DAQ-2025-000332

1
DAQC-CI154370001-25
Site ID 15437 (B1)

MEMORANDUM

TO: FILE – CHAMPIONX, LLC – Vernal Facility

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Daniel Riddle, Environmental Scientist

DATE: January 13, 2025

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Uintah County

INSPECTION DATE: December 18, 2024

SOURCE LOCATION: 1465 East 1650 South
Vernal, UT 84078

SOURCE CONTACTS: Calvin Williams, Field Operations Manager
970-456-6446, [e-mail]

Harry Chen, Environmental Records
832-370-7032, [e-mail]

OPERATING STATUS: Operating normally at the time of inspection.

PROCESS DESCRIPTION: ChampionX, LLC – Vernal Facility receives bulk chemicals
which are transferred to the on-site storage tanks. Bulk chemicals
are also received in drums or totes. The products handled at the
Vernal Facility include a variety of organic compounds, which
are delivered in bulk. The products are mixed in larger tanks and
transferred to drum, tote, or trucks for transport off-site. All
filling/loading operations utilize submerged, or bottom-fill
method.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN154370006-21, dated
December 15, 2021

SOURCE EVALUATION:

Name of Permittee: Permitted Location:

ChampionX, LLC
Vernal Facility

11177 South Stadium Drive 1465 East 1650 South
Sugar Land, TX 77478 Vernal, UT 84078

SIC Code: 5169: (Chemicals & Allied Products, NEC)
) $ ' $ '
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Section I: GENERAL PROVISIONS

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the
UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to
those rules. [R307-101]

I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]

I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions
covered by this AO must be reviewed and approved. [R307-401-1]

I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the two-year period prior to the date of the request. Unless
otherwise specified in this AO or in other applicable state and federal rules, records shall be kept
for a minimum of two (2) years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall,
to the extent practicable, maintain and operate any equipment approved under this AO, including
associated air pollution control equipment, in a manner consistent with good air pollution control
practice for minimizing emissions. Determination of whether acceptable operating and
maintenance procedures are being used will be based on information available to the Director
which may include, but is not limited to, monitoring results, opacity observations, review of
operating and maintenance procedures, and inspection of the source. All maintenance performed
on equipment authorized by this AO shall be recorded. [R307-401-4]

I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]

I.8 The owner/operator shall submit documentation of the status of construction or modification to
the Director within 18 months from the date of this AO. This AO may become invalid if
construction is not commenced within 18 months from the date of this AO or if construction is
discontinued for 18 months or more. To ensure proper credit when notifying the Director, send
the documentation to the Director, attn.: NSR Section. [R307-401-18]

Status: In Compliance. No limits set forth in this AO appear to have been exceeded. The
source stated that there have been no modifications to the equipment or processes. The
equipment appeared to be properly operated and maintained according to manufacturer
recommendations. Records are kept as required and were made available after the
inspection. No breakdowns have been reported since the previous inspection. This source
is not required to submit an emissions report at this time.

Section II: SPECIAL PROVISIONS

II.A The approved installations shall consist of the following equipment:

II.A.1 Vernal Specialty Chemical Distribution Center

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II.A.2 Storage Tanks
Twenty (20) vertical fixed roof storage tanks
Capacity: Nine (9) 6,014-gallon tanks
Eight (8) 8,809-gallon tanks
Three (3) 12,920-gallon tanks

II.A.3 Drums
Various one-barrel drums for delivering product to customers

II.A.4 Totes
Various units having a maximum capacity of 18 barrels each

II.A.5 Truck Loading
Fugitive emissions arising from the loading to and from delivery trucks, and the mixing and
blending of products to the customers specifications.

Status: In Compliance. The equipment observed on site appeared to match the above
equipment list. No unapproved equipment was observed during the inspection.

II.B Requirements and Limitations

II.B.1 Site-Wide Requirements

II.B.1.a The owner/operator shall not allow visible emissions from any stationary point or fugitive
emission source on site to exceed 10 percent opacity. [R307-401-8]

II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9. [R307-201-3]

Status: In Compliance. No visible emissions were observed from any point at the time of
inspection. Method 9 was utilized to verify opacity limits. See attached VEO form.

II.B.1.b The plant-wide emissions of VOCs and HAPs from the product load out and associated
operations shall not exceed the following:

3.41 tons per rolling 12-month period for VOCs
0.06 tons per rolling 12-month period for ethylene glycol
2.31 tons per rolling 12-month period for methanol,
0.07 tons per rolling 12-month period for xylene,
0.01 tons per rolling 12-month period for naphthalene,
0.08 tons per rolling 12-month period for ethylbenzene,
0.02 tons per rolling 12-month period for toluene, and
2.55 tons per rolling 12-month period for all HAPs combined. [R307-401-8]

II.B.1.b.1 The owner/operator shall calculate a new 12-month throughput total by the 20th day of each
month using data from the previous 12 months using the most current TANKS program. Records
of throughput and TANKS runs shall be kept for all periods when the plant is in operation.
Throughput shall be determined by invoice records, delivery tickets, bills of lading, and/or batch
tickets. The records shall be kept on a monthly basis by the 20th day of each month.
[R307-401-8]
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Status: In Compliance. For the rolling 12-month period from December 2023 – November
2024, reported emissions are as follows:

0.491335 tons for VOCs
0.037355 tons for ethylene glycol
1.06606 tons for methanol
0.033865 tons for xylene
0.00245 tons for naphthalene
0.02448 tons for ethyl benzene
0.002845 tons for toluene
1.167435 tons for HAPs combined

See the attached table for more information.

II.B.2 Tank Requirements

II.B.2.a The owner/operator shall load the tanker trucks on site by the use of submerged loading.
[R307-401-8]

Status: In Compliance. The source loads tanker trucks with submerged loading.

II.B.2.b The owner/operator shall inspect the thief hatches at least once every six months to ensure the
thief hatches are closed, latched, and the associated gaskets, if any, are in good working
condition. Records of thief hatch inspections shall include the date of the inspection and the
status of the thief hatches. [R307-401-8]

Status: In Compliance. See attached for inspections from June 2021 – December 2024.

Section III: APPLICABLE FEDERAL REQUIREMENTS

In addition to the requirements of this AO, all applicable provisions of the following federal programs
have been found to apply to this installation. This AO in no way releases the owner or operator from any
liability for compliance with all other applicable federal, state, and local regulations including
UAC R307.

AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

Ozone Nonattainment and Maintenance Areas: General Requirements [R307-325]

Status: In Compliance. No VOC containing materials were observed spilled, discarded, stored in
open containers, or handled in any other way that would result in greater evaporation.

EMISSION INVENTORY:
The emissions listed below are an estimate of the total potential emissions (PTE) from ChampionX, LLC
– Vernal Facility on the Approval Order (AO) DAQE-AN154370006-21, dated December 15, 2021. PTE
are supplied for supplemental purposes only.

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Criteria Pollutant PTE tons/yr
Volatile Organic Compounds 3.41

Hazardous Air Pollutant PTE lbs/yr
Ethyl Benzene (CAS #100414) 160
Ethylene Glycol (CAS #107211) 120
Methanol (CAS #67561) 4620
Naphthalene (CAS #91203) 20
Toluene (CAS #108883) 40
Xylenes (Isomers And Mixture) (CAS #1330207) 140

PREVIOUS ENFORCEMENT
ACTIONS: No enforcement action within the past five years.

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN154370006-21,
dated December 15, 2021, the overall status is: In Compliance.
The facility appears to be well maintained and operated.
Required records were current and made available after the
inspection via email.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Inspect at the regular inspection frequency for this type of
source. The facility operates Monday – Friday from 6:00 AM to
4:00 PM. A hard hat, steel-toed boots, and safety glasses are
required to tour the facility.

NSR RECOMMENDATIONS: None at this time.

ATTACHMENTS: VEO form, email correspondence, VOC and HAP emissions,
hatch inspections
STATE OF UTAH, DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF AIR QUALITY Page _of_
City/County:
Phone: C(T
Site ID: / SJ.-/ 3}-
Facility:
Equipment/Proce s:
Control Equipment:
Emission Point:
Sky Condition : Clear [ 1 Partly Cloudy f ) Overcast [ )
Precipitation: No f J es l J
ind: Direction: �--Speed: ___ mph
mbient Temp: "F RH: %---
Height Relative to Observer: ----
istance From Observer: ___ _
ondensed Water Vapor Present: No [ J Yes f )
ached l J Detached [ J
ngth of Condensed Water Vapor Plume: ______ _
ackground: ________________ _
tch process unit: indicate observer position relative to
rce; indicate potential emission points and/or actual
ission points. 0
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� Wind ► Emission Point with Plume (1:=J
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,: white-file; canar -inspector; pink-owner/operator
Start time: ____ Stop time: __ _
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COMMENTS:
1 have received a copy of these observations:
Daniel Riddle <[e-mail]>
Air Quality Inspection.
5 messages
Williams, Calvin <[e-mail]>Thu, Dec 19, 2024 at 12:14 PM
To: "Chen, Harry" <[e-mail]>
Cc: "[e-mail]" <[e-mail]>
Harry,
I had the State of Utah stop by to do an Air Quality Inspections. Daniel Riddle need some information that I told him you
can provide.
Daniel,
Will you let Harry know what information you are needing.
Thanks,
Calvin Williams
Field Operations Manager I
ChampionX
1465 E. 1650 S. Vernal UT 84078
T 970-456-6446
E [e-mail]
CONFIDENTIALITY NOTICE: This e-mail communication and any attachments may contain proprietary and privileged
information for the use of the designated recipients named above. Any unauthorized review, use, disclosure or distribution
is prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the
original message.
Daniel Riddle <[e-mail]>Thu, Dec 19, 2024 at 1:17 PM
To: "Williams, Calvin" <[e-mail]>
Cc: "Chen, Harry" <[e-mail]>
Harry,
Please send the rolling 12-month (Dec 23 - Nov 24) totals for your emissions for VOCs, ethylene glycol, methanol, xylene,
napthalene, ethylbenzene, toluene, and combined HAPs as required by Condiiton II.B.1.b. Additionally, send all of the
thief hatch inspections for the past 12 months. I'm attaching your Air Quality Permit for your reference. Please provide
these records by Dec 31, 2024, and let me know if you have any questions.
12/26/24, 10:57 AM State of Utah Mail - Air Quality Inspection.
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-f:1818897339795703285&simpl=msg-f:18188973397957032…1/4
You don't often get email from [e-mail]. Learn why this is important
Best,
Daniel
[Quoted text hidden]
15437 AO.pdf
2425K
Chen, Harry <[e-mail]>Thu, Dec 19, 2024 at 3:32 PM
To: Daniel Riddle <[e-mail]>, "Williams, Calvin" <[e-mail]>
Hello Daniel,

Thx for the follow-up. Yes, I should be able to provide the requested informaon to you by the deadline.

Kind regards,

Harry

From: Daniel Riddle <[e-mail]>
Sent: Thursday, December 19, 2024 2:18 PM
To: Williams, Calvin <[e-mail]>
Cc: Chen, Harry <[e-mail]>
Subject: [EXT] Re: Air Quality Inspecon.

ChampionX IT Security Warning: External sender. This message originated outside of the ChampionX email system. Learn why
this is important
Please do not click on any links or open any attachments unless you trust the sender and know the content is safe.
[Quoted text hidden]
[Quoted text hidden]
Chen, Harry <[e-mail]>Mon, Dec 23, 2024 at 7:56 AM
To: Daniel Riddle <[e-mail]>, "Williams, Calvin" <[e-mail]>
Morning Daneil,

12/26/24, 10:57 AM State of Utah Mail - Air Quality Inspection.
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-f:1818897339795703285&simpl=msg-f:18188973397957032…2/4
You don't often get email from [e-mail]. Learn why this is important
Aached are the requested annual reports in compliance with Vernal Plant’s air permit Special Provision II. B.1.b.1.
for your review and approval. Should you have any further quesons, pls let me know.

Happy Holidays!

Harry

Harry Chen
SHEQ Global Compliance Technical Lead - Central Services

ChampionX
11177 S. Stadium Dr, Sugar Land, Texas 77478
T 281-632-8121 M 832-370-7032
E [e-mail]

From: Daniel Riddle <[e-mail]>
Sent: Thursday, December 19, 2024 2:18 PM
To: Williams, Calvin <[e-mail]>
Cc: Chen, Harry <[e-mail]>
Subject: [EXT] Re: Air Quality Inspecon.

ChampionX IT Security Warning: External sender. This message originated outside of the ChampionX email system. Learn why
this is important
Please do not click on any links or open any attachments unless you trust the sender and know the content is safe.
Harry,
[Quoted text hidden]
[Quoted text hidden]
[Quoted text hidden]
2 attachments
Hatch Insepction 2024.pdf
147K
12/26/24, 10:57 AM State of Utah Mail - Air Quality Inspection.
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-f:1818897339795703285&simpl=msg-f:18188973397957032…3/4
VOC and HAP Dec_2023_Nov_2024.pdf
444K
Daniel Riddle <[e-mail]>Mon, Dec 23, 2024 at 9:33 AM
To: "Chen, Harry" <[e-mail]>
Cc: "Williams, Calvin" <[e-mail]>
Thank you! I'll let you know if I need anything else.
[Quoted text hidden]
12/26/24, 10:57 AM State of Utah Mail - Air Quality Inspection.
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-f:1818897339795703285&simpl=msg-f:18188973397957032…4/4
Page 1 of 4

2024 Annual VOC and HAP Reporting _ Vernal Plant, ChampionX

Page 2 of 4

2024 Annual VOC and HAP Reporting_ Vernal Plant, ChampionX

Page 3 of 4

2024 Annual VOC and HAP Reporting_ Vernal Plant, ChampionX

Page 4 of 4

2024 Annual VOC and HAP Reporting_ Vernal Plant, ChampionX

2024 Vernal Plant Hatch Inspection Record:
INDEX Item Task Status Comments
II.B.2.b The owner/operator shall inspect the thief hatches at least once every six months to ensure the
3.2 Thief/Ports Hatches – Gaskets - Bolts
Check for leaks, corrosion and damage Yes* No Thief hatches close, latch and are in good working condition
thief hatches are closed, latched, and the associated gaskets, if any, are in good working
condition. Records of thief hatch inspections shall include the date of the inspection and the Facility Name:Vernal, UT Inspection Date:6/3/2021
status of the thief hatches. [R307-401-8]Address:1465 E. 1650 S. Vernal UT
Inspector Name:Calvin Williams
Tanks Inspected (ID #’s):
Item Task Status Comments
6/22/2020 Calvin Williams- Field Operations Manager
3.3 Thief/Ports Hatches – Gaskets - Bolts
Check for leaks, corrosion and damage Yes* No Thief hatches close, latch and are in good working condition.
12/8/2020 Calvin Williams- Field
Operations Manager
6/3/2021 Calvin Williams- Field
Operations Manager Facility Name:Vernal, UT Inspection Date:12/15/2021
12/15/2021 Calvin Williams- Field
Operations Manager Address:1465 E. 1650 S. Vernal UT
6/24/2022 Calvin Williams- Field Operations Manager Inspector Name:Calvin Williams
12/19/2022 Calvin Williams- Field Operations Manager Tanks Inspected (ID #’s):
6/23/2023 Calvin Williams- Field Operations Manager
12/18/2023 Calvin Williams- Field
Operations Manager Item Task Status Comments
6/11/2024 Calvin Williams- Field
Operations Manager
3.4 Thief/Ports Hatches – Gaskets - Bolts
Check for leaks, corrosion and damage Yes* No Thief hatches are closed, latched and in good working condition
12/10/2024 Calvin Williams- Field Operations Manager
Facility Name:Vernal, UT Inspection Date:6/24/2022
Address:1465 E. 1650 S.
Inspector Name:Calvin Williams
Tanks Inspected (ID #’s):
Item Task Status Comments3.5 Thief/Ports Hatches – Gaskets - Bolts
Check for leaks, corrosion and damage Yes* No Thief hatches close, latch and are in good working condition.
Facility Name:Vernal, UT Inspection Date:12/19/2022
Address:1465 E. 1650 S.
Inspector Name:Calvin Williams
Tanks Inspected (ID #’s):
Item Task Status Comments3.4 Thief/Ports Hatches – Gaskets - Bolts
Check for leaks, corrosion and damage Yes* No Thief hatches are closed, latched and in good working condition
Facility Name:Vernal, UT Inspection Date:6/23/2023
Address:1465 E. 1650 S.
Inspector Name:Calvin Williams
Tanks Inspected (ID #’s):
Item Task Status Comments3.5 Thief/Ports Hatches – Gaskets - Bolts
Check for leaks, corrosion and damage Yes* No Thief hatches close, latch and are in good working condition.
Facility Name:Vernal, UT Inspection Date:12/18/2023
Address:1465 E. 1650 S.
Inspector Name:Calvin Williams
Tanks Inspected (ID #’s):
Item Task Status Comments3.6 Thief/Ports Hatches – Gaskets - Bolts
Check for leaks, corrosion and damage Yes* No Thief hatches close, latch and are in good working condition.
Facility Name:Vernal, UT Inspection Date:6/11/2024
Address:1465 E. 1650 S.
Inspector Name:Calvin Williams
Tanks Inspected (ID #’s):
Item Task Status Comments3.6 Thief/Ports Hatches – Gaskets - Bolts
Check for leaks, corrosion and damage Yes* No Thief hatches close, latch and are in good working condition.
Facility Name:Vernal, UT Inspection Date:12/10/2024
Address:1465 E. 1650 S.
Inspector Name:Calvin Williams
Tanks Inspected (ID #’s):
Thief Hatch Inspections 1,2,3,4,5,6,7,8,9,10,11,12,13,14,15,16
Date Name & Title Thief Hatch Status Comments(I.e.: closed, latched, condition?)
closed, latched and in good working
condition none
closed, latched and in good working condition none
closed, latched and in good working condition none
closed, latched and in good working condition none
closed, latched and in good working condition none
closed, latched and in good working
condition none
closed, latched and in good working
condition none 1,2,3,4,5,6,7,8,9,10,11,12,13,14,15,16,17,18,19,20
closed, latched and in good working
condition none
closed, latched and in good working
condition none
1,2,3,4,5,6,7,8,9,10,11,12,13,14,15,16,17,18,19,20
1,2,3,4,5,6,7,8,9,10,11,12,13,14,15,16,17,18,19,20
closed, latched and in good working
condition none
1,2,3,4,5,6,7,8,9,10,11,12,13,14,15,16,17,18,19,20
1,2,3,4,5,6,7,8,9,10,11,12,13,14,15,16,17,18,19,20
1,2,3,4,5,6,7,8,9,10,11,12,13,14,15,16,17,18,19,20
1,2,3,4,5,6,7,8,9,10,11,12,13,14,15,16,17,18,19,20