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Home My WebLink AboutDAQ-2024-0048511 DAQC-PBR155190001-24 Site ID 15519 (B1) MEMORANDUM TO: FILE – SCOUT ENERGY MANAGEMENT, LLC – Federal 10-21-9-16 THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager FROM: Chris Jensen, Environmental Scientist DATE: January 29, 2024 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: January 24, 2024 SOURCE LOCATION: Federal 10-21-9-16 Lat: 40.014788 Long: -110.121421 Business Office: 13800 Montfort Drive, Suite 100 Dallas, TX 75240 SOURCE TYPE: Tank Battery Duchesne County API: 4301333110, 4301352513, 4301352514 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. 2 SOURCE EVALUATION: Site Type: PBR-Controlled Controlled by flare Site powered by Engine The source registered: 50,000 Estimated Oil BBL. DOGM current 12 month rolling production is: 10,318 BBLs. Utah Statute R307-506 requires a source with throughput greater than 8,000 BBLs to have controls. REGISTERED EQUIPMENT: Engine - Natural Gas 2-Stroke Lean Burn Make - Ajax Model - E-565 Mfg Year - 2012 Horse Power - 40 Combustion - Natural Gas, Engine - Engine - Natural Gas 2-Stroke Lean Burn Make - Ajax Model - EA-30 Mfg Year - 1953/ 2004 Horse Power - 29 Combustion - Natural Gas, Pneumatic, Tank 3 General Provisions 4 VOC emissions are minimized as reasonably practicable by equipment design, maintenance and operation practices. [R307-501-4(1)] In Compliance. Associated gas is routed to a sales gathering line. Vessel vent lines route emissions to a combustion device. Tanks all have thief hatches and PRV's that are closed and not leaking. 5 Air pollution control equipment is designed and installed appropriately, maintained and operated to control emissions. [R307-501-4(2)] In Compliance. A combustion device is installed and operating properly. The DAQ looked for design and installation parameters such as: The vessel vent line is sloped away from the inlet of the combustor, a two-phase scrubber is used to separate natural gas liquids or condensates, the combustor has a lit pilot with an auto-ignition device, and the inlet to the combustor is controlled by a pressure regulating device. 6 Vessel vent lines are sloped away from the flare inlet or to a separation vessel (scrubber). [R307-501-2] In Compliance. The vent lines are sloped properly. 7 Flare inlet lines are equipped with a fire arrestor, pressure gauge, inlet pressure regulating valve and other components according to the engineering design, the manufacturers specifications or good practices for safety and emissions control. [R307-501-2] In Compliance. The expected components were found installed. 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. 3 10 Flares 11 Any flare has an operational auto-igniter. [R307-503-4] In Compliance. This function is performed by the SureFire BMS. 12 Tank Truck Loading 13 Truck loading is done by bottom filling or submerged fill pipe. [R307-504(1)] In Compliance. The truck loading area is suitable for submerged loading and it is routine for truck drivers to load this way. 14 A vapor capture line is used during truck loading if subject to storage vessel emissions controls of R307-506-4(2). Effective 7/1/2019 for sources existing before 1/1/2018, and upon construction for new sources. [R307-504-4(2)] In Compliance. This source has the required vapor capture line installed. 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. 20 VOCs from storage vessels are recycled, recovered or controlled by a device that is compliant with R307-508. Exempt if <8000 bbls crude oil per year, <2000 bbls condensate, or if uncontrolled emissions are <4 tons VOC per year. [R307-506-4(2)(a)] In Compliance. Tank emissions are routed to an enclosed combustor. 21 Emissions from emergency storage vessels are controlled according to R307-506-4(2), or are only used in emergencies, are emptied within 15 days of receiving fluids and are equipped with a liquid level gauge. [R307-506-4(4)] In Compliance. No tanks are uncontrolled or used as an emergency tank. 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 noticed a new installation of a BMS and solar power for the ECD. 4 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. 25 VOC Control Devices 26 The VOC control device(s) required by R307-506 or R307-507 has a control efficiency of 95% or greater, operates with no visible emissions and has an operational auto-igniter according to R307-503. [R307-508-3(1)] In Compliance. The ECD is a brand (SFI) of combustor that has been certified by the US EPA. 27 Monthly AVO inspections are conducted on VOC control devices and associated equipment, and corrective actions are taken within 15 days. [R307-508-3(3)] In Compliance. The operator supplied inspection forms for review. These inspections were conducted monthly as required by 40 CFR (60) OOOO and this requirement. The operator indicated on the monthly inspection records that they use the EPA method 22 to detect visible emissions. 28 The following records are kept: VOC control device efficiency, for life of the equipment Manufacturer operating and maintenance instructions for VOC control devices, for life of the equipment AVO inspections of the VOC control device(s), associated equipment and any repairs, for 3 years. [R307-508-4] In Compliance. 29 Leak Detection and Repair 30 The source has an emissions monitoring plan. [R307-509-4(1)(a)] In Compliance. A field wide plan was produced to the DAQ for review during the records portion of the evaluation. The DAQ is not pursuing compliance action if this has not been prepared for each individual source. 31 The monitoring plan addresses difficult-to-monitor and unsafe-to-monitor components. [R307-509-4(1)(b)] In Compliance. Consistent with the Emissions Monitoring Plan requirement for compliance with NSPS (60) OOOO. 32 If emissions control is required, monitoring surveys are conducted to observe each fugitive emissions component for fugitive emissions. [R307-509-4(1)(c)] In Compliance. 5 33 Initial monitoring surveys were within 60 days after startup for new sources. Subsequent surveys are semi-annual for regular components, annual for difficult-to-monitor components, and as required by the monitoring plan for unsafe-to-monitor components. [R307-509-4(1)(d)] In Compliance. The records supplied by the operator met the standards required here. 34 Monitoring surveys are done with OGI equipment or by Method 21. [R307-509-4(1)(e)] In Compliance. The operator uses a Flir GF 320 OGI camera. 35 Fugitive leaks are repaired within 15 days unless infeasible, unsafe, etc., as stated in the rule, which require repair within 24 months per the rule. [R307-509-4(1)(f)] In Compliance. The latest LDAR survey revealed fugitive emissions from thief hatches on tanks 1 and 3. These were repaired and verified the same day. 36 Resurvey of the repaired components is completed within 30 days. [R307-509-4(1)(g)] In Compliance. 37 The following records are kept: The emissions monitoring plan, for life of the site LDAR inspections, repairs and resurveys, for 3 years [R307-509-5] In Compliance. 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 engine installed here was placed before 2016 and is not subject to these emissions standards. It is subject to the standards found in NSPS (60) JJJJ. See below. 40 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. 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. 6 43 Associated Gas Flaring 44 Associated gas is routed to a process unit for combustion, a sales pipeline or an operating VOC control device, except in an emergency. An emergency release is unanticipated, temporary, infrequent, unavoidable, =24 hrs. and is not due to operator negligence. Low pressure gas from working loss, breathing loss and oil flashing is not "associated gas". [R307-511-4(1)] In Compliance. Associated gas is gathered to a sales line. 45 The following records are kept: The time and date of event Volume of emissions Any corrective action taken for 3 years. [R307-511-5(1)(a)(b)] In Compliance. No reported venting events or breakdowns. 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 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. 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. This source has an Approval Order from the State of Utah with legal and enforceable limits. A monitoring, repair, and record keeping program is in place that would satisfy the requirements of 40 CFR (60) OOOO for a tank affected facility. There are no other affected facilities that are installed. 7 PREVIOUS ENFORCEMENT ACTIONS: The prior operator did not have performance stack tests for these engines. They self-reported about 40 more and set a goal for compliance by July 2018. 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. 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 remain the same. The DAQ was joined by Scout personnel during the site inspection. ATTACHMENTS: None