DAQ-2024-011946

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DAQC-PBR034340001-24
Site ID 3434 (B1)
MEMORANDUM

TO: FILE – SCOUT ENERGY MANAGEMENT LLC – Federal 14-20-8-16

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

FROM: Chris Jensen, Environmental Scientist

DATE: November 25, 2024

SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION

INSPECTION DATE: November 13, 2024

SOURCE LOCATION: Lat: 40.097969 Long: -110.145285
Duchesne County

Business Office:
Scout Energy Management, LLC
13800 Montfort Drive, Suite 100
Dallas, TX 75240

SOURCE TYPE: Tank Battery
API: 4301333991

SOURCE CONTACTS: Abby Molyneaux, Corporate Environmental 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. Federal Subpart: 40 CFR 60 Subpart ZZZZ.

SOURCE EVALUATION: Site Type: PBR-Uncontrolled
No Flare Controls, Site powered by Engine. The source
registered: 3199 Estimated Oil BBL.
DOGM current 12 month rolling production is: 508 BBLs.
Utah Statute R307-506 requires a source with throughput
greater than 8,000 BBLs to have controls.

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REGISTERED EQUIPMENT: Engine - Engine - Natural Gas 2-Stroke Lean Burn Make - Ajax
Model - E-42 Mfg Year - 1955 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)] 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. The expected components were found installed. The DAQ observed the installation for a cycle and it seems to be operating as expected. 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. 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. 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

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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: 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 records reviewed at the local office show service at intervals of twice a year.
PREVIOUS ENFORCEMENT
ACTIONS: None in the past 5 years.

COMPLIANCE STATUS &
RECOMMENDATIONS: Not In Compliance. The source was surveyed by AVO and with
an OGI camera and fugitive emissions were found from a
leaking thief hatch and a pneumatic valve in the treater shed. The
hatch gasket was replaced during the evaluation. Scout personnel
received a phone call, while inspecting another source, from
repair crews that the pneumatic valve diaphragm was replaced
later on that day. Requested records were gathered in a timely
manner for review at the local field office. The DAQ
recommends that no enforcement action be taken.

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