at the time of inspection and found compliant.

The monitoring plan addresses difficult-to-monitor and unsafe-to-monitor components.
[R307-509-4(1)(b)]

In Compliance. Monitoring plan properly addresses these areas of concern.

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Monitoring surveys are conducted to observe each fugitive emissions component for fugitive emissions.
[R307-509-4(1)(c)]

In Compliance. Monitoring surveys found 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 conducted on an appropriate time frame.

Monitoring surveys are done with OGI equipment or by Method 21. [R307-509-4(1)(e)]

In Compliance. Monitoring surveys 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 repaired on an appropriate schedule.

Resurvey of the repaired components is completed within 30 days. [R307-509-4(1)(g)]

In Compliance. 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 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 up to date 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. Exhaust vents found vertical, unrestricted, and at the proper height at the time of
inspection.

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Engine certifications or initial performance tests required are kept for the life of the engine at the source.
[R307-510-5]

In Compliance. Engine certifications or performance tests were supplied and reviewed 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 certifications or performance tests were supplied and reviewed at the time
of inspection.

Federal Requirements

NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion
Engines [40 CFR 60 Subpart JJJJ]

In Compliance. Engines maintenance records found properly kept at the time of inspection.

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. [40 CFR 60 Subpart
OOOOb]

In Compliance. This source was found to be compliant with OOOOb requirements at the time of
inspection.

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.