DAQ-2024-004383

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]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor
DAQC-029-24
Site ID 15099 (B1)
15372
15118
15358
15366
Ryan Zillner 15360
Ovintiv USA Inc.
370 17th Street, Suite 1700
Denver, CO 80202

Dear Mr. Zillner,

Re: No Further Action Letter – Ute Tribal 3-9-4-1E, Ute Tribal 7-9-4-1E, Ute Tribal 11-9-4-1E,
Ute Tribal 13-9-4-1E, Ute Tribal 5-2-4-1E, Ute Tribal 15-3-4-1E, Duchesne County

On October 5, 2023, the Utah Division of Air Quality (DAQ) received a response to the above
early settlement agreements addressing a variety of leak related violations. Based on the findings
of the inspection and response to the compliance advisory and the early settlement agreements
(DAQC-1010-23, 1015-23, 1011-23, 1014-23, 1012-23, and 1013-23), the DAQ feels that the
penalties were appropriate.

The DAQ acknowledges that many of the violations were at sites that did not require controls
and thus the effects of leaks may seem minimal. Due to the number of uncontrolled sites in the
Basin, these minimal effects do have a significant impact on the overall air quality in the Basin
which is why good air quality practices are still required. However, the DAQ is willing to waive
the penalties for these sites at this time. The DAQ is concerned that every source inspected that
day had violations with one source lacking a control required for more than a year. Overall good
maintenance and air quality practices are required and crucial for all sources in the Basin in order
to achieve our goal of achieving attainment with the required air quality standards. The lack of
LDAR requirements or control requirements as an excuse for a lack of maintenance and good air
quality practices at lower producing sites are not the intent of those particular rules.

Please be aware that future instances of noncompliance may be considered violations of Utah Air
Quality Rules and Ovintiv USA Inc. may be assessed penalties up to $10,000 per day if found to
be in violation of Utah Air Quality Rules.

+ 2 / 6 Ú Û Û Ù Û Ý
DAQC-029-24
Page 2

A response to this letter is not required. If you have any questions regarding this letter, please
contact Rik Ombach at [phone] or at [e-mail].

Sincerely,

Rik Ombach, Manager
Minor Source Oil and Gas Compliance Section

RO:CJ:rh

cc: TriCounty Health Department