DAQ-2025-003006

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DAQC-PBR142960001-25
Site ID 14296 (B1)
MEMORANDUM

TO: FILE – XCL ASSETCO, LLC – Wainoco State 1-14B1

THROUGH: Rik Ombach, Minor Source Oil and Gas Section Manager

FROM: Chris Jensen, Environmental Scientist

DATE: June 6, 2025

SUBJECT: OIL AND GAS PERMIT-BY-RULE EVALUATION

INSPECTION DATE: May 20, 2025

SOURCE LOCATION: Lat: 40.31249876, Long: -109.96740112
Uintah County

Business Office:
XCL AssetCo, LLC
600 North Shepherd Drive Suite 390
Houston, TX 77007

SOURCE TYPE: Tank Battery
API:

SOURCE CONTACTS: Lauren Brown, Corporate Environmental Contact
Phone: [phone], Email: [e-mail]

OPERATING STATUS: Plugged well

PROCESS DESCRIPTION: Oil and gas products are brought to the surface. These products
go through a separator where the oil and any water products are
sent to storage tanks and the gas is used to power equipment on
site (pump jack engine, tank heater, separator, flare, combustor,
etc.) Any remaining gas is sent to a pipeline that feeds a local gas
plant. The oil and process water in the storage tanks is loaded
into tanker trucks and hauled off site for processing and disposal.

APPLICABLE REGULATIONS: Utah Administrative Code (UAC) R307-500 Series for the Oil
and Gas Industry, and UAC R307-201: Emission Standards:
General Emission Standards; and UAC R307-150: Emission
Inventories.

SOURCE EVALUATION: Site Type: PBR-Uncontrolled
No Flare Controls, Site has Line Power.
DOGM current 12 month rolling production is: 1,661 BBLs.
Utah Statute R307-506 requires a source with throughput
greater than 8,000 BBLs to have controls.

# - $ . ) . )
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REGISTERED EQUIPMENT

General Provisions Visible emissions are within the following opacity limits: VOC Control Devices and Gasoline engines 0%, Diesel engines 20%, Natural Gas Engines and Boilers, Treater burners & Tank burners 10%, Mobile source dust 10%. [ R307-201-3] In Compliance. VOC emissions are, at all times, minimized as reasonably practicable by equipment design, maintenance and operation practices. [R307-501-4(1)] In Compliance. No visible emissions were detected by EPA Method 9. All natural gas-driven pneumatic controllers are in compliance with 40CFR 60.5390 or 60.5390a as applicable. Tagging and record keeping requirements are not required. [R307-502-4] In Compliance. No controls are of this type. They are snap acting and low bleed. Tank Truck Loading Truck loading is done by bottom filling or submerged fill pipe. [R307-504(1)] In Compliance. The truck loading area is suitable for submerged loading and it is routine for truck drivers to load this way. Storage Vessels Thief hatches are kept closed and latched. [R307-506-4(1)] In Compliance. All hatches were found closed at the start of the evaluation. Vessel Vent Components: (valves, unions, pressure relief devices, etc.) are leak-free, in good repair, and working as intended. (Tank covers are leak free and form a continuous seal.). [R307-501-4] In Compliance. No leaking components were found during the survey. The components were all operated and installed as expected. Associated Gas Flaring Associated gas is routed to a process unit for combustion, a sales pipeline or an operating VOC control device, except in an emergency. An emergency release is unanticipated, temporary, infrequent, unavoidable, =24 hrs. and is not due to operator negligence. Low pressure gas from working loss, breathing loss and oil flashing is not "associated gas". [R307-511-4(1)] In Compliance. Associated gas is gathered to a sales line. Recording Keeping Requirements Emission Inventory An emissions inventory has been submitted within the past three years. [R307-150-9(1)] In Compliance.

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PREVIOUS ENFORCEMENT
ACTIONS: None in the past 5 years.

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to the site, the overall status is: In Compliance. The
well here was plugged and the status in TEMPO changed to
"inactive." However, the tank battery remains as the production
from the Harvest Fellowship well is piped here. That well is
found about 1/2 mile south and uses the site ID # 102056. As an
inactive source, this tank battery is not represented on our
inspection map and since the location is easily spotted from the
road, the DAQ is easily mistaken in thinking this is an
unregistered source. The Harvest Fellowship well is schedule for
plugging in the near future so this may not be a problem for the
next inspector. It is nice to have a memo in the file for an
explanation of the condition in the field.

RECOMMENDATION FOR
NEXT INSPECTION: None other than what is usual.

UNDER EPA DECREE: No

ATTACHMENTS: None