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Home My WebLink AboutDAQ-2024-008522Department of Environmental Quality Kimbcrly D. Shelley Executive Director DIVISION OF AIR QUALITY Brycc C. Bird Director DEIDRE HENDERSON Lieutenant Governor June7,2024 DAQC-CAI58020001-24 Site ID 15802 (Bl) Sent Via Certified Mail No. 70070220000100683305 Lauren Brown XCL AssetCo, LLC 600 North Shepherd Drive Suite 390 Houston, Texas 77 007 4580 Dear Ms. Brown, Re: Compliance Advisory - XCL AssetCo, LLC - Butcher Butte Pad 3l-34H-218, Uintah County On February 8,2023,a representative of the Utah Division of Air Quality (DAQ) conducted an inspection of XCL AssetCo, LLC - Butcher Butte Pad 3l-34H-2lE remotely located with the latitude and longitude of 40.257066, -109.933673; Uintah County. The DAQ observed the following regulations of concern: R307-501-4 - General Requirements R307-506-4 - Storage Vessels R307-508-3 - VOC Control Devices These findings may be a violation of Utah Air Conservation Rules. XCL AssetCo, LLC - Butcher Butte Pad 31-34H-2lE 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 included with this letter. Please contact Stephen Foulger at: (801) 662-8650 or sfoulger@utah.gov if you have any additional questions. Sincerely, / t ,.-llt'" - Rik Ombach Minor Source Oil and Gas Compliance Section Manager cc: TriCounty Health Department Alan Humpherys, Manager, Minor Source NSR Section 195 North 1950 West. Salt Lake City, UT Mailing Address: P.O. Box 144820. Sa[ Lake Ciry, UT 84114-4820 Telephone (801) 5364000. Fax (801) 5364099. T.D.D. (801) 903-3978 www.deq.utah.gov Printed on 100% recycled paper DAQC-CAls802000l-24 Page 2 ' PotentialViolation(s) On February 8,2023, Stephen Foulger, an inspector from the DAQ attempted an inspection at XCL AssetCo, LLC - Butcher Butte Pad 3l-34H-2lE located remotely with the latitude and longitude: 40.257066 -109.933673; Uintah County, Utah. At the time of the inspection, the DAQ documented the following potential violation: 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. 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. Requirement and Rule Comments and 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. IR307-506-a(2)(a)] Out of Compliance: VOCs found coming from produced water stack valve. The VOC control device(s) required by R307-506 or R307- 507 has a control efficiency of 95oh or greater, operates with no visible emissions and has an operational auto-igniter according to R307-503. [R307-508-3( I )] 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-s01-4(1)] Out of Compliance: Emissions found coming from Tl2 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 tbund coming from Tl2 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. DAQC-CA1s8020001-24 Page 3 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: (801) 662-8650 or sfoulger@utah.gov if you would like to request a meeting or if you have any questions. ilililililil Flnst-Clas8 Mall Poshge & Fees Pald usPs PermltNo. G10 o G. -4 ru f lr,llll,tl',lllf l,tl,li,'l,lthrhll,lll,lllf 'flf rirt;rr1,;f lt your name, address, and ZP.r4o ln thls boto COMPLIANCE SECTION," SrtoFAtR QUALTry SALT LAKE CITY UT 8H114-4,82A r Completo it6mE 1,2, and O.r Print your name and address on the reverse so that we can retum the catd to you.r Aftach this card to the back of the mallplece, or on the front lf soace oermits- t3 Rgent E] C. 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