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Home My WebLink AboutDAQ-2024-0074001 DAQC-PBR045780001-23 Site ID 4578 (B1) MEMORANDUM TO: FILE – UINTA WAX OPERATING, LLC – Meacham Tribal 16-24-13-3-1W-H1 THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager FROM: Chris Jensen, Environmental Scientist DATE: December 4, 2023 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: November 15, 2023 SOURCE LOCATION: Meacham Tribal 16-24-13-3-1W-H1 Lat: 40.20094011 Long: -109.93924226 Business Office: 5128 Apache Plume Road, Suite 300 Fort Worth, TX 76109 SOURCE TYPE: Tank Battery Uintah County API: 4304755729, 4304755750 SOURCE CONTACTS: Aimee Cole, Local Contact Phone: 720-384-7365, Email: acole@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: General Emission Standards; and UAC R307-150: Emission Inventories, 40 CFR 60 Subpart OOOOa and 40 CFR 60 Subpart JJJJ. 2 SOURCE EVALUATION: Site Type: PBR-Controlled Controlled by flare Site powered by engine The source registered: 547,500 Estimated Oil BBL. DOGM current 12 month rolling production is: 24,952 BBLs. 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. Engine - Natural Gas 4-Stroke Rich Burn Make - Doosan Model - D14.6L Mfg Year - 2012 Horse Power - 449 Combustion - Natural Gas, Pneumatics, Tanks 3 General Provisions 4 VOC emissions are minimized as reasonably practicable by equipment design, maintenance and operation practices. [R307-501-4(1)] Out of Compliance. There were fugitive emissions in the treater shed from piping of supply gas. 5 Air pollution control equipment is designed and installed appropriately, maintained and operated to control emissions. [R307-501-4(2)] In Compliance. An enclosed combustor is installed and operating properly. The DAQ looked for design and installation parameters such as: the vessel vent line is sloped away from the inlet of the combustor, a two-phase scrubber is used to separate natural gas liquids or condensates, the combustor has a lit pilot with an auto-ignition device, and the inlet to the combustor is controlled by a pressure regulating device. 6 Vessel vent lines are sloped away from the flare inlet or to a separation vessel (scrubber). [R307-501-2] In Compliance. The vent lines are sloped properly. 7 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. [R307-501-2] In Compliance. The expected components were found installed. 8 Pneumatic Controllers 9 Continuous bleed natural gas-driven pneumatic controllers are in compliance with 40 CFR 60.5390 or 60.5390a as applicable. Exemptions to tagging and record keeping requirements apply to controllers existing before December 1, 2015. [R307-502-4] In Compliance. This source does not use continuous bleed natural gas-driven pneumatic controllers. 10 Flares 11 Any flare has an operational auto-igniter. [R307-503-4] In Compliance. Auto-ignition is managed by the ECD control box. 3 12 Tank Truck Loading 13 Truck loading is done by bottom filling or submerged fill pipe. [R307-504(1)] In Compliance. The truck loading area is suitable for submerged loading and it is routine for truck drivers to load this way. 14 A vapor capture line is used during truck loading if subject to storage vessel emissions controls of R307-506-4(2). Effective July 1, 2019, for sources existing before January 1, 2018, and upon construction for new sources. [R307-504-4(2)] In Compliance. This source has the required vapor capture line installed. 15 Oil and Gas Industry Registration Requirement 16 The source is registered with the DAQ. [R307-505-3(3)] In Compliance. 17 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. 18 Storage Vessels 19 Thief hatches are kept closed and latched. [R307-506-4(1)] In Compliance. All hatches were found closed at the start of the evaluation. 20 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. Tank emissions are routed to an enclosed combustor. 21 Emissions from emergency storage vessels 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 tanks are uncontrolled or used as an emergency tank. 23 Upon modification, the well site was re-evaluated against the thresholds of R307-506-4(2). [R307-506-4(6)] In Compliance. The DAQ did not identify any modifications or unauthorized equipment. 24 Records for each of the following are kept for three years: Storage vessel vent system inspections (openings, thief hatches, pressure relief devices, bypasses, etc.), if required 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 per R307-506-4(2)[R307-506-5] In Compliance. The recordkeeping procedures of the operator, concerning these requirements, are found to be orderly and complete. 4 25 VOC Control Devices 26 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 an operational auto-igniter according to R307-503. [R307-508-3(1)] In Compliance. The ECD is a brand of combustor that has been certified by the US EPA. Auto-ignition is managed by the ECD control box. 27 Monthly AVO inspections are conducted on VOC control devices and associated equipment, and corrective actions are taken within 15 days. [R307-508-3(3)] Out of Compliance. The operator supplied inspection forms for review. These inspections were conducted daily in excess of that required by 40 CFR (60) OOOO and this requirement. The DAQ could not see that the monthly method 22 inspection of the emissions control device is being performed. 28 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 inspections of the VOC control device(s), associated equipment and any repairs, for 3 years. [R307-508-4] In Compliance. 29 Leak Detection and Repair 30 The source has an emissions monitoring plan. [R307-509-4(1)(a)] In Compliance. A field wide plan was produced to the DAQ for review during the records portion of the evaluation. The DAQ is not pursuing compliance action if this has not been prepared for each individual source. 31 The monitoring plan addresses difficult-to-monitor and unsafe-to-monitor components. [R307-509-4(1)(b)] In Compliance. Consistent with the Emissions Monitoring Plan requirement for compliance with NSPS (60) OOOO. 32 If emissions control is required, monitoring surveys are conducted to observe each fugitive emissions component for fugitive emissions. [R307-509-4(1)(c)] In Compliance. The records supplied by the operator met the standards required here. 33 Initial monitoring surveys were within 60 days after startup for new sources. Subsequent surveys are semi-annual 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)] Out of Compliance. The operator supplied a summary of the LDAR inspection forms for review. The summary reported these inspections were conducted twice a year, no sooner than 4 months apart but, often very near or exceeding 7 months apart as allowed by 40 CFR (60) OOOO and this requirement. Notice the summary reports the most recent surveys were conducted on: May 20, 2022, and then December 15, 2022, and finally September 15, 2023. 34 Monitoring surveys are done with OGI equipment or by Method 21. [R307-509-4(1)(e)] In Compliance. The operator uses a Flir GF 320 OGI camera. 5 35 Fugitive leaks are 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. The supplied inspection forms summary indicated that fugitive emissions found during the latest surveys were repaired within the 15 days. Note 2020 and 2021 surveys show that repairs took 36 days and 23 days to complete. 36 Resurvey of the repaired components is completed within 30 days. [R307-509-4(1)(g)] In Compliance. 37 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] Not Observed. The DAQ was not allowed access to the original forms but only a summary of findings on an MS Excel workbook. The summary exceeded the three years requirement. The DAQ assumes these records are being kept. 38 Natural Gas Engines 39 Engines subject to R307-510 (does not have an AO, began operations, installed or modified after January 1, 2016) meet the following limits: Maximum Engine hp Emission Standards in (g/hp-hr) NOx CO VOC HC+NOx >25 hp and < 100 hp - 4.85 - 2.83 >100 hp 1.0 2.0 0.7 - [R307-510-4(1)] Out of Compliance. Stack tests were only supplied for the two Ajax E 565 pump jack engines. They did not meet this standard. The DAQ doubts the engines were manufactured after 2008, although a manufacture date was not presented by UWO. Wells were drilled after the January 2016, date and so the engines are assumed likely to have been relocated to this source (in 2018) and subject to this rule UAC R307-510. UWO has not provided the DAQ with performance testing of the electrical generating units. 40 Affected engines are certified or have an initial performance test per 40 CFR 60.4244. [R307-510-4(2)] In Compliance. Stack testing was completed and emissions were within the limits established by NSPS (60) JJJJ. 41 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. The exhaust stack vents vertically. 42 Engine certifications or initial performance tests required are kept for the life of the engine at the source. [R307-510-5] Out of Compliance. Performance testing results are not kept for the electric generator engines found at this source. 6 43 Associated Gas Flaring 44 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 is gathered to a sales line. 45 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)] Out of Compliance. UWO was unable to provide any records in support of compliance with this rule and was unwilling to provide a statement of compliance. It appeared by interview that events where venting does occur are not being tracked or reported. The DAQ asked for a letter stating that there were no events where associated gas are vented to the atmosphere. This request was refused. 46 Visible Emissions 47 Visible emissions, except for unavoidable irregularities that do not exceed three minutes, are within the following opacity limits: Installations constructed on or before 4/25/1971 40% Installations constructed after 4/25/1971 20% Gasoline engines 0% Diesel engines manufactured after 1/1/1973 20% Diesel engines manufactured before 1/1/1973 40% Note: Required VOC control devices shall have no visible emissions per R307-508-3. [R307-201-3] In Compliance. No visible emissions were detected. 55 Emission Inventory: 56 An emissions inventory has been submitted within the past three years. [R307-150-9(1)] In Compliance. The operator submitted for the 2020 emissions inventory. Applicable Federal Regulations: 57 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] Out of Compliance. This source has an Approval Order from the State of Utah with legal and enforceable limits. This source is exempt from OOOOa for the collection of fugitive emissions components. A monitoring, repair, and record keeping program is in place that would satisfy the requirements of 40 CFR (60) OOOOa for the collection of fugitive emissions components, closed vent system, and storage vessel facilities. However, UWO has refused to provide evidence that an engineering design assessment has been completed, as required by this subpart, for any closed vent systems installed at this source. The latest LDAR surveys were not conducted semi-annually, no later than 7 months apart. The DAQ was not allowed access to the forms but given instead, a summary of facts taken from the survey forms. Monthly AVO inspections for the closed vent system did not include an EPA method 22 evaluation of the control device. There are not other affected facilities installed. 7 59 NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines. [40 CFR 60 Subpart JJJJ] Out of Compliance. Performance testing of the electric generator engines was not presented to the DAQ when asked. The pump jack engines (AJAX E-565) were successfully tested to NSPS (60) JJJJ standards. Maintenance records were not presented for any of the engines in operation on this source. PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to: Meacham Tribal 16-24-13-3-1W-H1: Out of Compliance - The DAQ surveyed the location with an OGI camera and found fugitive emissions in the treater shed from control gas supply piping. The DAQ found several issues with the recordkeeping requirements for both NSPS (60) OOOOa and NSPS (60) JJJJ. Engine performance stack testing and engine maintenance recordkeeping has not been presented to the DAQ. Monthly AVO requirements for the closed vent system (which includes a method 22 evaluation of the enclosed combustor) was not found in the supplied documentation. UWO has also refused to show evidence that an engineering design assessment was completed for the closed vent system. The latest LDAR surveys were not conducted semiannually not to exceed 7 months apart. The DAQ was not given access to the LDAR survey forms but, was given instead, a prepared summary of facts compiled from the surveys. See evaluations above. UWO was unable to provide any records in support of compliance with the venting rule (R307-511) and was unwilling to provide a statement of compliance. Pump jack and generator engines have likely been relocated to this source after January 1, 2016, and have not been shown to comply with the performance standards nor, the recordkeeping requirements of the performance testing for the generator engines expected in R307-510. The latest LDAR surveys were not conducted semiannually not to exceed 7 months apart (R307-509-4). The DAQ was not given access to the LDAR survey forms but, was given instead, a prepared summary of facts compiled from the surveys. See evaluations above. In consideration of the joint consent decree with the US EPA, still in negotiation with UWO, no further enforcement action is taken. The infractions documented here will be submitted to the USEPA for potential inclusion to the Joint Consent Decree being negotiated at this time. 8 RECOMMENDATION FOR NEXT INSPECTION: The DAQ recommends that the next inspector look closely at the recordkeeping of UWO as this was found to be inadequate. ATTACHMENTS: None. Records received are being sent to SLC for inclusion in a file. Most records are multiple sheet MS Excel files.