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Home My WebLink AboutDAQ-2024-0117761 DAQC-PBR038020001-24 Site ID 3802 (B1) MEMORANDUM TO: FILE – SCOUT ENERGY MANAGEMENT, LLC – Federal 7-20-8-16 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:40.103364, Long: -110.141436 Duchesne County Business Office: Scout Energy Management, LLC 13800 Montfort Drive, Suite 100 Dallas, TX 75240 SOURCE TYPE: Tank Battery API: 4301333997 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: Several leaking components were found with an OGI camera survey; including all three thief hatches and a flowline leak found escaping the insulation bundle. Scout will have to unwrap the bundle and search for the leak. The leaking hatches were repaired during the course of the evaluation by Scout personnel. 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. 2 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. The source registered: 3199 Estimated Oil BBL. 1,341, DOGM current 12 month rolling production is: 1,341 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 - 1979 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: VOC emissions are, at all times, minimized as reasonably practicable by equipment design, maintenance and operation practices. [R307-501-4(1)] Out of Compliance. An OGI survey found that all three thief hatch gaskets were leaking. 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 Thief hatches are kept closed and latched. [R307-506-4(1)] In Compliance. All hatches were found closed at the start of the evaluation. 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. 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. 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. 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. Engines that were installed, relocated or modified after January 1, 2016 are required to show compliance with Table 1 of R307-510-4 through a performance test evaluation that is reviewed by the DAQ and found to be in compliance. [R307-510-4(1)] Not Applicable. This well was drilled before 2016 and the pumpjack engine is instead subject to the performance standards in NSPS (60) JJJJ or NESHAP ZZZZ. Applicable Federal Regulations: 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 completed twice a year. Roughly equivalent to every 4,320 hours specified in this subpart. PREVIOUS ENFORCEMENT ACTIONS: None in the past 5 years. COMPLIANCE STATUS & RECOMMENDATIONS: Out of Compliance. The DAQ found several leaks by a survey with an OGI camera. One leak was from one of the flowlines to the tank battery. These lines are covered in insulation and an aluminum shell. Scout will have to unwrap these and find the leaking component. The leaking hatch gaskets were replaced during the evaluation. No enforcement action taken as this is an uncontrolled source. 4 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.