DAQ-2025-002590

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DAQC-PBR041900001-25
Site ID 4190 (B1)
MEMORANDUM

TO: FILE – SM ENERGY COMPANY – 3-30-21 SOUTH ALTAMONT

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

FROM: Chris Jensen, Environmental Scientist

DATE: May 7, 2025

SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION

INSPECTION DATE: May 1, 2025

SOURCE LOCATION: Lat: -110.041473, Long: 40.2839698
Duchesne County

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

SOURCE TYPE: Tank Battery
API: 4301351586

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

OPERATING STATUS: Partially plugged.

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-Controlled
Voluntarily Controlled by Flare, Site has Line Power. The source
registered: 14,763 Estimated Oil BBL.

# - $ . ) . )
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DOGM current 12 month rolling production is:
4,069 BBLs.
Utah Statute R307-506 requires a source with throughput
greater than 8,000 BBLs to have controls.

REGISTERED EQUIPMENT 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. Air pollution control equipment is not required at this source. The production has fallen below the 8,000 BBL threshold. An enclosed combustor still remains. A combustion device, to gather tank emissions, is installed and operating properly. The DAQ looked for design and installation parameters such as: The vessel vent line is sloped away from the inlet of the combustor, a two-phase scrubber is used to separate natural gas liquids or condensates, the combustor has a lit pilot with an auto-ignition device, and the inlet to the combustor is controlled by a pressure regulating device. The tanks have working thief hatches and a pressure relief device 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. No leaking components were found during the survey. The components were all operated and installed as expected. 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. The generator has been removed and line power is installed.

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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. Recording Keeping Requirements Emission Inventory An emissions inventory has been submitted within the past three years. [R307-150-9(1)] In Compliance. 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. The operator submitted for the 2023 emissions inventory.
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 The DAQ can not recall a Federal Regulation that applies to this source any longer. The electric generator has been removed. There are no engines on location. The production of crude at 4,000 BBLs is not likely to exceed the 6 TPY standard to trigger NSPS 60 OOOOb. This well was originally subject to NSPS 60 OOOOa but was recently, and unsuccessfully, refractured. This well has a single plug at the moment and is scheduled for permanent plugging.
PREVIOUS ENFORCEMENT
ACTIONS: Warning in 2022 for not having a vapor recovery line for truck
loading.

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to the site, the overall status is: In Compliance.
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 did not conducted a review of the rules requiring
recordkeeping as this well no longer has the production for
controls and there are no engines installed.
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This well has been partially plugged for frac protect from nearby
drilling. SM Energy says this well is slated for plugging and will
not be brought back online. Currently all production equipment
remains intact. The Operator's representatives were pleasant and
cooperative.

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