DAQ-2025-001036

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DAQC-PBR030790001-25
Site ID 3079 (B1)
MEMORANDUM

TO: FILE – SCOUT ENERGY MANAGEMENT LLC – Nine Mile 6-7-9-16

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

FROM: Chris Jensen, Environmental Scientist

DATE: January 24, 2025

SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION

INSPECTION DATE: January 22, 2025

SOURCE LOCATION: Lat: 40.047103 Long: -110.163873
Duchesne County

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

SOURCE TYPE: Tank Battery

API: 4301331776, 4301333984

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

OPERATING STATUS: Clutched 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: 5,241 Estimated Oil BBL.
DOGM current 12 month rolling production is: 3,317 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 - DP-60 Mfg Year - 1973 Horse Power - 58 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] Out of Compliance. The pump jack engine, an Ajax DP-60, was smoking with visible emissions greater than 20% opacity. 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. High winds made the use of an OGI camera unreliable so leak detection was not attempted. 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. 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.
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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)] Out of Compliance. This well was drilled before 2016 and the pumpjack engine is instead subject to the performance standards in NSPS (60) JJJJ. See below. However, the engine was smoking with visible emissions greater than 20% opacity. 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. Scout had monthly production totals ready. NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines. Out of Compliance. This engine is reported to have been installed in 2008 and so subject to this rule. The initial performance may or may not have been performed at installation but, the retention time has lapsed. The DAQ was presented with maintenance forms. This engine is maintained yearly in accordance with the prepared maintenance plan. However, it was found to be smoking with visible emissions greater than 20% opacity.
PREVIOUS ENFORCEMENT
ACTIONS: None in the past 5 years.

COMPLIANCE STATUS &
RECOMMENDATIONS: Not in Compliance. Inclement weather conditions were outside
of reliable detection parameters of the OGI camera. The DAQ
only conducted a review of the rules requiring recordkeeping and
a visual determination of equipment and proper installation. The
operator's representatives were pleasant and cooperative.
Requested records were provided in a timely manner and
reviewed at the local field office. However, the oil well was
temporarily shut down, specifically, clutched. The pump jack
engine was left running to circulate the trace fluids for the tank
battery. This engine was found to have visible emissions above
20% opacity. Scout personnel mentioned that the well was
clutched in for maintenance the day before and perhaps the oil
was added above the fill line. The DAQ recommends Scout
answer to a Compliance Advisory and a return evaluation be
assigned soon.

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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: Compliance Advisory, Response to the CA
February 14, 2025

ATTN: Mr. Rik Ombach
Division of Air Quality
Utah Department of Environmental Quality
195 North 1950 West
Salt Lake City, UT 84114-4820

Sent via Email: [e-mail]

Subject: Compliance Advisory
Utah Administrative Code (UAC)Rule R307-201 and 40 CFR Part 60, Subpart JJJJ
Nine Mile 6-7-9-16 (Site 3079), Duchesne County, Utah
Scout Energy Management, LLC

Mr. Rik Ombach:

On February 4, 2025, Scout Energy Management, LLC (Scout) received a Compliance Advisory for the site
identified above dated January 31, 2025. The advisory references an observation made on January 22, 2025 of a
smoking Ajax DP-60 pump jack engine at the Nine Mile 6-7-9-16 well site in Duchesne County, Utah, PBR
Registration Site No. 3079. The compliance advisory identifies potential violations of UAC R307-201-3 (2), and 40
CFR §60.4243(a)(2)(i). Scout requests that you accept this letter, the corresponding email, and provided
information as response to the compliance advisory letter as required within 10 business days of February 4, 2025.

Scout does not know at this time what caused the smoke within the emissions for the engine associated with the
pump jack unit. The unit did have routine maintenance on January 16, 2025. This is an unmanned site and Scout
operators typically visits all there locations at least twice week. If any leaks or issues including smoking engines are
observed during those visits’ operators report the issues to management and or the mechanics and work to resolve
the issue. Based on discussions with management and the mechanics there were no reports of smoke coming from
the engine prior to January 22, 2025 this year. A mechanic did check the engine the following day, January 23,
2025 and did not find anything wrong with the unit and the unit was not smoking. Additionally, the unit was
visited again on February 4, 2025 and no smoke was observed. Pictures and a video were taken on the fourth and
are included with this letter.

In reference to 40 CFR §60.4243(a)(2)(i), included with this letter is a copy of the recently updated Scout, GMBU
Spark Ignited 2 Stroke Lean Burn Engine Inspection Checklist which is essentially the maintenance plan for the
engine at the Nine Mile 6-7-9-16 site assuming there are no repairs or issues with the unit. As mentioned, the site is
unmanned and is typically visited at least twice a week. Any needed repairs are performed as soon as practicable,
typically the same or following day.

If you have any questions regarding the information provided or if additional information is needed, please do not
hesitate to contact me at 469-485-3418 or via email [e-mail].

Sincerely,
Scout Energy Management, LLC
Chris Breitling

Cc: Chris Jensen, Email: [e-mail]