DAQ-2024-010370

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-CA069500001-24
Site ID 6950 (B1)

Sent Via Certified Mail No. 70190700000208347273

Lauren Brown
XCL AssetCo, LLC
600 North Shepherd Drive, Suite 390
Houston, TX 77007-4580

Dear Ms. Brown,

Re: Compliance Advisory – XCL AssetCo, LLC – Butcher Butte Pad 22-4D2-23, Duchesne County

On July 17, 2024, a representative of the Utah Division of Air Quality (DAQ) conducted an inspection
of XCL AssetCo, LLC Butcher Butte Pad 22-4D2-23 remotely located with the latitude and longitude
of 40.289851, -110.201845, Duchesne County.

The DAQ observed the following regulations of concern:

R307-501-4 - General Requirements

These findings may be a violation of Utah Air Conservation Rules. XCL AssetCo, LLC Butcher Butte
Pad 22-4D2-23 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 [e-mail] if you have any additional questions.

Sincerely,

Rik Ombach
Minor Source Oil and Gas Compliance Section Manager

cc: TriCounty Health Department
Alan Humpherys, Manager, Minor Source NSR Section
August 28, 2024
DAQC-CA069500001-24
Page 2

Potential Violation(s)
On July 17, 2024, Stephen Foulger, an inspector from the DAQ conducted an inspection at XCL
AssetCo, LLC Butcher Butte Pad 22-4D2-23 located remotely with the latitude and longitude of
40.289851, -110.201845, Duchesne County.

At the time of the inspection, the DAQ documented the following potential violation:

Requirement & Rule Comments & Observations
VOC emissions are minimized as reasonably practicable by
equipment design, maintenance and operation practices.
[R307-501-4(1)]

Out of Compliance: Emissions detected coming from a T12, and two unlit burners.

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.

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
[e-mail] if you would like to request a meeting or if you have any questions.