DAQ-2024-004573

1
DAQC-PBR154680001-24
Site ID 15468 (B1)
MEMORANDUM

TO: FILE – SCOUT ENERGY MANAGEMENT, LLC – Federal 5-23-9-16

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

FROM: Chris Jensen, Environmental Scientist

DATE: January 11, 2024

SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION

INSPECTION DATE: January 10, 2024

SOURCE LOCATION: Federal 5-23-9-16
Lat: 40.014978 Long: -110.093554

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

SOURCE TYPE: Tank Battery
Duchesne County
API: 4301332960

SOURCE CONTACTS: Abby Molyneux, 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 NSPS (60) JJJJ.

SOURCE EVALUATION: Site Type: PBR-Uncontrolled
Voluntarily Controlled by Flare

2
Site powered by Engine
The source registered: 20,000 Estimated Oil BBL.

DOGM current 12 month rolling production is: 7,142 BBLs.
Utah Statute R307-506 requires a source with throughput
greater than 8,000 BBLs to have controls.

REGISTERED EQUIPMENT: 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 12/1/2015. [R307-502-4]

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

15 Oil and Gas Industry Registration Requirement

16 The source is registered with the DAQ. [R307-505-3(3)]

In Compliance.

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. The DAQ did not identify any modifications or unauthorized equipment.

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. 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
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. These engines were performance tested pre-2016 and are not subject to these
standards.

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

In Compliance. Stack testing was completed and emissions were within the limits established by
NSPS (60) JJJJ.

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.

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

In Compliance. Copies of the test were presented to the DAQ.

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.

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

4
COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to: Federal 5-23-9-16: In Compliance - The source
was inspected 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