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Home My WebLink AboutDAQ-2024-0073591 DAQC-PBR153820001-24 Site ID 15382 (B1) MEMORANDUM TO: FILE – SCOUT ENERGY MANAGEMENT, LLC – W Point 4-8-9-16 THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Manager FROM: Chris Jensen, Environmental Scientist DATE: March 27, 2024 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: March 20, 2024 SOURCE LOCATION: W Point 4-8-9-16 Lat: 40.04999 Long: -110.149979 Business Office: 13800 Montfort Drive, Suite 100 Dallas, TX 75240 SOURCE TYPE: Tank Battery Duchesne County API: 4301332208, 4301350703, 4301352672 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. SOURCE EVALUATION: Site Type: PBR-Uncontrolled No Flare Controls Site powered by Engine The source registered: 7,999 Estimated Oil BBL. 2 DOGM current 12 month rolling production is: 4,344 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 - Ajax Model - E-565 Mfg Year - 2014 Horse Power - 40 Combustion - Natural Gas, Engine - Engine - Natural Gas 2-Stroke Lean Burn Make - Arrow Model - L-795 Mfg Year - 2012 Horse Power - 65 Combustion - Natural Gas, Pneumatic, Tank 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. Oil and Gas Industry: Tank Truck Loading [R307-504] In Compliance. The truck loading area is suitable for submerged loading and it is routine for truck drivers to load this way. 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. 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. 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. 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. 3 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 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. 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. Engine certifications or initial performance tests required are kept for the life of the engine at the source. [R307-510-5] In Compliance. The stack tests are kept by Scout. 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. The operator submitted for the 2020 emissions inventory. Tank trucks loading. In Compliance. The truck loading area is suitable for submerged loading and it is routine for truck drivers to load this way. 4 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. This source is permitted with the State of Utah with legal and enforceable limits. This source no longer has the production with PTE to be a tank affected facility. There are no other affected facilities that are installed. 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 and 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. 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 be reduced. The DAQ was joined by Scout personnel during the site inspection. ATTACHMENTS: None