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Home My WebLink AboutDAQ-2024-0082111 DAQC-PBR153860001-24 Site ID 15386 (B1) MEMORANDUM TO: FILE – SCOUT ENERGY MANAGEMENT, LLC – Walton 1-11-9-16 THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager FROM: Chris Jensen, Environmental Scientist DATE: May 14, 2024 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: May 1, 2024 SOURCE LOCATION: Walton 1-11-9-16 Lat:40.039942 Long: -110.079786 Business Office: 13800 Montfort Drive, Suite 100 Dallas, TX 75240 SOURCE TYPE: Tank Battery Duchesne County, UT API: 4301315792, 4301334080, 4301350580 SOURCE CONTACTS: Abby Molyneaux, Corporate Environmental Contact Phone: 972-325-1170, Email: abby.molyneaux@scoutep.com Chris Patterson, Local Contact Phone: 970-620-3459, Email: chris.patterson@scoutep.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, 40 CFR 60 Subpart OOOO. 2 SOURCE EVALUATION: Site Type: PBR- Uncontrolled Voluntarily Controlled by Flare Site powered by Engine The source registered: 20000 Estimated Oil BBL. DOGM current 12 month rolling production is: 6,577 BBLs. Utah Statute R307-506 requires a source with throughput greater than 8,000 BBLs to have controls. REGISTERED EQUIPMENT: Dehydrator, Dehydrator, Engine - Engine - Natural Gas 2-Stroke Lean Burn Make - Arrow Model - L-795 Mfg Year - 2009 Horse Power - 65 Combustion - Natural Gas, Engine - Engine - Natural Gas 2-Stroke Lean Burn Make - Arrow Model - L-795 Mfg Year - 2011 Horse Power - 65 Combustion - Natural Gas, Pneumatic, Tank VOC emissions are minimized as reasonably practicable by equipment design, maintenance and operation practices. [R307-501-4(1)] Not Observed. Air pollution control equipment is designed and installed appropriately, maintained and operated to control emissions. [R307-501-4(2)] Not Observed. Pneumatic Controllers 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 12/1/2015. [R307-502-4] Not Observed. Truck loading is done by bottom filling or submerged fill pipe [R307-504(1)] Not Observed. Oil and Gas Industry Registration Requirement The source is registered with the DAQ. [R307-505-3(3)] In Compliance. 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. 3 Storage Vessels Thief hatches are kept closed and latched. [R307-506-4(1)] Not Observed. Upon modification, the well site was re-evaluated against the thresholds of R307-506-4(2). [R307-506-4(6)] Not Observed. 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. These records were reviewed at the local office. Natural Gas Engines 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. This well was drilled before 2016 and the pumpjack engine is instead subject to the performance standards in NSPS (60) JJJJ. Affected engines are certified or have an initial performance test per 40 CFR 60.4244. [R307-510-4(2)] In Compliance. The stack testing report was presented to the DAQ during the records review. 4 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 Observed. Engine certifications or initial performance tests required are kept for the life of the engine at the source. [R307-510-5] In Compliance. Scout still has the test on file. Visible Emissions 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] Not Observed. Emission Inventory: 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: NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines. In Compliance. The engines at this source have been performance tested and the emissions were within the limits allowed in this subpart. The recordkeeping and maintenance provisions are also met to maintain the certification. NSPS (Part 60) OOOO: Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution. In Compliance. The tank battery at this source no longer has the production to have the PTE in excess of 4 TPY and are no longer an affected facility under this subpart. There are no other affected facilities installed. 5 PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: In Compliance – Due to Transportation issues, the DAQ only conducted a review of the rules requiring recordkeeping. The Operator's representatives were pleasant and cooperative. Requested records were provided in a timely manner and reviewed at the local field office. RECOMMENDATION FOR NEXT INSPECTION: The DAQ has no Recommendations for the next inspector other than what are customary. The DAQ recommends the inspection frequency of this source remain as planned. ATTACHMENTS: None.