DAQ-2025-001567

1
DAQC-PBR030070001-25
Site ID 3007 (B1) MEMORANDUM

TO: FILE – SCOUT ENERGY MANAGEMENT LLC – Mon Bt Ne 12-24-8-16

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

FROM: Chris Jensen, Environmental Scientist

DATE: March 17, 2025

SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION

INSPECTION DATE: March 12, 2025

SOURCE LOCATION: Lat: -110.07484 Long: 40.101476
Duchesne County

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

SOURCE TYPE: Tank Battery
API: 4301331923

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

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 ZZZZ.

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.
# - $ . ) . )

2
REGISTERED EQUIPMENT: Engine - Engine - Natural Gas 2-Stroke Lean Burn Make - Ajax
Model - E-30 Mfg Year - 1971 Horse Power - 29 Combustion -
Natural Gas, Pneumatic

General Provisions 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. 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. 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. 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. Vessel Vent Components: (valves, unions, pressure relief devices, etc.) are leak-free, in good repair, and working as intended. (Tank covers are leak free and form a continuous seal.). [R307-501-4] In Compliance. The conditions were too windy to use the OGI camera to look for leaks but there were no obvious issues. Natural Gas Engines Temporary Emergency Generators, in use for less than 100 days, have an operational hour meter and log book (onsite) recording hours used and maintenance performed. [40 CFR 60 Subpart IIII, JJJJ] In Compliance. There are no emergency generators installed at this source.

3
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. Associated gas is gathered to a sales line. 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 breakdowns or venting. Recordkeeping Regulations Emission Inventory An emissions inventory has been submitted within the past three years. [R307-150-9(1)] In Compliance. The operator submitted for the 2023 emissions inventory. 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)] Not Applicable. The engine installed at this source is not certified and may have not had an initial performance test. This engine was manufactured before the 2016 applicability of UAC R307-510 and the 2008 applicability of NSPS JJJJ. It would then be subject to the standards found in NESHAP (63) subpart ZZZZ. A maintenance plan has been drafted and followed. Certified and non-certified engines are regularly maintained according to the Engine manufacturer's Schedule or the Maintenance Plan. [40 CFR 60 Subpart IIII, JJJJ, 63 Subpart ZZZZ] In Compliance. The engines have not been used in over a year and no maintenance has been performed. Applicable Federal Regulations MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines In Compliance. A maintenance plan has been drafted and followed.

4
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. The
production equipment seems to be installed and operated as
expected. The source appeared to be clean and orderly with all of
the expected components found. After a site visit, the DAQ
conducted a review of the recordkeeping requirements. 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