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Home My WebLink AboutDAQ-2024-0117751 DAQC-PBR034910001-24 Site ID 3491 (B1) MEMORANDUM TO: FILE – SCOUT ENERGY MANAGEMENT, LLC – Federal 8-20-8-16 THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager FROM: Chris Jensen, Environmental Scientist DATE: November 18, 2024 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: November 13, 2024 SOURCE LOCATION: Lat:40.104421, Long: -110.136527 Business Office: Scout Energy Management, LLC 13800 Montfort Drive, Suite 100 Dallas, TX 75240 SOURCE TYPE: Tank Battery Duchesne API: 4301333995 SOURCE CONTACTS: Chris Breitling, Corporate Environmental Contact Phone: 469-485-3418, Email: chris.breitling@scoutep.com Kevan Stevens, Local Contact Email: kevan.stevens@scoutep.com OPERATING STATUS: Long term 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: NESHAP ZZZZ. 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 - Pre 7/1/2008 Horse Power - 40 Combustion - Natural Gas, Pneumatic, Tank 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. General Provisions: Truck loading is done by bottom filling or submerged fill pipe. [R307-504(1)] In Compliance. 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 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. 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. 3 Oil and Gas Industry Registration Requirement The source is registered with the DAQ. [R307-505-3(3)] In Compliance. Natural Gas Engines: Engines subject to R307-510 shall be certified or have an initial performance test per CFR 60.4244. [R307-510-4(2)] In Compliance. This engine is not EPA certified. It was installed prior to 2008 NSPS JJJJ applicability and will not be required to conduct a performance test. Engine certifications or initial performance tests required are kept for the life of the engine at the source. [R307-510-5] In Compliance. Engines installed before 2016 are not under obligation to retain certifications or stack tests for life. NESHAP (Part 63) ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines. [40 CFR 63 Subpart ZZZZ] In Compliance. Engine maintenance is planned for every six months but has not been performed as the engine has sat idle for over a decade. 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 provided in a timely manner and reviewed at the local field office. This well has been shut in since 2012. 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.