DAQ-2024-004564

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DAQC-CI143520001-23
Site ID 14352 (B1)

MEMORANDUM

TO: FILE – SCOUT ENERGY MANAGEMENT LLC – GOSP 4

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

FROM: Kyle Greenberg, Environmental Scientist

DATE: October 27, 2023

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Duchesne County

INSPECTION DATE: September 6, 2023

SOURCE LOCATION: 40.09936844 -110.05955782
Duchesne County, Utah
DIRECTIONS: Approximately 7 miles south of Myton, UT off of Sand Wash
Road.

SOURCE CONTACTS: Kevan Stevens;
[e-mail]
cell: 435-210-8355

OPERATING STATUS: Operating

PROCESS DESCRIPTION: Produced fluids gathered from various wells are delivered by
pipeline to the inlet of the Greater Monument Butte Gas Oil
Separation Plant #4 (GOSP 4). The fluids enter one of three free
water knockout (FWKO) vessels where three phase separation
occurs. The oil phase is directed to one of two heater treater units
where additional phase separation occurs. It is then delivered to
one of five 5,000 bbl storage tanks while the water phase from
the FWKOs and heater treaters will be delivered to one 5,000 bbl
water storage tank. Vapors generated by the operation of the oil
and water tanks will be collected by a vapor balance system. The
tank vapors are mixed with the gas collected from the FWKOs
and heater treaters and used for fuel.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN143520004-20, dated April 27,
2020; 40 CFR Part 60 Subpart JJJJ

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SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Scout Energy Management LLC - GOSP 4
13800 Montfort Drive, Suite 100 40.09936844 -110.05955782
Dallas, TX 75240 Duchesne, UT 84000

SIC Code: 1311: (Crude Petroleum & Natural Gas)

Section I: GENERAL PROVISIONS

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the
UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to
those rules. [R307-101]

I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]

I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions
covered by this AO must be reviewed and approved. [R307-401-1]

I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the two-year period prior to the date of the request. Unless
otherwise specified in this AO or in other applicable state and federal rules, records shall be kept
for a minimum of two (2) years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall,
to the extent practicable, maintain and operate any equipment approved under this AO, including
associated air pollution control equipment, in a manner consistent with good air pollution control
practice for minimizing emissions. Determination of whether acceptable operating and
maintenance procedures are being used will be based on information available to the Director
which may include, but is not limited to, monitoring results, opacity observations, review of
operating and maintenance procedures, and inspection of the source. All maintenance performed
on equipment authorized by this AO shall be recorded. [R307-401-4]

I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]

Status: In Compliance. Records reviewed on-site show maintenance is conducted and is
consistent with good air pollution control practice. AVO’s and Method 22 are conducted
monthly (reviewed on-site). The emergency generator is maintained and the emergency
generator’s hour log was reviewed, see attached records. Scout Energy reported there have
been no known breakdowns that have resulted in excess emissions. An Emissions Inventory
was submitted in 2020.

Section II: SPECIAL PROVISIONS

II.A The approved installations shall consist of the following equipment:

II.A.1 Greater Monument Butte Gas/Oil Separation Plant #4

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II.A.2 Free-Water Knockout Vessels
- listed for informational purposes only -

II.A.3 Three (3) Heater-Treater Units
- listed for informational purposes only -

II.A.4 Two (2) Vapor Combustion Units

II.A.5 Five (5) Oil Storage Tanks
Capacity: 210,000 gallons each

II.A.6 One (1) Produced-Water Storage Tank
Capacity: 210,000 gallons

II.A.7 Various Lease Automatic Custody Transfer Units
- listed for informational purposes only -

II.A.8 Vapor Balance System

II.A.9 One (1) Truck-Loading Vapor Combustion Unit

II.A.10 Two (2) Heat-Medium Heaters
Rating: 12.95 MMBtu/hr each
Fuel: Natural Gas

II.A.11 One (1) Emergency Generator Engine
Rating:456kW
Fuel: Natural Gas
Control Device: Non-Selective Catalytic Reduction
Manufactured on or after January 1, 2011

II.A.12 One (1) Emergency Flare

II.A.13 Various Electric Pumps and Compressors
- listed for informational purposes only -

II.A.14 Various Pneumatic Devices
operated by compressed air
- listed for informational purposes only –

Status: There are three free-water knockout vessels and two heater treater units. The two
Heat-Medium Heaters have 200 barrel glycol tanks that is used for heat tracing lines. The
emergency generator is a Doosan 21.9 natural-gas fired engine (SN:EEYOF300515)

II.B Requirements and Limitations

II.B.1 The Greater Monument Butte Gas/Oil Separation Plant #4 shall be subject to the
following:

II.B.1.a The owner/operator shall not produce more than 3,285,000 barrels (1 barrel = 42 gallons) of
separated oil per rolling 12-month period. [R307-401-8]

II.B.1.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new
12-month total by the twentieth day of each month using data from the previous 12 months.
Records of production shall be kept for all periods when the plant is in operation. Production
shall be determined by process flow meters or sales records. The records of production shall be
kept on a daily basis. [R307-401-8]

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II.B.1.b The owner/operator shall not allow visible emissions from any stationary point or fugitive
emission source on site to exceed 10 percent opacity. [R307-401-8]

II.B.1.b.1 Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9. [R307-201-3]

Status: In Compliance. Records reviewed show the site has not exceeded the oil production
limit, the last rolling 12-month oil production was 266,300 barrels. No visible emissions
were visible during the time of inspection.
II.B.2 Emergency Engine Requirements
II.B.2.a The owner/operator shall not operate each emergency engine on site for more than 100
hours per rolling 12-month period during non-emergency situations . There is no time
limit on the use of the engines during emergencies. [R307-401-8, 40 CFR 63 Subpart
ZZZZ]

II.B.2.a.1

To determine compliance with a rolling 12-month total, the owner/operator shall calculate a
new 12-month total by the 20th day of each month using data from the previous 12 months.
Records documenting the operation of each emergency engine shall be kept in a log and
shall include the following:

A. The date the emergency engine was used
B. The duration of operation in hours
C. The reason for the emergency engine usage [R307-401-8,
40 CFR 63 Subpart ZZZZ]

II.B.2.a.2 To determine the duration of operation, the owner/operator shall install a non -
resettable hour meter for each emergency engine. [R307-401-8,
40 CFR 63 Subpart ZZZZ]

II.B.2.b

The owner/operator shall install an emergency engine that is certified to meet a NOx
emission rate of 1.00 g/hp-hr or less. [R307-401-8]

II.B.2.b.1

To demonstrate compliance with the emission rate, the owner/operator shall keep a record
of the manufacturer's certification of the emission rate. The record shall be kept for the life
of the equipment. [R307-401-8]

Status: In Compliance. The emergency generator has not operated more than 100 hours
per a rolling 12-month period. The Doosan 21.9 natural-gas fired engine is an EPA
certified engine. See attached records of the hour log and engine maintenance. II.B.3 Flares and Vapor Combustion-Units Requirements

II.B.3.a

The owner/operator shall collect and send all gas/vapors from the free-water knockout
vessels, the three (3) heater-treater units, and the liquid storage tanks to a pipeline for
sales during normal operation and shall not be vented to the atmosphere. If
upset/breakdown conditions prevent the use of the sales pipeline, the gas/vapors from the
above units shall be routed to and controlled by a vapor combustion unit. [R307-401-8]

II.B.3.b

The owner/operator shall capture all gas/vapors from truck -loading operations with a
vapor balance system. The truck-loading vapor combustion unit shall control emissions
from the vapor balance system. [R307-401-8]
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II.B.3.c The owner/operator shall control emissions from the facility during emergency and upset
conditions with the Emergency Flare, including emergency blow-downs. [R307-401-8]

Status: In Compliance. All vapors are collected for combustion as required. Truck
loading operations is controlled with a vapor capture line. Both combustors were lit and
operating during the time of inspection. The emergency flare’s pilot light was lit during
the time of inspection. II.B.4 Heat-Medium Heaters Requirements

II.B.4.a

The owner/operator shall ensure the stack height for each heater is at least 24 feet tall, as
measured from the base of the stack. [R307-401-8]

Status: In Compliance.

Section III: APPLICABLE FEDERAL REQUIREMENTS

In addition to the requirements of this AO, all applicable provisions of the following federal programs
have been found to apply to this installation. This AO in no way releases the owner or operator from any
liability for compliance with all other applicable federal, state, and local regulations including UAC
R307.

NSPS (Part 60), JJJJ: Standards of Performance for Stationary Spark Ignition Internal
Combustion Engines

Status: In Compliance. The emergency generator is an EPA certified engine and it is maintained to
manufacture specifications. A stack test was also conducted on September 27, 2019; the results
were in compliance with JJJJ emission limits.

AREA SOURCE RULES EVALUATION:

EMISSION INVENTORY:

Listed before are the Actual Emissions Inventory provided from Scout Energy Management LLC - GOSP
4. A comparison of the estimated total potential emissions (PTE) on AO: DAQE-AN143520004-20, dated
April 27, 2020, is provided.
(PTE) are supplied for supplemental purposes only.

Criteria Pollutant PTE tons/yr Actuals tons/yr
CO2 Equivalent 13800.00 -
Carbon Monoxide 21.61 1.42
Nitrogen Oxides 18.48 1.70
Particulate Matter - PM10 1.06 0.13
Particulate Matter - PM2.5 1.06 0.13
Sulfur Dioxide 0.35 0
Volatile Organic Compounds 45.60 24.86

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Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr
Acetaldehyde (CAS #75070) 400 -
Acrolein (CAS #107028) 240 -
Benzene (Including Benzene From Gasoline) (CAS #71432) 40 -
Ethyl Benzene (CAS #100414) 40 -
Formaldehyde (CAS #50000) 2500 -
Generic HAPs (CAS #GHAPS) 20 -
Hexane (CAS #110543) 1440 -
Methanol (CAS #67561) 120 -
Toluene (CAS #108883) 80 -
Xylenes (Isomers And Mixture) (CAS #1330207) 120 -

PREVIOUS ENFORCEMENT
ACTIONS: Compliance Advisory DAQC-0607-19 issued May 21, 2019

Early Settlement Agreement DAQC-192-20 issued February 13,
2020

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN143520004-20
dated April 27, 2020: In Compliance.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: It is recommended to keep the inspection frequency as normal.

NSR RECOMMENDATIONS: None.

ATTACHMENTS: Rolling 12-month Production, Emergency Generator Hour Log,
Emergency Generator Maintenance Records
GOSP LACT : 156890
Monthly
Month LACT Ticket Volume
Aug, 2023 24,471.79
Jul, 2023 22,159.70
Jun, 2023 22,339.14
May, 2023 21,891.33
Apr, 2023 23,764.00
Mar, 2023 20,747.78
Feb, 2023 17,680.02
Jan, 2023 23,329.83
Dec, 2022 22,001.70
Nov, 2022 23,252.05
Oct, 2022 23,826.67
Sep, 2022 20,835.94
10/27/23, 4:15 PM IMG_0264.jpg
https://mail.google.com/mail/u/0/?pli=1#inbox?projector=1 1/1
Emergency Generator Maintenance Checklist
GOSP #4 Facility SC@UT
E NERGY PARTNERS
Yes No
Change Engine Oil X
Check Fuel Filter and change if needed X
Check Air Filter and clean/change if needed X
Inspect Starter and charge alternator X
Check radiator X
Check coolant level and add coolant if necessary X
Check hoses and belts for wear X
Check fan hub, grease if needed X
Check battery/cables/connections for corrosion X
Check cooling fan belt tensioner -adjust as necessary X
Comments/ Additional Information
Date 8/30/2023
Technician Pau l Merkley
l_
Spark Ignited 2 Stroke Lean Burn Inspection Checklist
lns11ection Date 9/16/2022
lns11ection Well Location GSOP 4 Generator
Engine Model T'.i11e
Engine Identification Number
Engine Kills
Test temperature kill by crossing button to gauge frame, adjust kill to 210 F.
Trip over speed kill if applicable .
Trip vibration kill , adjust if needed .
Drain oil out of lube box, ensure that the kills work.
Trip vibration kill on sampson post, adjust as needed .
Test production line pressure kill.
Drain crank oil and ensure that crank case oil level kill works .
Engine Service
Turn gas off at the scrubber, drain any liquids from scrubber.
Remove both scavenger plugs and drain oil, remove debris from scavenger ports.
Open fan access door and grease fan hub, check belt condition and tension .
Clean radiator fins with brush and compressed air.
Remove oil cup from air cleaner, dra i n oil , clean all three parts with solvent and compressed air.
Check condition of powerband belt, tighten if necessary.
Check condition of trace pump belt.
Check condition of spark plug .
Grease and inspect system and components.
Check love joy union for proper alignment or wear.
Check kill wires and repair if necessary .
Change oil, replace to proper level.
Grease pumping unit.
Grease trace pump.
Grease saddle bearing .
Grease tail bearing.
Grease rod rotator.
Pum11 i ng Unit Service
Ensure all grease lines are hooked up and in proper working co ndition.
Check oil leve l in gea r reducer, add o r replace if needed .
1 lns11ec t ors Na m e Pau l Merkley
The o il was changed and m ain te nan ce pe rfo r med o n t he back up gen erator.
Complete
Complete
X
Complete