DAQ-2025-002588

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DAQC-PBR101861001-25
Site ID 101861 (B1)
MEMORANDUM

TO: FILE – SM ENERGY COMPANY – Anderson BB 19-45-22 East

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

FROM: Chris Jensen, Environmental Scientist

DATE: May 23, 2025

SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION

INSPECTION DATE: May 8, 2025

SOURCE LOCATION: Lat: -110.144406, Long: 40.287792
Duchesne County

Business Office:
SM Energy Company
1700 Lincoln Street, Suite 3200 Suite 390
Denver, CO 80203

SOURCE TYPE: Tank Battery
API: 4301354426, 4301354427, 4301354429, 4301354430,
4301354431, 4301354432, 4301354433, 4301354434,
4301354435

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

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.

# - $ . ) . )
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SOURCE EVALUATION: Site Type: PBR-Controlled
Controlled by flare, Site has Line Power. The source registered:
2,084,364 Estimated Oil BBL.

DOGM current 12 month rolling production is:
1,027,907 BBLs.
Utah Statute R307-506 requires a source with throughput
greater than 8,000 BBLs to have controls.

REGISTERED EQUIPMENT Engine - Compressor Waukesha L5794GAI Mfg May 2007 1380
HP Mat 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 not leaking. The expected components were found installed. The DAQ observed the installation for a cycle and it seems to be operating as expected. Vessel vent lines route emissions to a VRU. 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. Associated Gas Flares Any flare has an operational auto-igniter and a continuously burning pilot flame. [R307-503-4] In Compliance. Steffes air assist. These components are factory installed. Flare inlet lines are equipped with a fire arrestor, pressure gauge, inlet pressure regulating valve and other components according to the engineering design, the manufacturers specifications or good practices for safety and emissions control. [R307-501-4(1)]] In Compliance. 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. A vapor capture line is used during truck loading if subject to storage vessel emissions controls of R307-506-4(2). [R307-504-4(2)] In Compliance. This source has the required vapor capture line installed.

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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. No leaking components were found during the survey. The components were all operated and installed as expected. VOCs from storage vessels are recycled, recovered or controlled by a device that is compliant with R307-508. Exempt if <8000 bbls crude oil per year, <2000 bbls condensate, or if uncontrolled emissions are <4 tons VOC per year.[R307-506-4(2)(a)] In Compliance. Tank emissions are routed to a VRU with an air assisted candlestick flare as backup. Emissions from emergency storage vessels (NOT used as a storage tank) are controlled according to R307-506-4(2),- or - are only used in emergencies, are emptied within 15 days of receiving fluids and are equipped with a liquid level gauge. [R307-506-4(4)] In Compliance. All tanks are connected together and controlled. Combustors and VOC Control Devices Air pollution control equipment is installed appropriately, maintained and operated, pursuant to the manufacturers specifications, to control emissions. [R307-501-4(2)] In Compliance. Operating correctly while on site. The VOC control device(s) required by R307-506 or R307-507 has a control efficiency of 95% or greater, operates with no visible emissions and has a continuously burning pilot flame and an operational auto-igniter according to R307-503. [R307-508-3(1)] In Compliance. VRU captures 100% of tank emissions and returns them compressed to a sales line. Vessel vent lines are sloped away from the flare inlet or to a separation vessel (scrubber). [R307-501-4(2)] In Compliance. The vent lines are sloped properly. Combuster inlet lines are equipped with a fire arrestor, pressure gauge, inlet pressure regulating valve and other components according to the engineering design, the manufacturer's specifications or good practices for safety and emissions control. [R307-501-4(2)] Not Applicable. Tank emissions sent to a vapor recovery compressor. Air pollution control equipment is designed and sized to achieve the destructive efficiencies in rules and to handle fluctuations in emissions. [R307-501-4(2)] In Compliance. 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. Vertical stacks in excess of 20 feet.
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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. None installed any more. Electricity has been run to the site. 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. There is an emergency flare to prevent venting. Recording Keeping 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. 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. VOC Control Devices A signed and stamped engineering assessment (with required statement) certifying that the closed vent system is of sufficient design and capacity. [40 CFR 60 Subpart OOOOa] In Compliance. The operator supplied an engineering design analysis for this tank battery. Monthly AVO and USEPA method 22 inspections are conducted on VOC control devices and associated equipment, and corrective actions are taken within 5 days and completed within 15 days. [R307-508-3(3)] In Compliance. The operator provided these documents for review and they met the Utah R307-508 standards
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The following records are kept: VOC control device efficiency, for life of the equipment Manufacturer operating and maintenance instructions for VOC control devices, for life of the equipment AVO and USEPA method 22 inspections of the VOC control device(s), associated equipment and any repairs, for 3 years. [R307-508-4] In Compliance. Leak Detection and Repair The source has a source specific emissions monitoring plan. [R307-509-4(1)(a)] In Compliance. A field wide plan was produced to the DAQ for review during the records portion of the evaluation. The DAQ is not pursuing compliance action if this has not been prepared for each individual source. The monitoring plan addresses difficult-to-monitor and unsafe-to-monitor components. [R307-509-4(1)(b)] In Compliance. Consistent with the Emissions Monitoring Plan requirement for compliance with NSPS (60) OOOOb. Monitoring surveys are conducted to observe each fugitive emissions component for fugitive emissions. [R307-509-4(1)(c)] In Compliance. Initial monitoring surveys were within 60 days after startup for new sources. Subsequent surveys are semi-annual (no further than 7 months nor nearer than 4 months apart) for regular components, annual for difficult-to-monitor components, and as required by the monitoring plan for unsafe-to-monitor components. [R307-509-4(1)(d)] In Compliance. The new NSPS (60) OOOOb standard is quarterly and LDARs have been conducted at that frequency. Monitoring surveys are done with OGI equipment or by Method 21. [R307-509-4(1)(e)] In Compliance. The operator uses a Flir GF 320 OGI camera. Fugitive leaks are attempted within 5 days and repaired within 15 days unless infeasible, unsafe, etc., as stated in the rule, which require repair within 24 months per the rule. [R307-509-4(1)(f)] In Compliance. The supplied inspection forms showed that the latest surveys did not find any leaks. Resurvey of the repaired components is completed within 30 days. [R307-509-4(1)(g)] In Compliance. The following records are kept: The emissions monitoring plan, for life of the site LDAR inspections, repairs and resurveys, for 3 years [R307-509-5] In Compliance.

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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 rental company has supplied SM Energy with an EPA certificate for the compressor engine. Engine certifications or initial performance tests required are kept for the life of the engine at the source. [R307-510-5] In Compliance. SM Energy has this on file at the local office. 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. This certified engine meets the standards of NSPS (60) JJJJ. 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' owner completes the maintenance according to their plan as part of the rental agreement with SM Energy. Copies of each maintenance form completed are on file at the local offices of SM Energy. 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 NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines [40 CFR 60 Subpart JJJJ] In Compliance. The engine at this source is EPA Certified NSPS (60) JJJJ compliant and the emissions were within the limits allowed in this subpart. The recordkeeping and maintenance provisions are also met to maintain the certification. NSPS (Part 60) OOOOb: Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification or Reconstruction Commenced After December 6, 2022. In Compliance. This source has a permit (PBR) from the State of Utah with legal and enforceable limits. A monitoring, repair, and record keeping program is in place that would satisfy the requirements of 40 CFR (60) OOOOb for the collection of fugitive emissions components, closed vent system, and storage vessel facilities. See above evaluations. These installations are installed as expected and operating properly. There are other affected facilities installed like intermittent bleed pneumatic controllers and diaphragm pumps but they either use instrument air for actuation or electric actuators and surefire BMS. A reciprocating compressor is installed and operated by Archrock. These have an exemption (in NSPS OOOOb) if installed on an oil well pad. No other affected facilities like gas well unloading, dehydrators, or sweetening units are installed. The planning documents like emissions monitoring, and CVS design analysis are complete. Quarterly LDAR, monthly AVO, and method 22 surveys were completed on time and correctly.

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PREVIOUS ENFORCEMENT
ACTIONS: None in the past 5 years.

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to the site, the overall status is: In Compliance. This
source is a multi- well location of ten long horizontal wells. The
source was surveyed by AVO and with an OGI camera and was
found to be well-kept with no visible or fugitive emissions. The
DAQ toured the installation to look for compliance with NSPS
OOOOb regulations and it appears that it is in compliance. There
is instrument air for pneumatic controls. Note, tank burner
management is done by a Profire BMS using electronic actuators
in place of T-12s and microswitches. Tank bottom and scrubber
water transfer is done by pneumatic diaphragm pumps using
compressed air. There is a vapor recovery unit installed to
compress tank emissions to a sales line as well as a compressor
set for artificial lift. Emergency tank emissions are routed to a
Steffes air assisted flare with tank pressure monitoring and
electric BMS. Horizontal treaters have instrument air plumbed
for controls and a well shut in device installed in case of over
pressure conditions. Incidentally, a LACT unit is installed for
truck loading.

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.

UNDER EPA DECREE: No

ATTACHMENTS: None