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Home My WebLink AboutDAQ-2024-0083871 DAQC-PBR101832001-24 Site ID 101832 (B1) MEMORANDUM TO: FILE – SCOUT ENERGY MANAGEMENT, LLC - Big Red THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager FROM: Chris Jensen, Environmental Scientist DATE: March 22, 2024 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: March 20, 2024 SOURCE LOCATION: Big Red Lat:40.08052 Long: -110.10816 Business Office: Scout Energy Management, LLC 13800 Montfort Drive, Suite 100 Dallas, TX 75240 SOURCE TYPE: Tank Battery Duchesne County API: 4301354420, 4301354421, 4301354456 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, 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 DOGM current 12 month rolling production is: 283,171 BBLs. Utah Statute R307-506 requires a source with throughput greater than 8,000 BBLs to have controls. REGISTERED EQUIPMENT: Tank battery, 3 electrical generators. Steffes air assisted flare SAA8 General Provisions VOC emissions are minimized as reasonably practicable by equipment design, maintenance and operation practices. [R307-501-4(1)] In Compliance. Associated gas is routed to a sales gathering line. Vessel vent lines route emissions to a combustion device. Tanks all have thief hatches and PRV's that are closed and not leaking. Air pollution control equipment is designed and installed appropriately, maintained and operated to control emissions. [R307-501-4(2)] In Compliance. A combustion device 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. Scout provided an engineering design document. 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. 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. This installation has a BMS, pressure gauge, and fire suppressor installed. An inlet pressure regulating valve is not required on a Steffes SAA8 air assisted flare. 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] In Compliance. This source does not use continuous bleed natural gas-driven pneumatic controllers. 3 Flares Any flare has an operational auto-igniter. [R307-503-4] In Compliance. This function is performed by the BMS. Tank Truck Loading 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. A vapor capture line is used during truck loading if subject to storage vessel emissions controls of R307-506-4(2). Effective 7/1/2019 for sources existing before 1/1/2018, and upon construction for new sources. [R307-504-4(2)] In Compliance. This source has the required vapor capture line installed. Oil and Gas Industry Registration Requirement The source is registered with the DAQ. [R307-505-3(3)] In Compliance. Storage Vessels Thief hatches are kept closed and latched. [R307-506-4(1)] In Compliance. All hatches were found closed at the start of the evaluation. 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. 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. 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. 4 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. VOC Control Devices 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 Steffes SAA8 has been certified by the US EPA. Monthly AVO inspections are conducted on VOC control devices and associated equipment, and corrective actions are taken within 15 days. [R307-508-3(3)] In Compliance. The Operator supplied inspection forms for review. These inspections were conducted monthly as required by 40 CFR (60) OOOO and this requirement. The Operator indicated on the monthly inspection records that they use the EPA method 22 to detect visible emissions. 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. Leak Detection and Repair 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. 5 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. 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. Consistent with the Emissions Monitoring Plan requirement for compliance with NSPS (60) OOOO. 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)] In Compliance. The Operator supplied LDAR inspection forms for review. These inspections were conducted twice a year, no sooner than 4 months apart and no later than seven months apart, as required by 40 CFR (60) OOOO and this requirement. 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. 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 showed that the leaking components identified during the latest survey were repaired the same day except one repair took 10 days. Resurvey of the repaired components is completed within 30 days. [R307-509-4(1)(g)] In Compliance. Within 10 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. New well. All records are being kept in an orderly fashion. 6 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. The engines are certified compliant with the standards of 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 engine certification was presented to the DAQ during the records review. 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 engine exhaust stack vents vertically. Engine certifications or initial performance tests required are kept for the life of the engine at the source. [R307-510-5] In Compliance. 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 is gathered to a cooling tower and then to a sales line. 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 reported venting events or breakdowns. Scout prepared a statement of such. 7 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] In Compliance. No visible emissions were detected. Emission Inventory: An emissions inventory has been submitted within the past three years. [R307-150-9(1)] In Compliance. New well. This well has not yet been subject to a reporting period. Applicable Federal Requirements: 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. In Compliance. This source has a permit (PBR) 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. See above evaluations. There are no other affected facilities installed. This source will be subject to NSPS (60) OOOO(b) when it becomes effective this summer. Until then, this source was evaluated according to subpart OOOO(a) and Utah Administrative Code R307-501 through 511. NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines. In Compliance. The engines at this source are EPA certified. The recordkeeping and maintenance provisions are also met to maintain the certification. NSPS (Part 60) ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines. In Compliance. These standards are met with compliance with NSPS (60) JJJJ. 8 PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: In Compliance - The source was surveyed by AVO, and with an OGI camera, was found to be well-kept with no visible or fugitive emissions. Requested records were provided in a timely manner and reviewed at the Local field office. This source is multi-well location. The production totals are for all 3 wells combined. There are no pumpjack engines installed. Products are brought to surface by an artificial lift system powered by electrical generators. All pneumatic controllers and valves are supplied with instrument air except for tank burner controls where the use of air is deemed a safety concern. 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. The DAQ was joined by Scout personnel during the site inspection.