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Home My WebLink AboutDAQ-2024-007143 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 903-3978 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-CA157460001-24 Site ID 15746 (B1) Sent Via Certified Mail No. 70190700000208346757 XCL AssetCo, LLC 600 North Shepherd Drive, Suite 390 Houston, TX 77007 Dear Ms. Brown, Re: Compliance Advisory – XCL AssetCo, LLC – Butcher Butte Pad 31-134H-21, 31-64H-21, 31-114H-21, 31-144H-21, Duchesne County On February 8, 2024, a representative of the Utah Division of Air Quality (DAQ) conducted an inspection of XCL AssetCo, LLC Butcher Butte Pad 31-134H-21, 31-64H-21, 31-114H-21, and 31-144H-21 remotely located with the latitude and longitude of 40.258845, -110.031459, Duchesne county. The DAQ observed the following regulations of concern: R307-506-4 - Storage Vessels 60082 R307-508-3 - VOC Control Devices 60082 R307-501-4 - General Requirements 60082 R307-503-4 - Auto-Igniters 60082 These findings may be a violation of Utah Air Conservation Rules. XCL AssetCo, LLC Butcher Butte Pad 31-134H-21, 31-64H-21, 31-114H-21, and 31-144H-21 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. / % Û â Û Ù Û Ý DAQC-CA157460001-24 Page 2 Additional details about the above observations and regulations are included with this letter. Please contact Stephen Foulger at sfoulger@utah.gov or (801) 662-8650 if you have any additional questions. Sincerely, Rik Ombach Minor Source Oil and Gas Compliance Section Manager RO:SF:rh cc: Alan Humpherys, UDAQ, Minor NSR Section Manager TriCounty Health Department DAQC-CA157460001-24 Page 3 Potential Violation(s) On February 8, 2024, Stephen Foulger, an inspector from the DAQ attempted an inspection at XCL AssetCo, LLC Butcher Butte Pad 31-134H-21, 31-64H-21, 31-114H-21, and 31-144H-21 located remotely with the latitude and longitude 40.258845, -110.031459, Duchesne county. At the time of the inspection, the DAQ documented the following potential violation: Requirement & Rule Comments & Observations VOCs from storage vessels are recycled, recovered or controlled by a device that is compliant with R307-508. Exempt if <8000 bbls crude oil per year, <2000 bbls condensate, or if uncontrolled emissions are <4 tons VOC per year.[R307-506-4(2)(a)] Out of Compliance: VOCs found coming from produced water stack valve. Any flare has an operational auto-igniter. [R307-503-4] Out of Compliance: The auto-ignitor to the combustor was found in non-working order and emissions were detected coming from the flare. The VOC control device(s) required by R307-506 or R307-507 has a control efficiency of 95% or greater, operates with no visible emissions and has an operational auto-igniter according to R307-503. [R307-508-3(1)] Out of Compliance: The auto-ignitor to the combustor was found in non-working order and emissions were detected coming from the flare. VOC emissions are minimized as reasonably practicable by equipment design, maintenance and operation practices. [R307-501-4(1)] Out of Compliance: Emissions found coming from T12 pneumatic, produced water tank stack valve, and one-inch chem line. The auto-ignitor to the combustor was found in non-working order and emissions were detected coming from the flare. Air pollution control equipment is designed and installed appropriately, maintained and operated to control emissions. [R307-501-4(2)] Out of Compliance: Emissions found coming from T12 pneumatic, produced water tank stack valve, and one-inch chem line. The auto-ignitor to the combustor was found in non-working order and emissions were detected coming from the flare. 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 deficiencies 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 be in compliance with the applicable regulations. Once received, the DAQ will review your response and the CA may be revised as a result of that review. DAQC-CA157460001-24 Page 4 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. 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 a bar 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 sfoulger@utah.gov or (801) 662-8650 if you would like to request a meeting or if you have any questions.