DAQ-2025-002302

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DAQC-PBR042570001-25
Site ID 4257 (B1) MEMORANDUM

TO: FILE – SM ENERGY COMPANY – COOK 1-26B1

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

FROM: Chris Jensen, Environmental Scientist

DATE: April 21, 2025

SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION

INSPECTION DATE: April 16, 2025

SOURCE LOCATION: Lat: -109.969100, Long: 40.2764091
Uintah County

Business Office:
SM Energy Company
1700 Lincoln Street, Suite 3200
Denver, CO 80203

SOURCE TYPE: Shut in well
API: 4304731981

SOURCE CONTACTS: James Lebeck, Corporate Environmental Contact
Phone: [phone], Email: [e-mail]
Ryan Sokolowski, Field Contact
Phone: [phone], Email: [e-mail]

OPERATING STATUS: Shut in for frac protect.

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.

SOURCE EVALUATION: Site Type: PBR-Uncontrolled
Controlled by flare, Site has Line Power. The source registered:
469 Estimated Oil BBL.
DOGM current 12 month rolling production is: 30,091 BBLs.
Utah Statute R307-506 requires a source with throughput
greater than 8,000 BBLs to have controls.
# - $ . ) . )
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REGISTERED EQUIPMENT: 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 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. Used 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] Not Applicable. There are no emergency generators installed at this source. 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
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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. 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 breakdowns or venting. Applicable Federal Regulations Not Applicable. This well was drilled prior to the NSPS OOOO regulations and there are no engines installed.
PREVIOUS ENFORCEMENT
ACTIONS: None found in the DAQ repository, TEMPO tracking does
however show a noncompliance in 2022.

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to the site, the overall status is: In Compliance.
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. The
operator's representatives were pleasant and cooperative.
Requested records were provided in a timely manner and reviewed
at the local field office. Since this well was shut in for frac protect
and the previous evaluation was not in compliance, the DAQ
recommends returning soon to look at this source again. The DAQ
recommends it be scheduled for the 2027 inspections.

RECOMMENDATION FOR
NEXT INSPECTION: The DAQ has no recommendations for the next inspector other
than what are customary. The DAQ was joined by SME personnel
during the site inspection.

RECOMMENDATIONS FOR NSR: None

ATTACHMENTS: None