DAQ-2025-000853

SM
ENERGY
February 7 ,2025
REVIEWED
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Attn: Mr. Harold Burge & Mr. Chad Gilgen, &
UT DAQ Compliance Section
Department of Environmental Quality
Division of Air Quality
P.O. Box t44820
salt Lake city, UT B4ll4-4820
[Submitted via email to: hburge(Outah.gov & [e-mail] .]
Request ofTest Extension for Sand Dryer & Crusher
SM Energy Company - Anderson Sand Mine
AO: DAQE-GN1.61.87 0002-24
Project Number: N 161870002
Mr. Burge & Mr. Gilgen:
SM Energy Company (SM) owns the approved Sand Dryer and Crusher for the processing facility at
the Anderson Sand Mine, Project Number N161870001. The Division of Air Quality (DAQ) issued
the Approval Order (AO) for the Anderson Sand Mine on September 10,2024 IDAQE-
AN161870007-24). The AO was originally issued to XCL SandCo, LLC, and then transferred to SM
on October 2,2024 wirh AO: DAQE-GN161,870002-24 and Project Number: N161870002. SM
contracts a third-party, Ramsey Hill Exploration, LLC (RHEx), to operate the Anderson Sand Mine.
Within 180 days of startup, the AO requires stack testing on NSPS Subpart OOO and Subpart UUU
units, which would be the Crusher and Sand Dryer, respectively. Please see Conditions II.B.2.h and
II.8.5.a.2. For the following reasons, SM would like to request an extension for these testing
requirements.
There was a transition in ownership. SM's acquisition of XCL fell within the initial 180 days
of startup. It takes some time for new ownership to integrate and assimilate the site
accordingly.
The cold winter months caused a decrease in capacity and limited runtime. The Facility has
a front end with mining, crushing, and washing. The front end has been shut down due to
freezing conditions. Thus, it is challenging for the Facility to reach maximum capacity with
winter temperatures. In addition, the Crusher was removed from the site, and it not
expected to return until May or f une 2025.
Relative to other dryers in the industry, the XCL/SM Rotary Sand Dryer is large. It is rated
for 300 tons per hour (tph). A larger unit needs more time to be able to reach sustainable
maximum capacity for testing. Many sand dryers can take up to a year or longer to
commission and fine tune for maximum operation.
a. Furthermore, historically, other smaller sand dryers in the state have been granted
extensions for initial testing. For XCL/SM's larger dryer, it would seem fair to allow
similar extension status.
1700 Lincoln Street
Suite 3200
Denver, Colorado 80203
SM-Energy.com
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SM Test Extension Request
February 7 ,2025
With these considerations in mind, SM-Energy would respectfully request a 720 to 180-day
extension to the initial stack test. This would be helpful to ensure the Crusher and Sand Dryer are
given appropriate time to reach sustainable maximum capacities, under SM-Energy ownership, and
in more suitable weather conditions. Also, the Crusher is not currently on-site, and there is no way
to test the unit until it returns in May/June timeframe.
Additionally, we should keep in mind that NSPS Subpart UUU requires three, two-hour runs for
testing, so achieving a sustainable maximum capacity is more difficult than most other tests where
only three, one-hour runs are needed.
If agreeable with the DAQ, a 120 to 180-day extension would then move SM-Energy's testing
deadline to June 10 to August10,2025.
We will make ourselves available for a call should you have any questions or wish to further
discuss. Should the DAQ have any questions with this request, please contact Eric Sturm, with Air
Regulations Consulting, LLC (ARC) at402.877.7887 or [e-mail].
Kind regards.
9* Sobb,*,/)
'Ry^nsokolowski,
SM Air Quality Specialist
Eric Sturm, ARC Principal, Sr. Consultant
Mike Cina, RHEx, Director of Operations