DAQ-2025-000961

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DAQC-PBR030160001-25
Site ID 3016 (B1)
MEMORANDUM

TO: FILE – SCOUT ENERGY MANAGEMENT LLC – Mon Bt Ne 4-25-8-16

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

FROM: Chris Jensen, Environmental Scientist

DATE: February 10, 2025

SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION

INSPECTION DATE: February 5, 2025

SOURCE LOCATION: Lat: 40.094491 Long: -110.074986
Duchesne County

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

SOURCE TYPE: Tank Battery

API: 4301331639, 4301333262

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

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.

# - $ . ) . )
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SOURCE EVALUATION: Site Type: PBR-Uncontrolled
No Flare Controls, Site powered by Engine. The source
registered: 7,999 Estimated Oil BBL.
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.

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. 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. Natural Gas Engines
Not Applicable. This well was drilled before 2016 and the pumpjack engine is instead subject to
the performance standards in NSPS (60) JJJJ. Emission Inventory: An emissions inventory has been submitted within the past three years. [R307-150-9(1)] In Compliance. 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.

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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. NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines. In Compliance. The engines installed at this source are not certified and may have not had an initial performance test. The recordkeeping time for this document has expired. A maintenance plan has been drafted and followed. The engines have not been used in over a year and no maintenance has been performed.
PREVIOUS ENFORCEMENT
ACTIONS: None in the past 5 years.

COMPLIANCE STATUS &
RECOMMENDATIONS: In Compliance. Inclement weather conditions were outside of
reliable detection parameters for the use of an OGI camera. After
a site visit, the DAQ conducted a review of the rules requiring
recordkeeping. Since none of the engines installed here have
been used in the last year, no maintenance has been performed.
The operator's representatives were pleasant and cooperative.
Requested records were provided in a timely manner and
reviewed 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