DAQ-2024-007287

State of Utah
SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor
Department of
Environmental Quality
Kimberly D. Shelley
Executiv.e Director
DTVISION OF AIR QUALITY
Bryce C. Bird
Director
November 6,2023 DAQC-I169-23
Site ID 8335 (B1)
Sent Via Certified Mail No. 70190700000208346153
Lauren Brown
XCL Resourcas, LLC
32 I 7 Montrose Boulevard #200
Houston, TX77006
Dear Ms. Brown,
Re: Compliance Advisory - XCL Resources, LLC - Butcher Butte Pad22-3C-22,
Duchesne County
On September 28, 2023, a representative of the Utah Division of Air Quality (DAQ) conducted an
inspection of XCL Resources, LLC Butcher Butte Pad22-3C-22located at latitude 40.28805,
longitude -1 1 0. 1 0428, Duchesne County.
The DAQ observed the following regulations of concern:
R307-506-4 - Storage Vessels
R307-509- 4 - Leak Detection and Repair
R307-511-4 - Associated Gas Flaring
R307-501-4 - General Requirements
R307-508-3 - VOC Control Devices
These findings may be a violation of Utah Air Conservation Rules. XCL Resources, LLC Butcher
Butte Pad22-3C-22 is required to comply with the above regulations. A written response to this
letter is required within ten (10) business days of receipt of this letter.
195 North 1950 West. Salt Lake City, UT
Mailing Address: P.O. Box 144820 . Salt Lake City, UT 84114-4820
Telephone [phone]. Fax [phone]. T.D.D. [phone]
hw.deq.utah.gov
Printed on 100% recycled paper
DAQC-I169-23
Page2
Additional detaits about the above observations and regulations are included with this letter.
Please contact Stephen Foutger at [phone] or [e-mail] if you have any
additional questions.
Minor Source Oil and Gas Compliance Section Manager
RO:SF:rh
cc: TriCounty Health Department
Alan Humpterys, UDAQ, Minor NSR Section Manager
Sincerely,
,rea%A
Rik Ombach
DAQC-I169-23
Page 3
Potential Violation(s)
On September 28,2023, an inspector from the DAQ attempted an inspection at XCL Resources,
LLC Butcher Butte Pad22-3C-22located at latitude 40.28805, longitude -110.10428, Duchesne
County.
At the time of the inspection, the DAQ documented the following potential violation(s):
Reouirement & Rule Comments & Observations
Initial monitoring surveys were within 60 days after startup for
new sources. Subsequent surveys are semi-annual forregular
components, annual for diffrcult-to-monitor components, and as
required by the monitoring plan for unsafe-to-monitor
components. [R307-509-4(l Xd)]
XCL failed to produce requested records.
The source has an emissions monitoring plan.
[R307-s0e-a(l)(a)]
XCL failed to produce requested records.
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 inspections of the VOC control device(s), associated
equipment and any repairs, for 3 years. [R307-5084]
XCL failed to produce requested records.
Resurvey of the repaired components is completed within 30
days. [R307-s09-a( I )(g)]
XCL failed to produce requested records.
The monitoring plan addresses difficult-to-monitor and unsafe-
to-monitor components. [R307-509-4(1Xb)]
XCL failed to produce requested records.
The following records are kept:
The time and date of event
Volume of emissions
Any corrective action taken for 3 years.
[R307-s 1 1 -s( I XaXb)]
XUL talled to produce requested records,
Monthly AVO inspections are conducted on VOC control
devices and associated equipment, and corrective actions are
taken within 15 days. [R307-508-3(3)]
XCL failed to produce requested records.
If emissions control is required, monitoring surveys are
conducted to observe each fugitive emissions component for
tugitive emissions. [R307-509-4( lXc)]
)(UL larled to produce requested records.
DAQC-I169-23
Page 4
The purpose of a Compliance Advisory (CA) is to document observations made by the DAQ. You
are responsible for complying with the Utah Air Conservation Rules. There are possible
administrative and civil penalties for failing to do so. Section 19-2-115 of the Utah Code
Annotated provides that violators of the Utah Air Conservation Act and/or any order issued there
under may be subject to a civil penalty of up to $10,000 per day for each violation.
When considering if the potential violation(s) are resolved, the DAQ will consider the written
response to this CA. Responses may include information demonstrating compliance with the
regulations or an anticipated schedule from your company to become compliant with the
applicable regulations. Once received, the DAQ will review your response and the CA may be
revised as a result of that review.
Failure to respond in writing within ten (10) business days of receipt of this CA shall be
considered in the escalation of subsequent enforcement action and assessment of penalties.
The following records are kept:
The emissions monitoring plan, for life of the site
LDAR inspections, repairs and resurveys, for 3 years
[R307-s0e-s]
XCL failed to produce requested records.
Fugitive leaks are repaired within 15 days unless infeasible,
unsafe, etc., as stated in the rule, which require repair within 24
months per the rule. [R307-5094(1X0]
XCL failed to produce requested records.
Records for each of the following are kept for three years:
Storage vessel vent system inspections (openings, thief
hatches, pressure relief devices, b1ryasses, etc.), if required
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 per R307-506-4(2)[R307-506-5]
XCL failed to produce requested records.
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-s014(2a)]
No back-pressure control device was fbund
installed on the flare inlet at the time of
inspection. XCL has placed an order for
this control measure and will install it once
it has been received.
VOC emissions are minimized as reasonably practicable by
equipment design, maintenance and operation practices.
[R307-s01-4(1)]
Crude oil tank thief hatch found leaking
emissions at the time of inspection.
Air pollution control equipment is designed and installed
appropriately, maintained and operated to control emissions.
[R307-s014(2)]
Crude oil tank thief hatch found leaking
emissions at the time of inspection.
DAQC-I169-23
Page 5
Possible DAQ actions to resolve a CA include: No Further Action Letter, Warning Letter, Early
Administrative Settlement with reduced civil penalty, Settlement Agreement with civil penalty, or
Notice of Violation and Order to Comply.
This CA does not limit or preclude the DAQ from pursuing additional enforcement options.
Additionally, this CA does not constitute abar to enforcement action for conditions that the DAQ
did not observe or evaluate, or any other conditions found during future inspections.
A meeting may be requested to discuss this CA. Please contact Stephen Foulger at [phone]
or [e-mail] if you would like to request a meeting or if you have any questions.
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