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Home My WebLink AboutDAQ-2025-0031731 DAQC-PBR155770001-25 Site ID 15577 (B1) MEMORANDUM TO: FILE – SM ENERGY COMPANY – Mecham 3-1B2 THROUGH: Rik Ombach, Minor Source Oil and Gas Section Manager FROM: Chris Jensen, Environmental Scientist DATE: June 30, 2025 SUBJECT: OIL AND GAS ATTEMPTED COMPLIANCE EVALUATION INSPECTION DATE: June 12, 2025 SOURCE LOCATION: Lat: 40.334775, Long: -110.052394 Duchesne County Business Office: SM Energy Company 1700 Lincoln Street, Suite 3200 Denver, CO 80203 SOURCE TYPE: Tank Battery API: 4301351844 SOURCE CONTACTS: James Lebeck, Corporate Environmental Contact Phone: 303-830-5855, Email: jlebeck@sm-energy.com Ryan Sokolowski, Field Contact Phone: 574-360-7168, Email: RSokolowski@sm-energy.com OPERATING STATUS: 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 OOOO. SOURCE EVALUATION: Site Type: PBR-Uncontrolled Controlled by flare, Site has Line Power. The source registered: 11,799 Estimated Oil BBL. # - $ . ) . ) 2 DOGM current 12 month rolling production is: 9,219 BBLs. Utah Statute R307-506 requires a source with throughput greater than 8,000 BBLs to have controls. REGISTERED EQUIPMENT Engine - Tank 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 presented an affirmative 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 supplied inspection forms for review. These inspections were conducted monthly as required by 40 CFR (60) OOOO and this requirement. 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. The operator indicated on the monthly inspection records that they use the EPA method 22 to detect visible emissions. 3 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. To be consistent with NSPS (60) OOOOb, 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. The records supplied by the operator met the standards required here. Monitoring surveys are conducted to observe each fugitive emissions component for fugitive emissions. [R307-509-4(1)(c)] In Compliance. Consistent with the Emissions Monitoring Plan requirement for compliance with NSPS (60) OOOO. 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 operator supplied LDAR inspection forms for review. These inspections were conducted twice a year, no sooner than four months apart and no later than seven months apart as required by 40 CFR (60) OOOO and this requirement. 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 latest survey did find a leaking pipe nipple on the fuel inlet to the pilot. It was repaired and verified with an OGI camera that day during the survey. 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. 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. 4 Applicable Federal Regulations NSPS (Part 60) OOOO: Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution [40 CFR 60 Subpart OOOO] In Compliance. This source was evaluated according to the records reviewed. A physical site visit was deemed unsafe. LDAR, AVO, and method 22 evaluations were conducted on time and found to be in compliance. PREVIOUS ENFORCEMENT ACTIONS: None in the past 5 years. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to the site, the overall status is: In Compliance. There was a work over rigged up at the time of inspection. There was a lot of activity and it was decided that for safety reasons we should probably not come on location. Discovering fugitive emissions under these conditions would be futile, with equipment shut down and not in use for some time. A records review was however completed with no issues found. The DAQ would recommend that a future inspector return soon and complete an evaluation. RECOMMENDATION FOR NEXT INSPECTION: The DAQ has no recommendations for the next inspector other than what are customary. UNDER EPA DECREE: No. ATTACHMENTS: None.