DAQ-2024-004591

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DAQC-PBR153900001-23
Site ID 15390 (B1)
MEMORANDUM

TO: FILE – SCOUT ENERGY MANAGEMENT, LLC – Wells Drw 5-5-9-16

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

FROM: Chris Jensen, Environmental Scientist

DATE: December 11, 2023

SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION

INSPECTION DATE: November 6, 2023

SOURCE LOCATION: Wells Drw 5-5-9-16
Lat: 40.061432 Long: -110.15018

Business Office:
13800 Montfort Drive, Suite 100
Dallas, TX 75240

SOURCE TYPE: Tank Battery
Duchesne County
API: 4301331759, 4301352416, 4301352417

SOURCE CONTACTS: Abby Molyneaux, Corporate Environmental Contact
Phone: [phone], Email: [e-mail]
Chris Patterson, Local Contact
Phone: [phone], Email: [e-mail]

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.

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SOURCE EVALUATION: Site Type: PBR-Uncontrolled
No Flare Controls
Site powered by Engine
The source registered: 20,000 Estimated Oil BBL.

DOGM current 12 month rolling production is: 10,717 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-42 Mfg Year - 2014 Horse Power - 40 Combustion -
Natural Gas, Engine - Engine - Natural Gas 2-Stroke Lean Burn
Make - Ajax Model - EA-30 Mfg Year - 2014 Horse Power - 29
Combustion - Natural Gas, Pneumatic, Tank

8 Pneumatic Controllers

9 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 December 1, 2015. [R307-502-4]

In Compliance. This source does not use continuous bleed natural gas-driven pneumatic
controllers.

15 Oil and Gas Industry Registration Requirement

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.

18 Storage Vessels

19 Thief hatches are kept closed and latched. [R307-506-4(1)]

In Compliance. All hatches were found closed at the start of the evaluation.

23 Upon modification, the well site was re-evaluated against the thresholds of R307-506-4(2).
[R307-506-4(6)]

In Compliance. Modifications noted by the DAQ were that all production equipment has been
removed. The production is piped off lease. We may need to find out what tank battery it is going
to and make sure that location has controls if needed.

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.

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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. The pumpjacks use Ajax E-42 pre-2008 engines that are not subject to the
emissions limitations of this rule.

40 Affected engines are certified or have an initial performance test per 40 CFR 60.4244. [R307-510-4(2)]

In Compliance. The engines were manufactured before 2008 and are not subject to performance
testing unless reconstructed or relocated after January 2016. These wells were drilled in 2001.

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. The exhaust vents vertically.

42 Engine certifications or initial performance tests required are kept for the life of the engine at the
source. [R307-510-5]

In Compliance.

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 detected.

55 Emission Inventory:

56 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:

59 NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion
Engines [40 CFR 60 Subpart JJJJ]

In Compliance. The engines at this source are manufactured before 2008. The recordkeeping and
maintenance provisions are also met to maintain the use and comply with this subpart.

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PREVIOUS ENFORCEMENT
ACTIONS: No enforcement actions within the past five years.

COMPLIANCE STATUS &
RECOMMENDATIONS: In Compliance – The source was inspected by AVO and with an
OGI camera was found to be well-kept with no visible or
fugitive emissions. The pumpjack engines are Ajax E-42
engines. These are pre-2008 and if a maintenance plan is
developed and followed, no testing is required unless
reconstructed (NSPS (60) JJJJ) or relocated (Utah R307-510).
All production equipment has been removed and production is
piped off lease. Requested records were provided in a timely
manner and reviewed at the local field office.

RECOMMENDATION FOR
NEXT INSPECTION:
The DAQ recommends the next inspector look for where the
production is sent and ensure that the source has controls if
needed. The DAQ recommends the inspection frequency of this
source be reduced. The DAQ was joined by Scout personnel
during the site inspection.

ATTACHMENTS: None