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Home My WebLink AboutDAQ-2025-0021141 DAQC-PBR037110001-25 Site ID 3711 (B1) MEMORANDUM TO: FILE – SCOUT ENERGY MANAGEMENT LLC – Federal 13-29-8-16 THROUGH: Rik Ombach, Minor Source Oil and Gas Section Manager FROM: Chris Jensen, Environmental Scientist DATE: April 14, 2025 SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION INSPECTION DATE: April 9, 2025 SOURCE LOCATION: Lat: -110.150745, Long: 40.083141 Duchesne County Business Office: Scout Energy Management, LLC 13800 Montfort Drive, Suite 100 Dallas, TX 75240 SOURCE TYPE: Tank Battery API: 4301334171 SOURCE CONTACTS: Chris Breitling, Corporate Environmental Contact Phone: 469-485-3418, Email: chris.breitling@scoutep.com Kevan Stevens, Field Contact OPERATING STATUS: Operating 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: 3,199 Estimated Oil BBL. DOGM current 12 month rolling production is: 152 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-42 Mfg Year - 1948 Horse Power - 40 Combustion - Natural Gas, Pneumatic, Tank 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 all but one are not leaking. The expected components were found installed. The DAQ observed the installation for a cycle and it seems to be operating as expected. 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] Out of Compliance. The thief hatch gaskets from the center tank (a crude tank labeled #1) was found leaking. Natural Gas Engines Affected engine exhaust vents are vertical and unrestricted. Stacks are 8' or greater if the site horsepower rating is 151 to 305 Stacks are 10' or greater if the site horse power rating is 306 or greater. [R307-510-4(3)] In Compliance. This source was drilled before 2016 and is not subject to this rule's standards. 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. None are installed on this location. 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. Recordkeeping Requirements 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)] In Compliance. The engine installed at this source is not certified and may have not had an initial performance test. The retention time for this document has expired. A maintenance plan has been drafted and followed. Engine certifications or initial performance tests required are kept for the life of the engine at the source. [R307-510-5] In Compliance. Engines installed before 2016 are not subject to R307-510 and are not under obligation to retain certifications or stack tests for life. Engines that were installed, relocated or modified after January 1, 2016 are required to show compliance with Table 1 of R307-510-4 through a performance test evaluation that is reviewed by the DAQ and found to be in compliance. [R307-510-4(1)] In Compliance. Engines installed before 2016 are not subject to R307-510 and are not under obligation to retain certifications or stack tests for life. 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. A maintenance plan has been drafted and followed. 4 Associated Gas Flaring 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 venting or breakdowns. Applicable Federal Regulations NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines. In Compliance. The engine installed at this source is not certified and may have not had an initial performance test. The retention time for this document has expired. A maintenance plan has been drafted and followed. PREVIOUS ENFORCEMENT ACTIONS: None in the past 5 years. This is the first evaluation. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to the site, the overall status is: Out of Compliance. The source was surveyed by AVO and with an OGI camera and was found to be well-kept with no visible emissions. The thief hatch on the center tank (crude tank labeled #1) was leaking past the envelope gasket. A leaking thief hatch does not meet the standard of closed, sealed, and properly seated (NSPS 60.5411(b)(2)) and maintained to minimize emissions (UAC R307-501). All other fittings, valves, and openings surveyed are not leaking. The DAQ conducted a review of the rules requiring recordkeeping and looked for installation/operation issues. The operator's representatives were pleasant and cooperative. Requested records were provided in a timely manner and reviewed at the local field office. The DAQ recommends no enforcement action to be taken on the leaking gasket as it was replaced by Scout personnel during the course of the evaluation. 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