DAQ-2025-000834

[Customer Name]
[Asset / Opportunity]
[Document Title]
Confidential and / or Proprietary Information Belonging to ChampionX | 1
February 6, 2025 via email
Mr. Chad Gilgen
Section Manager
UTDAQ Minor Source Compliance
P.O. Box 144820
Salt Lake City, Utah Utah 84114
Dear Mr. Gilgen
Re: Notification for Temporary Source
Vernal Facility, ChampionX LLC
1465 E 1650 S
Vernal, UT 84078
For your approval, ChampionX LLC (ChampionX) hereby submits the letter of notification to
have a temporary Frac tank to be used at our Vernal Facility. We are planning to bring in a
21,000-gallon temporary frac tank to the site for holding a permitted chemical product while
the tank farm unit (T-9) is undergoing a routine clean-up and inspection. The project is
expected to be completed within 180 days as of this notification.
Should you have any question or need any further information, please feel free to contact me.
Regards,
Harry Chen
ChampionX LLC
Global Compliance Technical Lead – SHEQ
(O) 281-632-8121; (C) 832-370-7032
[e-mail]
cc. Calvin Williams, Facility Operation Manager, Vernal Facility
REVIEWED
Initials: CG Date: 2-12-25
Compliance Status: Notification LetterFile # 15437 (B2)
Chad Gilgen <[e-mail]>
Temporary Source Notification
Chad Gilgen <[e-mail]>Wed, Feb 12, 2025 at 12:59 PM
To: "Chen, Harry" <[e-mail]>
Cc: "Williams, Calvin" <[e-mail]>, Daniel Riddle <[e-mail]>
Hi Harry,
I am in receipt of the letter.
Thanks,
Chad
Chad Gilgen | Manager | Minor Source Compliance
385-306-6500 (cell)
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
On Wed, Feb 12, 2025 at 9:38 AM Chen, Harry <[e-mail]> wrote:
Morning Chad,

Sorry for the omission….Aached is the reference leer for your file….Appreciate the help from you and your team
to guide us through the process.

Kind regards,

Harry

From: Chen, Harry <[e-mail]>
Sent: Tuesday, February 11, 2025 5:08 PM
To: Chad Gilgen <[e-mail]>
Cc: Williams, Calvin <[e-mail]>; Daniel Riddle <[e-mail]>
Subject: RE: [EXT] Re: Temporary Source Noficaon

Hello Chad,
2/12/25, 1:00 PM State of Utah Mail - Temporary Source Notification
https://mail.google.com/mail/u/0/?ik=36f4379b4d&view=pt&search=all&permmsgid=msg-a:r8320774300272617502&dsqt=1&simpl=msg-a:r83207743…1/5

Thanks for your email and inquiries. I apologize for the late reply due to a family emergency over the past
weekend. I spoke to Mr. Fouler on 1/9 because I was told that he was the only person available to answer my
quesons. Perhaps, what I should have done was to contact your secon directly or Danniel to get the answer.
Sorry for the confusion.

This morning, I did have a discussion with Alan Humpherys at the suggeson of Danniel regarding my applicaon.
Alan agrees that R307-415 does not apply to a minor source facility but recommend that I submit a leer of
noficaon to Minor Source Compliance Secon for approval.

In response to your following questions:
Is there a Standard Operating Procedure or O&M Plan in place for this work demonstrating compliance with the
provisions of Utah Administrative Code R307-325 (copy attached)? The site conducts a daily yard inspection
routinely. The Frac tank will be inspected to ensure the mechanical integrity. The Frac tank has a vapor tight
cover on the top of the container to minimize the vapor emissions. We will apply BMP to maintain tank operation
condition free from drips or leaks.
Will the products from each permitted tank be transferred for cleaning one at a time? The plan is to transfer the
permitted product (SCAL11240W) to the Frac tank for 180 days. It will not be multiple products.
Does each permitted storage tank hold the same product? No. but only one product which has been permitted
for T-9, will be transferred into the temporarily Frac tank for storage.
Does this temporary 21,000 gallon frac tank have separate chambers for different products? No. A single
compartment only.
Does the frac tank have secondary spill containment? Yes. It will be located a concrete slab and protected by
absorbent socks.
Is the frac tank constructed to account for the vapor pressure of the products to ensure VOCs will not be emitted
as fugitives? The frac tank is designed to be vapor tight with a working release at 1 psi to protect the tank
operation. The maximum vapor pressure of the product (SCAL 11240W) is 0.88 psi.
Hope I answer your concerns. Should you have any addional quesons, pls advise.

Kind regards,

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
2/12/25, 1:00 PM State of Utah Mail - Temporary Source Notification
https://mail.google.com/mail/u/0/?ik=36f4379b4d&view=pt&search=all&permmsgid=msg-a:r8320774300272617502&dsqt=1&simpl=msg-a:r83207743…2/5
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E [e-mail]

From: Chad Gilgen <[e-mail]>
Sent: Thursday, February 6, 2025 4:42 PM
To: Chen, Harry <[e-mail]>
Cc: Williams, Calvin <[e-mail]>; Daniel Riddle <[e-mail]>
Subject: [EXT] Re: Temporary Source Noficaon

Hello Harry,

I have a couple of questions regarding your email and attached letter.

In your email you indicated you spoke with Stephen Fouler. Did you intend to reference Stephen Foulger who works
with our Utah Division of Air Quality Minor Source Oil & Gas Compliance group? The attached letter you provided is
addressed to Daniel Riddle with the Utah Division of Air Quality Minor Source Compliance group. Can you please
clarify who you spoke with at the Division of Air Quality regarding this project?

The letter references R307-415-6e as the rule being used to allow this action. The provisions of R307-415 are
applicable to Title V sources. The Champion X Facility in Vernal Utah is exempt from Title V, per the provisions of
R307-415-4(2)(c), so R307-415-6e does not apply to this facility.

Approval Order DAQE-AN154370006-21 (copy attached) lists the following permitted 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
Please provide some additional information about this temporary 21,000-gallon frac tank related to the process for
transferring product to/from this tank as well as the cleaning process for each permitted storage tank as follows:
Is there a Standard Operating Procedure or O&M Plan in place for this work demonstrating compliance with the
provisions of Utah Administrative Code R307-325 (copy attached)?
Will the products from each permitted tank be transferred for cleaning one at a time?
Does each permitted storage tank hold the same product?
Does this temporary 21,000 gallon frac tank have separate chambers for different products?
Does the frac tank have secondary spill containment?
Is the frac tank constructed to account for the vapor pressure of the products to ensure VOCs will not be emitted
as fugitives?
Let me know if you have any questions or would like to discuss any of these items further.
2/12/25, 1:00 PM State of Utah Mail - Temporary Source Notification
https://mail.google.com/mail/u/0/?ik=36f4379b4d&view=pt&search=all&permmsgid=msg-a:r8320774300272617502&dsqt=1&simpl=msg-a:r83207743…3/5

Thanks,
Chad

Chad Gilgen | Manager | Minor Source Compliance
385-306-6500 (cell)

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.

On Thu, Feb 6, 2025 at 11:51 AM Chen, Harry <[e-mail]> wrote:
Dear Mr. Gilgen,

After a consultation with Mr. Stephen Fouler regarding our project on 1/9/2025, I am providing the agency with a
letter of notification as a follow-up for setting up a temporary frac tank at our Vernal Facility. Should you have any
questions, pls advise.

Kind regards,

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]

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2/12/25, 1:00 PM State of Utah Mail - Temporary Source Notification
https://mail.google.com/mail/u/0/?ik=36f4379b4d&view=pt&search=all&permmsgid=msg-a:r8320774300272617502&dsqt=1&simpl=msg-a:r83207743…4/5
2/12/25, 1:00 PM State of Utah Mail - Temporary Source Notification
https://mail.google.com/mail/u/0/?ik=36f4379b4d&view=pt&search=all&permmsgid=msg-a:r8320774300272617502&dsqt=1&simpl=msg-a:r83207743…5/5