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HomeMy WebLinkAboutDAQ-2024-0045961 DAQC-PBR100678001-23 Site ID 100678 (B1) MEMORANDUM TO: FILE – UINTA WAX OPERATING, LLC – Bastian Tribal 21-16-3-1W CTB THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager FROM: Chris Jensen, Environmental Scientist DATE: November 29, 2023 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: November 15, 2023 SOURCE LOCATION: Bastian Tribal 21-16-3-1W CTB Lat: 40.201088 Long: -109.98854 Business Office: 5128 Apache Plume Road Suite 300 Fort Worth, TX 76109 SOURCE TYPE: Multi-well Tank Battery Duchesne County API: 4301354037, 4301354038, 4301354039, 4301354040, 4301354041 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, and 40 CFR 60 Subpart JJJJ. 2 SOURCE EVALUATION: Site Type: PBR-Controlled Voluntarily Controlled by flare Site powered by engine The source registered: 912,500 Estimated Oil BBL. DOGM current 12 month rolling production is: 6,907 BBLs. Utah Statute R307-506 requires a source with throughput greater than 8,000 BBLs to have controls. REGISTERED EQUIPMENT: Engine - Engine - Natural Gas 4-Stroke Rich Burn Make - Caterpillar Model - G3412 Mfg Year - 2011 Horse Power - 603 Combustion - Field Gas, Engine - Engine - Natural Gas 4-Stroke Rich Burn Make - Caterpillar Model - G3412 Mfg Year - 2011 Horse Power - 603 Combustion - Field Gas, Pneumatic, Tank 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. 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. 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. See attached. 3 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)] In Compliance. There are two rental generators installed here. They have Doosan certified engines. 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. 42 Engine certifications or initial performance tests required are kept for the life of the engine at the source. [R307-510-5] In Compliance. 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. Not Observed. None of the tank batteries have the PTE to be an affected facility under this subpart. This source has a state permit with legal and enforceable limits and is exempt as a collection of fugitive emission components affected facility. There are no other affected facilities installed here. 4 59 NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines. In Compliance. The engines in use here are all EPA certified. PREVIOUS ENFORCEMENT ACTIONS: A search in the DAQ EZ-Search application did not return any enforcement action documents within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: In Compliance - This source was found to be clean and well-kept with no visible or fugitive emissions. The source was inspected by AVO and with an OGI camera and found to be free of leaks. RECOMMENDATION FOR NEXT INSPECTION: The DAQ has no recommendations for the next inspector other than what are customary. The next inspector may note that the recordkeeping of UWO was rather disorganized and submissions have been incomplete and late. They may want to be very clear about what records are needed and how and when they are to be delivered. The DAQ recommends the inspection frequency of this source remain the same. ATTACHMENTS: Email exchange, 12-month production Well API 10/2023 Bastian Tribal 21-16-3-1W CTB 6907 Bastian Tribal 21-16-3-1W 43-013-54037 Bastian Tribal 22-13-3-1W 43-013-54038 Bastian Tribal 22-14-3-1W 43-013-54039 Bastian Tribal 27-03-3-1W 43-013-54040 Bastian Tribal 27-04-3-1W 43-013-54041 CPG Tribal Battery 49990 CPG Tribal 2-26-35-3-1W-H1 43-047-55650 CPG Tribal 26-2-3-1W 43-047-55760 CPG Tribal 26-3-3-1W 43-047-55762 CPG Tribal 26-6-3-1W 43-047-55763 CPG Tribal 26-7-3-1W 43-047-55758 CPG Tribal 26-8-3-1W 43-047-55757 RP Tribal 22N-31W & 27S-31W 856890 RP Tribal 22N-31W-H6UB 43-013-53479 RP Tribal 22N-31W-H4UB 43-013-53480 RP Tribal 27S-31W-H1UB 43-013-54269 RP Tribal 27S-31W-H2CP 43-047-57043 RP Tribal 27S-31W-H3UB 43-013-54271 RP Tribal 27S-31W-H4CP 43-013-54284 Meacham Tribal 16-24-13-3-1W-H1 CTB 24952 Meacham Tribal 16-24-13-3-1W-H1 43-047-55729 Meacham Tribal 1-25-36-3-1W-H1 43-047-55750 RP27S Battery H6UB & H8UB 294000 RP 27S-31W-H6UB 43-013-53478 Skoufos Tribal 14-22-15-3-1W-H3 43-013-53482 Skoufos Tribal 4-27-34-3-1W-H1 43-013-53483 RP 27S-31W-H8UB 43-013-53484 Skoufos Tribal 13-22-15-3-1W-H1 43-013-53486 RP Tribal 22N-31W-H7UB 43-013-53488 RP Tribal 23N-31W-H2UB, 24N-31W-H6UB, H8UB 333234 RP Tribal 24N-31W-H8UB 43-047-56291 RP Tribal 23N-31W-H2UB 43-047-56293 RP Tribal 24N-31W-H6UB 43-047-56294 Kendall Tribal 4-30-31-3-1E-H3 43-047-53988 14197 Badger 1-26-35-3-1W-H2 & 4-25-36-3-1W-H1 41623 Badger 01-26-35-03-01W-H3 43-047-55747 Badger 01-26-35-03-01W-H2 43-047-55748 Badger 01-26-35-03-01W-H4 43-047-55749 12 Month Rolling Production