DAQ-2024-008010

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t579 g + b3'55December 22nd,2023
File#
Mr. RikOmbach, Manager
C/O Mr. Stephen Foulger, Environmental Scientist
Minor Source Compliance Section
Division of Environmental Quality
State of Utah
195 North 1950 West
Salt Lake City, Utah 84115
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FIESOUFTCES
UTAH DEPAFTMENT OF
ENVIRONMENTAL OUAUry
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DIVISION OF AIR QUALIT\'
Re: Compliance Advisory - XCL Resources - Butcher Butte Pad 27-4D-23 & Butcher Butte Pad 22-3C'
22
Utah Administrative Code R307-506-4, R307-509-4, R307-511-4, R307-501-4, R307-5089-3,
Duchesne County
Dear Mr. Rik Ombach,
XCL Resources ("XCL" or the "Company'') is in receipt of the referenced Compliance Advisory letter: the
Company hereby submits this letter as a response to the same.
Following the receipt of the referenced Compliance Advisory letters on L2/412023, XCL started the
process of compiling the records requested in the Compliance Advisory letters. Please see the additional
information in this packet that addresses each of the outlined comment or concerns in the compliance
advisory letters.
The provided materials include:
o AVCI. OGI camera, and Storage vessel vent system inspections
. Copy of XCL's Emission Monitoring Plan
o VOC Operating and Maintenance lnstructions
o VRU and Flare
Additional items to note:
o The Butcher Butte Pad 22-3C-22 had ongoing drilling and completion activities in the second half
of 2C23. The OGI inspection is scheduled to be performed by the end of the years.
o No emergency flaring was noted at either of the subject locations.
o XCL has started the transition of implementing an electronic recordkeeping database and
process. Transitioning away from paper inspections to electronic. This transition is still ongoing
and is expected to be completed by end of Q1 2024.
o Flare inlet controls for the Butcher Butter Pad 22-3C-22 are still on order and due to supply
chain issues have not yet been received, but will be installed as soon as practicable once
received.
XCL Resources | 500 N. Shepard Suite 3901 Houston, TX77OO7
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. Due to the nature of paper records and changes in staffing, XCL is locating additional records.
And will be provided in a separate update to UDAQ once complete. Current estimated
completion date is by end of January 2024. What is provided, XCL believes to be a good faith
effort to comply and produce the requested records by the UDAQ and demonstrates XCL's
compliance with UDAQ rules and regulations.
XCL is committed to being a good steward of environmental quality and has since taken additional
actions to increase XCL's regulatory oversite and efficiencies. Taking into consideration XCL's
participation and continued cooperation with the respect to current and past Compliance Advisories,
XCL respectfully asks the Utah Department of Environmental Quality Division of Air Quality to close this
matter with no further action.
Once UDAQ has been able to review the provided materials, XCL would like to extend an invitation to
discuss and address any additional concerns or questions. A meeting to be scheduled at the UDAClls
convenience.
Please let us know if you have any questions or would require any additional information in the
meantime.
Thank you,
Ryan
Air Quality
rvan.sokolowski @xclresouces.com
s74.360.7L68
XCL Resources | 600 N. Shepard Suite 3901 Houston, TX77OO7