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Home My WebLink AboutDAQ-2024-0121381 DAQC-PBR030000001-24 Site ID 3000 (B1) MEMORANDUM TO: FILE – SCOUT ENERGY MANAGEMENT, LLC – Mon Bt 8-23-8-16 THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager FROM: Chris Jensen, Environmental Scientist DATE: December 17, 2024 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: December 4, 2024 SOURCE LOCATION: Lat:40.105975, Long: -110.078956 Duchesne County Business Office: Scout Energy Management, LLC 13800 Montfort Drive, Suite 100 Dallas, TX 75240 SOURCE TYPE: Tank Battery API: 4301332101, 4301334140 SOURCE CONTACTS: Abby Molyneaux, Corporate Environmental Contact Phone: 972-325-1170, Email: abby.molyneaux@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. Federal Subpart: 40 CFR 60 Subpart JJJJ, 40 CFR 60 Subpart ZZZZ. SOURCE EVALUATION: Site Type: PBR – Uncontrolled No Flare Controls, Site powered by Engine. The source registered: 7999 Estimated Oil BBL. # - $ . ) . ) 2 DOGM current 12 month rolling production is: 2,407 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 - Pre 7/1/2008 Horse Power - 40 Combustion - Natural Gas, Engine - Engine - Natural Gas 2- Stroke Lean Burn Make - Arrow (Lufkin) Model - L-795 Mfg Year - Post 7/1/2008 Horse Power - 65 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. 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. 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. Truck Loading 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. 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. 3 Natural Gas Engines See NSPS evaluations below. These engines were manufactured and installed before 2016. 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 Arrow L 795 engine is subject to this subpart. 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 operator has prepared an engine maintenance plan and the maintenance provisions have been met. NESHAP (Part 63) ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines. In Compliance. The Ajax E42 engine is subject to this subpart. Applicable parts of this standard are met with compliance with JJJJ. Maintenance is performed every 6 months, approximately equal to 4,320 hours. 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 for review at the local field office. 4 RECOMMENDATION FOR NEXT INSPECTION: The DAQ has no recommendations for the next inspector other than what are customary. RECOMMENDATIONS FOR NSR: None. ATTACHMENTS: None.