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HomeMy WebLinkAboutDAQ-2024-0074091 DAQC-PBR151170001-23 Site ID 15117 (B1) MEMORANDUM TO: FILE – SCOUT ENERGY MANAGEMENT, LLC – State 5-16-9-16 THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Manager FROM: Stephen Foulger, Environmental Scientist DATE: July 31, 2023 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: June 29, 2023 SOURCE LOCATION: State 5-16-9-16 Lat: 40.034365 Long: -110.130191 Business Office: 13800 Montfort Drive, Suite 100 Dallas, TX 75240 SOURCE TYPE: Tank Battery Duchesne County API: 4301333849, 4301351448, 4301351587 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 OOOO. 2 SOURCE EVALUATION: Site Type: PBR- Uncontrolled Controlled by flare Site powered by Engine The source registered: 7,999 Estimated Oil BBL. DOGM current 12 month rolling production is: 17 bbls. Utah Statute R307-506 requires a source with throughput greater than 8,000 BBLs to have controls. REGISTERED EQUIPMENT: Engine - Engine - Natural Gas 2-Stroke Lean Burn Make - Arrow Model - L-795 Mfg Year - 2013 Horse Power - 65 Combustion - Natural Gas, Pneumatic, Tank 8 Pneumatic Controllers 15 Oil and Gas Industry Registration Requirement 16 The source is registered with the DAQ. [R307-505-3(3)] In Compliance. Search of DAQ records shows source is properly registered. 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. Search of DAQ records shows source is properly registered. 18 Storage Vessels 19 Thief hatches are kept closed and latched. [R307-506-4(1)] In Compliance. Thief hatches found closed and latched at the time of inspection. 23 Upon modification, the well site was re-evaluated against the thresholds of R307-506-4(2). [R307-506-4(6)] In Compliance. No modifications to this source were found at the time of inspection. 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. Scout is in the first year of ownership of this facility and has no records currently. 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. 40 Affected engines are certified or have an initial performance test per 40 CFR 60.4244. [R307-510-4(2)] In Compliance. DAQ inspector has reviewed these documents and found them compliant. 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. Operator has been instructed on need to fix all non-vertical stacks. Operator is drafting plans and submitting plans to DAQ. 42 Engine certifications or initial performance tests required are kept for the life of the engine at the source. [R307-510-5] In Compliance. See attached forms. 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 observed at the time of inspection. 48 Dehydrators. 52 VOC control devices required by R307-507-4(1) have only been removed after a minimum of one year, and only if the rolling 12-month actual uncontrolled emissions are <4 tons VOC per year, individually or combined with emissions from storage vessels. [R307-507-4(4)] In Compliance. Control removed after production dropped below 4 tons of VOCs in the last 12 months. 54 Records of required vent system inspections at sources with dehydrators are kept for three years. [R307-507-5(2)] In Compliance. 4 55 Emission Inventory: 56 An emissions inventory has been submitted within the past three years. [R307-150-9(1)] In Compliance. Search of DAQ records shows emissions inventory properly reported. 60 NSPS (Part 60) OOOO: Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution [40 CFR 60 Subpart OOOO] In Compliance. PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to: State 5-16-9-16: In Compliance - This source was found to be compliant at the time of inspection. Recommend to decrease frequency of inspections due to good compliance status and production being below 8,000 barrels. RECOMMENDATION FOR NEXT INSPECTION: Decreased/less frequent inspections. Source found in compliance at the time of inspection and has dropped below 8,000 bbls of production. ATTACHMENTS: