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Home My WebLink AboutDAQ-2025-0001181 DAQC-PBR101839001-25 Site ID 101839 (B1) MEMORANDUM TO: FILE – SCOUT ENERGY MANAGEMENT, LLC – Mike the Tiger THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager FROM: Chris Jensen, Environmental Scientist DATE: December 31, 2024 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: December 11, 2024 SOURCE LOCATION: Lat:40.07837, Long: -110.13552 Duchesne County Business Office: Scout Energy Management, LLC 13800 Montfort Drive, Suite 100 Dallas, TX 75240 SOURCE TYPE: Tank Battery API: 4301354500, 4301354501, 4301354502, 4301354503 SOURCE CONTACTS: Abby Molyneaux, Corporate Environmental Contact Phone: 972-325-1170, Email: abby.molyneaux@scoutep.com Chris Patterson, Field Contact Phone: 970-620-3459, Email: chris.patterson@scoutep.com OPERATING STATUS: Operating PROCESS DESCRIPTION: Oil and gas products are brought to the surface using a pumping unit. These products go through a separator where the oil and any water products are sent to storage tanks and the 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. These products are sent to an off lease compressor station nearby by underground piping. 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 OOOOb. # - $ . ) . ) 2 SOURCE EVALUATION: Site Type: PBR – Controlled Controlled by flare, Site powered by Engine. DOGM current 12 month rolling production is: 467,641 BBLs. Utah Statute R307-506 requires a source with throughput greater than 8,000 BBLs to have controls. REGISTERED EQUIPMENT: Engine - Pneumatic, Tank 3 General Provisions 4 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. The pneumatic controllers at this source are not continuous bleed but are low- bleed or snap acting. The few that have been installed use instrument air. Most all pneumatic controllers have been replaced with electronic actuators and BMS. 8 8 Flares Any flare has an operational auto-igniter and a continuously burning pilot flame. [R307-503-4] In Compliance. The auto-ignition function is performed by the SureFire BMS. The pilot flame is continuous. Flare inlet lines are equipped with a fire arrestor, pressure gauge, inlet pressure regulating valve and other components according to the engineering design, the manufacturers specifications or good practices for safety and emissions control. [R307-501-4(1)]] In Compliance. A combustion device is installed and operating properly. The DAQ looked for design and installation parameters such as: The vessel vent line is sloped away from the inlet of the 3 combustor, a two-phase scrubber is used to separate Natural Gas liquids or condensates, the combustor has a lit pilot with an auto-ignition device, and the inlet to the combustor is controlled by a pressure regulating device. 11 Tank 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. A vapor capture line is used during truck loading if subject to storage vessel emissions controls of R307-506-4(2). [R307-504-4(2)] In Compliance. This source has the required vapor capture line installed. 14 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. VOCs from storage vessels are recycled, recovered or controlled by a device that is compliant with R307- 508. Exempt if <8000 bbls crude oil per year, <2000 bbls condensate, or if uncontrolled emissions are <4 tons VOC per year. [R307-506-4(2)(a)] In Compliance. Tank emissions are routed to an air assisted flare. Emissions from emergency storage vessels (NOT used as a storage tank) are controlled according to R307-506-4(2), - or - are only used in emergencies, are emptied within 15 days of receiving fluids and are equipped with a liquid level gauge. [R307-506-4(4)] In Compliance. No tanks are uncontrolled or used as an emergency tank. 22 Combustors and VOC Control Devices: Air pollution control equipment is installed appropriately, maintained and operated, pursuant to the manufacturer’s specifications, to control emissions. [R307-501-4(2)] In Compliance. This installation has been installed correctly as the DAQ understands. All of the expected components are present and not leaking. Vessel vent lines are sloped away from the flare inlet or to a separation vessel (scrubber). [R307-501-4(2)] In Compliance. The vent lines are sloped properly. 29 4 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. 32 Associated Gas Flaring Associated gas is routed to a process unit for combustion, a sales pipeline or an operating VOC control device, except in an emergency. An emergency release is unanticipated, temporary, infrequent, unavoidable, =24 hrs. and is not due to operator negligence. Low pressure gas from working loss, breathing loss and oil flashing is not "associated gas". [R307-511-4(1)] In Compliance. No reported releases. The following records are kept: The time and date of event Volume of emissions Any corrective action taken for 3 years. [R307-511-5(1)(a)(b)] In Compliance. No reported releases. Monthly inspections are conducted according to 40 CFR 60.5416a(c) on the closed vent system, openings, thief hatches and bypass devices if emissions control is required, and defects are repaired within 15 days. [R307-506-4(5)] In Compliance. The records supplied by the operator met the standards required here. 41 Emission Inventory: An emissions inventory has been submitted within the past three years. [R307-150-9(1)] In Compliance. This new source has not yet been required to report to an Inventory. 43 Leak Detection and Repair: The source has a source specific emissions monitoring plan. [R307-509-4(1)(a)] In Compliance. A field wide plan was produced to the DAQ for review during the records portion of the evaluation. The DAQ is not pursuing compliance action if this has not been prepared for each individual source. The monitoring plan addresses difficult-to-monitor and unsafe-to-monitor components. [R307-509-4(1)(b)] In Compliance. Consistent with the Emissions Monitoring Plan requirement for compliance with NSPS (60) OOOOb. 5 Monitoring surveys are conducted to observe each fugitive emissions component for fugitive emissions. [R307-509-4(1)(c)] In Compliance. These components are included in the plan. Initial monitoring surveys were within 60 days after startup for new sources. Subsequent surveys are semi-annual (no further than 7 months nor nearer than 4 months apart) for regular components, annual for difficult-to-monitor components, and as required by the monitoring plan for unsafe-to-monitor components. [R307-509-4(1)(d)] In Compliance. These surveys are being conducted Quarterly as required by NSPS (60) OOOOb. Monitoring surveys are done with OGI equipment or by Method 21. [R307-509-4(1)(e)] In Compliance. The operator uses a Flir GF 320 OGI camera. Fugitive leaks are attempted within 5 days and repaired within 15 days unless infeasible, unsafe, etc., as stated in the rule, which require repair within 24 months per the rule. [R307-509-4(1)(f)] In Compliance. The last two surveys both found several leaking components all of which were repaired and verified the same day except for one that needed parts that the LDAR crew did not have on hand. It was however, later repaired on time. Resurvey of the repaired components is completed within 30 days. [R307-509-4(1)(g)] In Compliance. Resurvey was completed at the completion of repair as the repair crew carries an OGI camera. The following records are kept: The emissions monitoring plan, for life of the site LDAR inspections, repairs and resurveys, for 3 years [R307-509-5] In Compliance. 52 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. 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. The DAQ was presented with a copy of the engine certification for the generator originally supplied to Scout by the rental yard who owns and maintains the engine. 6 Engine certifications or initial performance tests required are kept for the life of the engine at the source. [R307-510-5] In Compliance. Scout had a copy on file. 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)] In Compliance. This is a certified engine in use here. 61 Combustors and VOC Control Devices Records for each of the following are kept for three years: Monthly storage vessel vent system inspections (openings, thief hatches, pressure relief devices, bypasses, etc.), if controlled. Monthly crude oil throughput Emission calculations, actuals and sampling data when used to justify an exemption to storage vessel rules Emergency storage vessel usage (dates used, emptied, and volumes), if not controlled. [R307-506-5] In Compliance. Copies kept at the local office. Monthly AVO and USEPA method 22 inspections are conducted on VOC control devices and associated equipment, and corrective actions are taken within 5 days and completed within 15 days. [R307-508-3(3)] In Compliance. The following records are kept: VOC control device efficiency, for life of the equipment Manufacturer operating and maintenance instructions for VOC control devices, for life of the equipment. AVO and USEPA method 22 inspections of the VOC control device(s), associated equipment and any repairs, for 3 years. [R307-508-4] 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 EPA certified that the emissions were within the limits allowed in this subpart. The recordkeeping and maintenance provisions are also met to maintain the certification. 7 NSPS (Part 60) OOOOb: Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification or Reconstruction Commenced After December 6, 2022: In Compliance. This source has an Approval (PBR) from the State of Utah with legal and enforceable limits. A monitoring, repair, and record keeping program is in place that would satisfy the requirements of 40 CFR (60) OOOOb for the collection of fugitive emissions components, closed vent system, and storage vessel facilities. See above evaluations. These installations are installed as expected and operating properly. There are other affected facilities installed like intermittent bleed pneumatic controllers and diaphragm pumps, but they either use instrument air for actuation or electric motors and surefire BMS. A reciprocating compressor is installed and is used for cooling of the associated gas. These have an exemption (in NSPS OOOOb) if installed on an oil well pad. No other affected facilities like gas well unloading, dehydrators, or sweetening units are installed. The planning documents like Emissions monitoring, engine maintenance, and CVS design analysis are done. PREVIOUS ENFORCEMENT ACTIONS: None. This is the first evaluation. COMPLIANCE STATUS & RECOMMENDATIONS: In Compliance. This source is a multi-well location of long horizontal wells. The source was surveyed by AVO and with an OGI camera and was found to be well-kept with no visible or fugitive emissions. The DAQ toured the installation to look for compliance with NSPS OOOOb regulations and it appears that it is in compliance. There is instrument air for pneumatic controls. Note: Tank burner management is done by a Profire BMS using electronic actuators in place of T-12s and microswitches. Tank bottom and scrubber water transfer is done by centrifugal pumps driven by electric motors. There is a rental electric generator installed. Tank emissions are routed to a Steffes air assisted flare with tank pressure monitoring and electric BMS. Horizontal treaters have instrument air plumbed for controls and a well shut in device installed in case of over pressure conditions. A safety PRV at every tank. Incidentally, a LACT unit is installed for truck loading. Electric motors and pumps use produced water for artificial lift. 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.