DAQ-2024-007280

ffi
State of Utah
SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor
Department of
Environmental Quality
Kimberly D. Shelley
Executive Director
DIVISION OF AIR QUALITY
Bryce C. Bird
Director
October 24,2023 DAQC-1rs6-23
Site ID: 15513 (81)
Sent Via Certified Mail No. 70190700000208346115
Bob Redweik
Citation Oil & Gas Corporation
14077 Cutten Road
Houston, TX77069
Dear Mr. Redweik:
Re: Early Settlement Agreement - Citation Oil & Gas Corporation - Pineview Tank Battery and
Gas Plant - Summit County, Utah
On August 25,2023, the Utah Division of Air Quality (DAQ) issued a Compliance Advisory to
Citation Oil & Gas Corporation Pineview Tank Battery and Gas Plant as a result of an inspection
performed on August 17,2023. Citation Oil & Gas Corporation responded to the Compliance
Advisory on September 11, 2023, and on October 2,2023. Based on the findings of the inspection
and response to the Compliance Advisory, the DAQ determined that Citation Oil & Gas
Corporation was in violation of:
1. Condition II.B.2.c of Approval Order DAQE-AN155130002-22
The owner/operator shall ensure VOC emissions during truck loading operations are
controlled at all times using a vapor capture line. The vapor capture line shall be connected
from the tanker truck to a control device or process.
Section l9-2-ll5 of the Utah Code provides that violations of the Utah Air Conservation Act (the
Act) and/or any order issued thereunder may be subject to a civil penalty of up to $10,000 per day
for each violation. Based upon our civil penalty policy, we calculated a preliminary civil penalty
for the above listed violation of $729.
The monetary amount of the DAQ settlement offer specified below is derived from a pre-
established schedule of penalties, which takes into account, among other factors, the magnitude
and severity of the violation, economic benefit, cooperation of the source as well as the prior
history of violations. See the attached penalty worksheet for details.
195 North 1950 West. Salt Lake City. UT
Mailing Address: P.O. Box 144820. Salt Lake City, UT 84114-4820
rerephone (80r) s364000 .r#:r2ir,:;:;:ee. r.D.D. (80r) e03-3e78
Printed on 100% recycled paper
DAQC-1rs6-23
Page2
All parties we deal with, whether private, commercial, or governmental are treated similarly in the
settlement process. Early Settlement Agreements are based on the evaluation of the same factors
and criteria in all cases. The DAQ acknowledges that the violation on October 2,2023,was
addressed by Citation Oil & Gas Corporation by installing a vapor capture line to control VOC
emissions for truck loading operations.
If you are interested in settling this violation, we are authorized to offer settlement in accordance
with the DAQ Penalty Policy as follows:
1. Citation Oil & Gas Corporation agrees to pay a reduced civil penalty in the sum of $583.
Payment of a civil penalty precludes further civil enforcement for the above described
violation against the named source. Citation Oil & Gas Corporation agrees to pay $583 of
the stipulated penalty within twenty (20) business days from the date you receive this
Early Settlement Agreement.
2. The DAQ retains its authority to take any enforcement actions based on any and all
violations not specifically described above.
3. In the event any further violations of the Act, the Utah Air Quality Rules, the source's AO,
or the Director's Orders occur, the DAQ may consider the violation described above in
assessing a penalty for the subsequent violations, in accordance with the provisions of
Utah Administrative Code R307- I 30.
4. Entering into this Early Settlement Agreement shall not constitute an admission of
violation of the Act, the Utah Air Quality Rules, or the source's AO nor shall it be inferred
to be such an admission in any administrative or judicial proceeding. The described
violation will constitute part of the company compliance history for any purpose for which
such history is relevant to the DAQ.
At the DAQ's option, you may request a portion of the calculated civil penalty gravity component
to be used to complete a Supplemental Environmental Project (SEP) to benefit present and future
air quality within Utah. For more information, please contact the DAQ representative listed below.
This Early Settlement Agreement constitutes an offer of settlement and is not a demand for
payment. The Early Settlement Agreement reflects a reduced penalty for early settlement of this
matter.
If the above terms are acceptable to you, please sign and return this Early Settlement Agreement
and a check in the sum of $583. Submit the signed Early Settlement Agreement and check made
payable to the DAQ at the letterhead address within twenty (20) business days of receipt of this
Early Settlement Agreement. Electronic payments are also available on our website at:
https ://deq.utah. gov/general/payment-portal.
DAQC-1rs6-23
Page 3
You may write or call to request a settlement conference with the DAQ representative listed
below. A conference must be scheduled within twenty (20) business days of your receipt of this
Early Settlement Agreement. If we do not receive a signed copy of this Early Settlement
Agreement and payment or other correspondence from you within twenty (20) business days of
your receipt, we will assume that you are not interested in resolving this matter as outlined above.
This Early Settlement Agreement is intended to quickly resolve the non-compliance issues listed
above and requires the immediate attention of your company. Failure to resolve this matter as
outlined above may result in this offer being revoked and/or having this matter referred to a
formal enforcement process, including filing a judicial case to collect penalties (up to $10,000 per
day for each violation) and compel compliance in the state district court.
If you have any additional questions regarding this matter, please contact Rik Ombach at
801-499-6095 or by email at [e-mail].
Sincerely,
4-d
Bryce C. Bird
Director
BCB:RO:rh
cc: Summit County Health Department
DAQC-I1s6-23
Page 4
Acceptance of Early Settlement Agreement
I have read the above Early Settlement Agreement and I agree to the terms and conditions thereof.
CompanyName: Citation Oil & Gas Corporation
Name:
Title:
Signature Date Telephone Number
DAQC-I1s6-23
Page 5
Rl07-130-1.
Scope.
This policy provides guidance to the director in negotiating with air pollution sources penalties for
consent agreements to resolve non-compliance situations. It is designed to be used to determine a
reasonable and appropriate penalty for the violations based on the nature and extent ofthe violations,
consideration of the economic benefit to the sources of non+ompliance, and adjustments for specific
circumstances.
R307-130-2.
Categories.
Violations are grouped in four general categories based on the potential for hamr and the nature and
extent ofthe violations. Penalty ranges for each category are listed.
(l) Category A. $7,000-10,000 per day.
Citation OiI & Gas
Corporation -
Pineview Tank
Battery and Gas
PIant
Condition
II.B.2.c of
Approval Order
DAQE.
AN15s13000L22
A lack of
infrastructure for
Yapor capture lines
associated with
truck loading
DAQC-r ts6-23
Page 6
Violations with high potential for impact on public health and the environment including:
(a) Violation of emission standards and
limitations of NESHAP.
(b) Emissions contributing to
nonattainment area or PSD increment
exceedances.
(c) Emissions resulting in documented public health effects
and/or environmental damage.
(2) Category B. $2,000-7,000 per day.
Violations of the Utah Air Conservation Act, applicable State and Federal
regulations, and orders to include:
(a) Significant levels of emissions resulting from violations of emission limitations or
other regulations which are not within Category A.
(b) Substantial non-compliance with
monitoring requirements.
(c) Significant violations of approval orders, compliance orders, and
consent agreements not within Category A.
(d) Significant and/or knowing violations of "notice of intent" and other notification
requirements, including those of NESHAP.
(e) Violations of reporting requirements of
NESHAP.
(3) Category C.Up to $2,000 per day.
Minor violations of the Utah Air Conservation Act, applicable State and Federal Regulations and orders
having no significant public health or environmental impact to include:
(a) Reporting
violations
(b) Minor violations of monitoring
requirements, orders and agreements
(c) Minor violations of emission
limitations or other regulatory
requirements.
(4) Category D.Up to $299.00.
DAQC-1ts6-23
PageT
Violations of specific provisions of R307
which are considered minor to include:
(a) Violation of automobile emission
standards and requirements
(b) Violation of wood-burning regulations
by private individuals
(c) Open buming violations by private
individuals.
R307-130-3.
Adjustments.
The amount of the penalty within each category may be adjusted and/or suspended in
part based upon the following factors:
(1) Good faith efforts to comply or lack of good faith. Good faith takes into account the openness in
dealing with the violations, promptness in correction of problems, and the degree of cooperation with the
State to include accessibility to information and the amount of State effort necessary to bring the source
into compliance.
(2) Degree of willfulness and./or negligence. In assessing willfulness and/or negligence, factors to be
considered include how much control the violator had over and the foreseeability of the events
constituting the violation, whether the violator made or could have made reasonable efforts to prevent
the violation, and whether the violator knew of the legal requirements which were violated.
(3) History of compliance or non-compliance. History of non-compliance includes consideration of
previous violations and the resource costs to the State ofpast and current enforcement actions.
(4) Economic benefit of non-compliance. The amount of economic benefit to the source of non-
compliance would be added to any penalty amount determined under this policy.
(5) Inability to pay. An adjustment downward may be made or a delayed payment schedule may be used
based on a documented inability of the source to pay.
R307-130-4
Options.
Consideration may be given to suspension of monetary penalties in trade-off for expenditures resulting
in additional controls and/or emissions reductions beyond those required to meet existing requirements.
Consideration may be given to an increased amount of suspended penalty as a deterrent to future
violations where
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CITATION OIL & GAS CORPORATION
HOIJSTON.TX 77069
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CITATION OIL & GAS CORPORATION_
14077 CUTTEN ROAD
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HOUSTON,TX 77069
September 11,2023
cERTtFtED MAIL # 92,14 8901 9403 8329 52
RETURN RECEIPT REQUESTED
Mr. Rik Ombach
Minor Source Compliance Manager
Minor Source Oil and Gas Compliance Section
P.O. Box 144820
Salt Lake City, UT 84114-4820
RE: COMPLIANGE ADVISORY (DAQC-903-23) - RESPONSE
PINEVIEW TANK BATTERY & GAS PLANT FACILITY
CONDITION ll.B.2.c of APPROVAL ORDER DAQE-AN1551 30002-22
SUMMIT COUNTY, UTAH
Dear Mr. Ombach:
Citation Oil & Gas Cop. (Citation) hereby submits the required response to the aftached
August 25, 2023, Compliance Advisory (DAQC-903-23) received on 91112023. Our
response to the noted potentialviolation is provided below along with added attachments
for your records.
Cited Potential Violation
On August 17,2023, an inspector from the DAQ conducted an inspedion of Citation's
Pineview Tank Battery and Gas Plant facility located in Summit County, Utah. At the
time of the inspection the DAQ documented the following potentia! violation:
A lack of infrastructure for vapor capture lines associated with truck loading
operations, which may be a violation of Condition ll.B.2.c of Approval Order DAQE-
ANf5513O0O2-22 dated August 15,2022.|n accordance with Condition 11.8.2.c ot
Approval Order DAQE-AN155130002-22, the owner/operator shall ensure VOC
emissions during truck loading operations are controlled at alltimes using a vapor
capture line. The vapor capture line shall be connected from the tanker truck to a
control device or process.
Citation Response: - as documented in our July 31 ,2023, e-mail response the Pineview
Tank Battery truck loading operations does not currently have an active vapor capture
line for truck loading. Citation field personnel has reviewed the configuration of the oil
hauling tank trucks and has determined what materials are necessary to installthe
required vapor capture lines. We are currently ordering al! material to allow the vapors
Page? of?
Compliance Advisory - Response
Pineview Tank Battery and Gas Plant
Sept I l, 2023
recovered from the tank truck to be routed back to the onsite flare. Based on expected
material acquisition, delivery, and construction schedules we are proposing a November
15, 2023, completion date.
As required this response, proposed corrective actions and implementation schedule
have been prepared and sent within the required 10 business day deadline. lf you have
any questions or need additional information regarding this matter, please don't hesitate
to contact me at [phone] or at email [e-mail].
Regards,
r.P.
Manager - Regulatory Compliance
Attachments:
Compliance Advisory (DAQC-903-22)
cc: Kyle Greengberg (UT Division of Air Quality) Via email
State of Utah
SPENCERJ. COX
Governor
DEIDRE HENDERSON
Lieutenant Govetnor
August 25,2023
Sent Via Certified
Department of
Environmental Quality
Kimbcrly D. Sbelley
Erecntive Dhzctor
DIVISION OF AIR QUALITY
Brycc C, Bird
Direclor
Mail No. 70 I 90700000208345859
DAQC-903-23
Site ID 1ss13 (B4)
Re:
Bob Redweik
Citation Oil & Gas Corporation
14077 Cutten Road
Houston, TX77069
Dear Mr. Redweik:
Compliance Advisory - Citation Oil & Gas Corporation - Pineview Tank Battery and Gas
Plant - Condition II.B.2.c of Approval Order DAQE-ANI55130002-22 - Summit County,
Utah
On August 17,2023, a rep,resentative of the Utah Division of Air Quality (DAQ conducted an
inspection of Citation Oil & Gas Corporation Pinwiew Tank Battery and Gas Plant. The DAQ
observed a lack of infrastructure for vapor capture lines associated with truok loading operations
which may be a violation of Condition II.B.2.c of Approval Order DAQE-AI{L55130002A2.
Citation Oil & Gas Corporation 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.
Additional details about the above observations and regulations are attached to this letter. Please
contact Kyle Greenberg at 385-306-6533 or [e-mail] if you have any questions
about this letter.
Sincerely,
:('.-/*.L-
Rik Ombach, Manager
Minor Source Compliance Oil and Gas Section
RO;KG:rh
Summit County Health Department
195 Nortb 1950 West. Salt Lakc City, UT
Mailing Addrcss: P.O. Box 144820 . Salt Lake City, UT 84114-4820
Telcphone (801) 5364000. Fax [phone]. T.D,D. (80t) 903-3978
$ne.deq.doh.gov
Printcd on 10070 recycled peper
cc:
Potential Violation(s)
On August 17,2023, an inspector from the DAQ observed Citation Oil & Gas Corporation
Pineview Tank Battery aad Gas Plant in Summit County, Utah.
At the time of the inspection the DAQ documerted the fotlowing potential violation:
A lack of infrastnrcture for vapor capture line,s associated with truck loading operations, which
may be a violation of Condition II.B.2.o of Approval Order DAQE-ANI155130002-22 dated
August 15,2022.
DAQC403-23
Page2
AO Conditions/Rules
Conilitlon II.B.2.c of Approval Order IIAQE-AI\155130002-22:
The owner/operator shall ensure VOC emigsions during truck loading operations are
controlled at all times using a vapor capture line. The vapor capfure lino shall be connected
from the tanker truck to a control device or process.
The purpose of a Complianee Advisory (CA) is to document observations made by the DAQ. You
are rosponsible for complyiag with the Utah Air Couservation Rules. There are possible
adminigtrative and civil penaltios for failing to do so. Section $A-ll5 of the Utah Code
Annotated provides that violators of the Utah Air Conservation Act andlor any order issued there
uoder may be subject to a civil peualty ol"p to $1O000 per day for each violation.
The written response to this CA uriil be considered in resolving the deficiencies documented in
this letter. It may inch:de information demonsfating compliance with the regulations or a
schedule to bring your company back into compliance with the applicable regulations. The DAQ
will review your response and this CA may be revised as a result of that review, Failwe to
respond in writing within tm (10) business. days of receipt of this CA will be considered in any
subsequent enforcement action and the assessment ofpenalties.
Possible DAQ actions to resolve a CA include: No Furtfier Action Letter, Warning Let0er, Ear$
Adminiskative Settlement with reduced civil penalty, Settlement Agreement with civil penalty, or
Notice of Violation and Order to Comply.
This CA does not limit or preolude the DAQ fi'om pursuing enforcement options conoerning this
inspection. Also, this CA does not constitute abar to enforcement action for conditions that the
DAQ did not observe or evaluate, or any other oonditions found durtng future inspections.
A meeting may be requested to discuss this CA. Please contact Kyle Cneenb eryat385-306-6533
or [e-mail] if you would like to request a meeting or if you have any questions about
this letter.
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