HomeMy WebLinkAboutDAQ-2025-0003361
DAQC-PBR034850001-25
Site ID 3485 (B1)
MEMORANDUM
TO: FILE – SCOUT ENERGY MANAGEMENT, LLC – Federal 6-25-8-15
THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager
FROM: Chris Jensen, Environmental Scientist
DATE: January 13, 2025
SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION
INSPECTION DATE: January 8, 2025
SOURCE LOCATION: Lat:40.09117, Long: -110.183083
Duchesne County
Business Office:
Scout Energy Management, LLC
13800 Montfort Drive, Suite 100
Dallas, TX 75240
SOURCE TYPE: Tank Battery
API: 4301350053
SOURCE CONTACTS: Chris Breitling, Corporate Environmental Contact
Phone: 469-485-3418, Email: chris.breitling@scoutep.com
Kevan Stevens, Field Contact
Phone: 970-458-5121, Email: kevan.stevens@scoutep.com
OPERATING STATUS: Long term 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.
DOGM current 12 month rolling production is: 0 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 - Pre 7/1/2008 Horse Power - 40 Combustion
- Natural Gas, Pneumatic, Tank
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.
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.
Thief hatches are kept closed and latched. [R307-506-4(1)]
In Compliance. All hatches were found closed at the start of the evaluation.
Emission Inventory:
An emissions inventory has been submitted within the past three years. [R307-150-9(1)]
In Compliance.
Oil and Gas Industry Registration Requirement
The source is registered with the DAQ. [R307-505-3(3)]
In Compliance.
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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. 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.
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.