DAQ-2025-001601

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DAQC-PBR145390001-25
Site ID 14539 (B1) MEMORANDUM

TO: FILE – JAVELIN ENERGY LLC – Brotherson 2-26B4

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

FROM: Stephen Foulger, Environmental Scientist

DATE: March 17, 2025

SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION

INSPECTION DATE: January 31, 2025

SOURCE LOCATION: Lat: -110.310424804687 Long: 40.2741317749023

Business Office:
Javelin Energy Management Partners, LLC
5221 North O Connor Boulevard, Suite 1100
Adamsville, TX 75039

SOURCE TYPE: Tank Battery
Duchesne County
API: 4301333139, 4301354122, 4301354123

SOURCE CONTACTS: Zach Bertelli, 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 OOOOa.

SOURCE EVALUATION: Site Type: PBR-Controlled
Controlled by flare, Site powered by Engine. The source
registered: 509,600 Estimated Oil BBL.
DOGM current 12 month rolling production is: 47,938
Utah Statute R307-506 requires a source with throughput
greater than 8,000 BBLs to have controls.
/ + # ) * 0 ' " -
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REGISTERED EQUIPMENT: Engines, Pneumatics, Tanks

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 controlled at the time of inspection. VOC control devices required by R307-507-4(1) have only been removed after a minimum of one year, and only if the rolling 12-month actual uncontrolled emissions are <4 tons VOC per year, individually or combined with emissions from storage vessels. [R307-507-4(4)] In Compliance. VOC control device found not removed 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 were reviewed at the time of inspection and found to be compliant. 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 at the time of inspection and were found compliant. Associated Gas 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. 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 lines found available for use at the time of inspection.

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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. 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. Vent lines found properly sloped at the time of inspection. Combustor inlet lines are equipped with a fire arrestor, pressure gauge, inlet pressure regulating valve and other components according to the engineering design, the manufacturer's specifications or good practices for safety and emissions control. [R307-501-4(2)] In Compliance. Combustor inlet lines found properly engineered at the time of inspection. Air pollution control equipment is designed and sized to achieve the destructive efficiencies in rules and to handle fluctuations in emissions. [R307-501-4(2)] In Compliance. Control equipment found properly designed and sized at the time of inspection. The VOC control device(s) required by R307-506 or R307-507 has a control efficiency of 95% or greater, operates with no visible emissions and has a continuously burning pilot flame and an operational auto-igniter according to R307-503. [R307-508-3(1)] In Compliance. Control device found on-site operates with no visible emissions and at an efficiency of greater than 95 percent. 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 was reported at the time of inspection.
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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. VOC control devices required by R307-507-4(1) have only been removed after a minimum of one year, and only if the rolling 12-month actual uncontrolled emissions are <4 tons VOC per year, individually or combined with emissions from storage vessels. [R307-507-4(4)] In Compliance. VOC control device found not removed at the time of inspection. Leak Detection and Repair The monitoring plan addresses difficult-to-monitor and unsafe-to-monitor components. [R307-509-4(1)(b)] In Compliance. Monitoring plan properly addresses difficult and unsafe to monitor components. 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. Surveys found conducted on and appropriate time frame 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 are conducted using OGI equipment. 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. Leaks detected are repaired in an appropriate time frame. Resurvey of the repaired components is completed within 30 days. [R307-509-4(1)(g)] In Compliance. Components are resurveyed within the required 30 days. 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 inspections found properly kept at the time of inspection. 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. These records were reviewed and found to be compliant at the time of inspection. Engine certifications or initial performance tests required are kept for the life of the engine at the source. [R307-510-5] In Compliance. These records were reviewed and found to be compliant at the time of inspection.
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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. These records were reviewed and found to be compliant at the time of inspection. Temporary Emergency Generators, in use for less than 100 days, have an operational hour meter and log book (onsite) recording hours used and maintenance performed. [40 CFR 60 Subpart IIII, JJJJ] In Compliance. No emergency generators were found on-site at the time of inspection. 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. Engines on-site predate these requirements. Certified and non-certified engines are regularly maintained according to the Engine manufacturer's Schedule or the Maintenance Plan. [40 CFR 60 Subpart IIII, JJJJ, 63 Subpart ZZZZ] In Compliance. These records were reviewed and found to be compliant at the time of inspection. Applicable Federal Regulations NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines [40 CFR 60 Subpart JJJJ] In Compliance. Engine records were reviewed at the time of inspection and were found to be compliant. NSPS (Part 60) OOOOa: Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification or Reconstruction Commenced After September 18, 2015 [40 CFR 60 Subpart OOOOa] 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