DAQ-2025-000174

1
DAQC-PBR031800001-25
Site ID 3180 (B1)
MEMORANDUM

TO: FILE – SCOUT ENERGY MANAGEMENT LLC – State 4-36-8-15

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

FROM: Chris Jensen, Environmental Scientist

DATE: January 9, 2025

SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION

INSPECTION DATE: January 8, 2025

SOURCE LOCATION: Lat: 40.080117 Long: -110.188007
Duchesne County

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

SOURCE TYPE: Tank Battery
API: 4301334231

SOURCE CONTACTS: Chris Breitling, Corporate Environmental Contact
Phone: [phone], Email: [e-mail]
Kevan Stevens, Field Contact
Phone: [phone], Email: [e-mail]

OPERATING STATUS: 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: 40 CFR 60 Subpart JJJJ.

SOURCE EVALUATION: Site Type: PBR-Uncontrolled
No Flare Controls, Site powered by Engine. The source
registered: 1,055 Estimated Oil BBL.

# - $ . ) . )
2
DOGM current 12 month rolling production is: 94 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 -
Arrow (Lufkin) Model - L-795 Mfg Year - 2010 Horse Power -
65 Combustion - Natural Gas, Pneumatic, Tank

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. 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 natural gas-driven pneumatic controllers at this source are not continuous bleed but are low-bleed or snap acting. 8 Storage Vessels 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. 14 Thief hatches are kept closed and latched. [R307-506-4(1)] In Compliance. All hatches were found closed at the start of the evaluation. 29 41 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. 52

3
Oil and Gas Industry Registration Requirement The source is registered with the DAQ. [R307-505-3(3)] In Compliance. 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. Monthly crude production is being kept. 54 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 well was drilled before 2016 and the pumpjack engine is instead subject to the performance standards in NSPS (60) JJJJ. Applicable Federal Regulations NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines [40 CFR 60 Subpart JJJJ] In Compliance. The engines at this source are not EPA certified. The initial performance testing may or may have not been completed but, the records retention time has expired. The source has an engine maintenance plan that is being followed to maintain compliance.
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.

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