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Home My WebLink AboutDAQ-2024-0117721 DAQC-PBR034170001-24 Site ID 3417 (B1) MEMORANDUM TO: FILE – SCOUT ENERGY MANAGEMENT, LLC – Federal 12-20-8-16 THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager FROM: Chris Jensen, Environmental Scientist DATE: November 22, 2024 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: November 13, 2024 SOURCE LOCATION: Lat:40.10138, Long: -110.150087 Duchesne County Business Office: Scout Energy Management, LLC 13800 Montfort Drive, Suite 100 Dallas, TX 75240 SOURCE TYPE: Tank Battery API: 4301333993 SOURCE CONTACTS: Abby Molyneaux, Corporate Environmental Contact Phone: 972-325-1170, Email: abby.molyneaux@scoutep.com OPERATING STATUS: Shut in 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. Federal Subpart: 40 CFR 60 Subpart JJJJ. SOURCE EVALUATION: Site Type: PBR – Uncontrolled No Flare Controls, Site powered by Engine. DOGM current 12 month rolling production is: 0 BBLs. Utah Statute R307-506 requires a source with throughput greater than 8,000 BBLs to have controls. 2 REGISTERED EQUIPMENT: Engine - Engine - Natural Gas 2-Stroke Lean Burn Make - Ajax Model - E-42 Mfg Year - 1990 Horse Power - 40 Combustion - Natural Gas, Pneumatic, Tank General Provisions: VOC emissions are, at all times, 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. Tanks all have thief hatches and PRV's that are closed and not leaking. All equipment is installed and operated as expected. Visible Emissions Visible emissions are within the following opacity limits: VOC Control Devices and Gasoline engines 0%, Diesel engines 20%, Natural Gas Engines and Boilers, Treater burners & Tank burners 10%, Mobile source dust 10%. [R307-201-3] In Compliance. No visible emissions were detected by use of the USEPA Method 9. Pneumatic Controllers All natural gas-driven pneumatic controllers are in compliance with 40CFR 60.5390 or 60.5390a as applicable. Tagging and record keeping requirements are not required. [R307-502-4] In Compliance. This source does not use continuous bleed natural gas-driven pneumatic controllers. Storage Vessels 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. Thief hatches are kept closed and latched. [R307-506-4(1)] In Compliance. All hatches were found closed at the start of the evaluation. Natural Gas Engines 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. 3 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. The results for the 2023 inventory have not yet been released. 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. Applicable Federal Regulations: NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines. In Compliance. The engine at this source is not certified. Stack testing may or may not have been performed but, the record retention time limit for this testing has expired. The maintenance provisions have been met. PREVIOUS ENFORCEMENT ACTIONS: None in the past 5 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 gathered 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 was joined by Scout personnel during the site inspection. RECOMMENDATIONS FOR NSR: None. ATTACHMENTS: None.