Document 65jyGnp3bE3O72Y1RVDr9pm5g

Cobra Oil and Gas - Flat Rock Compressor Station Full Compliance Evaluation (FCE) On-Site Clean Air Act (CAA) Inspections Inspection Date: March 21, 2023 Inspection Report Date: May 22, 2023 EPA Representatives: Michael Stovern, Colin Lecortz, Christine Tokarz Tribal Representatives: Mike Natchees, Lonnie Favel, Mariko Blackbird, Alverna Nelson Company Representatives: Lee Schultz Company Contact: Inspection Report Prepared By: Inspection Report Reviewed By: Barbara Pappas Production & Regulatory Compliance Supervisor Cobra Oil & Gas Corporation 2201 Kell E. Boulevard Wichita Falls, Texas 76307 970.716.5103, barbara@cobraogc.com Digitally signed by MICHAEL Michael Stovern MICHAEL STOVERN STOVERN Date: 2023.06.27 09:34:43 -06'00' Digitally signed by SCOTT Scott Patefield SCOTT PATEFIELD PATEFIELD Date: 2023.06.27 13:41:50 -06'00' Last CAA Inspection: June 11, 2020 Applicable Rules: 40 C.F.R. Part 63, Subpart HH (MACT HH) 40 C.F.R. Part 63, Subpart ZZZZ (MACT ZZZZ) 40 C.F.R. Part 60, Subpart JJJJ (NSPS JJJJ) CAA Permit History: Part 71 Permit Number: V-UO-000020-2007.00 Issue Date: December 18, 2018 Effective Date: January 17, 2019 General Source Information Parent Company Name: Facility Name: Facility Location: EPA Region: County, State: Reservation: Tribe: Responsible Official: NAICS Code: Cobra Oil and Gas Corporation Flat Rock Compressor Station Latitude 39.565458, Longitude -109.708615 8 Uintah, Utah Uintah & Ouray Reservation Ute Indian Tribe Barbara Pappas 211111 1 ICIS-AIR ID Number: Source Designation: 080000004904701005 Major source subject to Title V Overall Inspection Findings MACT HH: x No concerns were noted in the inspection MACT ZZZZ: x Engine C-4 has operated for 566 hours in 2020, 504 hours in 2021 and 288 hours in 2022 and only one maintenance activity has been conducted on 10/19/2020. MACT ZZZZ requires this engine to have maintenance conducted "every 1,440 hours of operation or annually, whichever comes first". This engine does not appear to meet the maintenance requirements. NSPS JJJJ: x No concerns were noted in the inspection Title V Permit: x Based on the OGI observed venting from the uncontrolled tanks (TK-01 and TK-02) during dip pot liquid dump events there is concerns that these emissions were underestimated during 2022 and that these emissions were not included in 2020 and 2021 annual emissions inventory. Previous Areas of Concern Semi-annual "SIXMON Reports", emission inventory and emission fee worksheets were not submitted for 2019. However, the source did submit a letter stating "The facility did not operate for the entire annual year of 2019". Please be advised that this inspection report is finalized, but that the report is not a final determination of compliance. General Inspection Observations and Commentary The inspectors, tribal representatives and company representative arrived at the site at 10:00 am on 3/21/2023. The inspectors, tribal representative and facility staff made introductions with the inspectors presenting their credentials and completed a brief safety meeting. The inspector started the opening meeting by stating that the purpose of the inspection was to complete a Full Compliance Evaluation (FCE) of the facility with respect to all Clean Air Act (CAA) regulations. The facility operator pointed out that the facility has been mothballed since 2017 with all compressor engines removed from the facility and both dehydration units skillet flanged and no longer operational. Walk Through Inspection Observations: The inspectors began the facility walk through at 10:10 am. The inspectors observed that the facility only had removed all compressor engines at the site and the site only acts as a `pass-through' facility. One generator engine was observed on site and was not operating at the time of the inspection. The facility operator stated that Cummins generator engine has been shutdown for 2 years after they converted the facility meter to solar power. 2 The inspectors preceded to walk through the scrubber buildings and noted all vessels were shutin but there was a leak on a pneumatic liquid level controller. The supply gas valve to the pneumatic was closed and the leak ceased. Both dehydration units were observed to be shut-in with both inlets and outlets skillet flanged. 2 tanks were observed on-site with manufacture dates of February 2005 and July 2013. One tank is currently used to hold liquids that accumulate in the low spots in the pipeline. Two times a day pipeline gas is used to push the liquids to the tank. The facility operated said that these events and estimated emissions are tracked in a system called PRAMS. Upon further request for records Cobra claimed that the liquids come from two dip pots that accumulate water and methanol and use pipeline gas to push the liquids to TK-1 and nothing in TK-2. However, upon OGI video review it is clear there is a substantial amount of gas associated with the liquid dumps and both tanks TK-1 and TK-2 are full of liquid. Closing Meeting Following the facility walkthrough, the inspectors held an exit meeting. The operator identified the company contact for follow-up information and records that would be needed to complete the inspection report. The inspectors said that they would provide a copy of the inspection report when completed. Inspectors left the facility at 10:57 am. Table 1: Engine Details Engine Make Model ID G-1 Cummins G8.3CG C-4 Arrow C-66 Serial # 46985734 38977 Mfg Date Max Fuel HP 3/12/2009 118 NG unknown 17 NG Stroke Burn 4SRB 4SRB Engine Status Shut down Operating 3 Title V Permit Requirements (V-UO-000020-2007.00): I. Facility Information and Emission Unit Identification Table 2 - Emission Units and Emission Generating Activities Emission Unit ID Description 118 hp Cummins G8.3CG Generator Engine; 4-stroke Rich G-1 Burn (4SRB), Natural Gas-Fired: Serial No. 46985734 Installed 6/22/2009 Challenger Process Systems TEG Dehydration Unit Still D-2 Column Vent; 30 MMscf/d* gas throughput; 3.5 gpm* lean glycol recirculation rate: Serial No. N/A Installed 11/2/2006 Control Equipment Air Fuel Ratio (AFR) Controller / NonSelective Catalytic Reduction (NSCR) (not enforceable) Enclosed Combustor (not enforceable) H-2 FlameCo SC-18-10 Glycol Reboiler for D-2, 0.375 MMBtu/hr* Exterran TEG Dehydration Unit Still Column Vent; 21 Enclosed Combustor D-3 MMscf/d Gas Throughput; 3.5 gpm Lean Glycol Recirculation Rate: (not enforceable) Serial No. TBD Installed 11/2009 H-3 F-1 TK-01 TK-02 TK-03 TK-04 TK-05 TK-06 TK-07 TK-08 Hanover SV-20-14 Glycol Reboiler for D-3, 0.5 MMBtu/hr MESSCO 36" VOCinerator, Enclosed Combustor, 95% destruction efficiency 400 bbl Natco Oil/ Produced Water Storage Tanks C-4 Arrow Model C-66, 4SRB Pump-Jack Engine. 17.1 hp-site rated Serial No. 38977 Installed: N/A EL Equipment Leaks and Fugitive Emissions *hp = horsepower, MMscf/d = million standard cubic feet per day, gpm = gallons per minute, MMBtu/hr = million British thermal units per hour. 4 Table 4 - Insignificant Emission Units* Emission Unit ID Description 50/50 Antifreeze Tank 500 gal Horizontal, Welded Steel, Antifreeze Storage Tank Diesel Fuel Tank Methanol Tank Triethylene Glycol Tank Dehydration Drip Tank Load-1 Load-2 500 gal Horizontal, Welded Steel, Diesel Fuel Storage Tank 500 gal Horizontal, Welded Steel, Methanol Storage Tank 500 gal Horizontal, Welded Steel, TEG Storage Tank 500 gal Horizontal, Welded Steel, Dehydration Drip Storage Tank Oil Truck Loadouts for Flat Rock Oil / Produced Water Truck Loadouts for the Flat Rock 13-29-14-20 Oil Well Load-3 Oil / Produced Water Truck Loadouts for the Ute Tribal 29-1A Oil Well Load-4 Oil / Produced Water Truck Loadouts for the Ute Tribal 32-02A Oil Well Load-5 Oil / Produced Water Truck Loadouts for the Ute Tribal 30-6A Oil Well H-5 SB 38-24B, 3.0MMBtu/hr, Separator Heater at Flat Rock 13-29-14-20 Serial No. 0609-659 H-6 NT-250, 0.25 MMBtu/hr, Separator Heater at Ute Tribal 29-1A Serial No. 22607 H-7 SB 16-10 0.50 MMBtu/hr, Separator Heater at Ute Tribal 32-02A Serial No. 0403-059 H-8 SB 18-10 0.50 MMBtu/hr, Separator Heater at Ute Tribal 30-6A Serial No. 0009-502 H-4 FlameCo SB 24-26-24, Process Heater, 0.5 MMBtu/hr *Insignificant emission units can change at the facility as long as the new or replacement units meet the criteria for insignificance, and Cobra supplies information as required under 40 CFR part 71 and this permit. The insignificant emission unit status does not exempt these emission units from the requirements of the New Source Performance Standards (NSPS) and Maximum Available Control Technology (MACT) standards that may apply. 5 II. 40 CFR Part 60, Subpart JJJJ - Standards of Performance for Stationary Spark Ignition Internal Combustion Engines A. Applicability [40 CFR 60.4230] 40 CFR part 60, subpart JJJJ applies to the following engines: 1. Cummins engine identified as Emission Unit G-1 in Table [3] of this permit. There is nothing to evaluate with this general condition. B. General Provisions [40 CFR 60.1-19] 1. The General Provisions at 40 CFR part 60, subpart A apply. Notwithstanding conditions in this permit, the Permittee shall comply with all applicable requirements of 40 CFR part 60, subpart A. 2. All reports required under 40 CFR part 60, subpart A shall be sent to the EPA at the following address as listed in 60.4: Director, Air and Toxics Technical Enforcement Program, 8ENF-AT Office of Enforcement, Compliance and Environmental Justice 1595 Wynkoop Street, Denver, Colorado 80202-1129 There is nothing to evaluate with this general condition. C. Emission Standards for Emission Unit G-1 [40 CFR 60.4233(e), 60.4234, and Table 1] The Permittee, as an owner and operator of a non-emergency SI ICE with a maximum engine power greater than or equal to 100 hp, shall comply with the emission standards in Table 1 of subpart JJJJ over the entire life of the engine: 1. 2.0 gram per horsepower-hour (g/hp-hr) for NOX; 2. 4.0 g/hp-hr for CO; and 3. 1.0 g/hp-hr for VOC. There is nothing to evaluate with this general condition. D. Compliance Requirements for Emission Unit G-1 [60.4243(b) and 60.4244, as applicable] The Permittee, as the owner and operator of stationary SI ICE that must comply with the emission standards specified in section II.B. of this permit, shall demonstrate compliance according to one of the methods specified in paragraphs 1 and 2 of this section, as applicable: 6 1. Purchasing an engine certified according to the procedures specified in subpart JJJJ for the same model year and demonstrating compliance according to one (1) of the methods specified in paragraphs 1. (a) or (b) of this section: (a) If the Permittee operates and maintains the certified stationary SI ICE and control device according to the manufactures emission-related written instructions, the Permittee shall keep records of conducted maintenance to demonstrate compliance, but no performance testing is required. The Permittee shall also meet requirements as specified in 40 CFR 1068 subparts A through D, as applicable. If the Permittee adjusts engine settings according to and consistent with the manufacturer's instructions, the stationary SI ICE will not be considered out of compliance. The facility operates engine unit G-1 as a non-certified engine. (b) If the Permittee does not operate and maintain the certified stationary SI ICE and control device according to the manufactures emission-related written instructions, the engine will be considered a non-certified engine, and the Permittee shall demonstrate compliance according to 60.4243(a)(2)(i) through(iii), as appropriate. Following a records review, engine G-1 was operated in 2020 but then shut-down and the facility was converted to solar power. 2. Purchasing a non-certified engine and demonstrating compliance with the emission standards specified in sections II.B of this permit and according to the requirements specified in 60.4244, and according to the following: As an owner or operator of a stationary SI ICE greater than 25 hp and less than or equal to 500 hp, the Permittee shall keep a maintenance plan and record of conducted maintenance and shall, to the extent practicable, maintain and operate the engine in a manner consistent with good air pollution control practice for minimizing emissions. In addition, the Permittee shall conduct an initial performance test to demonstrate compliance. Following a records request the facility provided the maintenance plan. The current operator does not have records of the engine G-1 initial performance test. The facility has undergone two changes of ownership changes since the initial demonstration in 2009. E. Testing Requirements for Emission Unit G-1 [60.4244 and 60.4245(d)] For each performance test required, the Permittee shall comply with the procedures as specified in 60.4244(a)-(f) and submit performance tests results according to 60.5254(d). 7 The initial performance test was conducted while under previous ownership. The engine does not require periodic performance tests. F. Notifications, Reports, and Records for Owners and Operators [40 CFR 60.4245(a)] 1. The permittee shall keep records of all notifications and supporting documentation submitted to comply with this subpart; 2. The Permittee shall keep all records of maintenance conducted on Emission Units G-1; 3. The Permittee shall keep all documentation pertaining to engine certification from the manufacturer for emission unit; and 4. The Permittee shall maintain all documentation for emission unit G-1 showing the noncertified engine meets emission standards. Following a records request, the facility provide all records of engine maintenance. 8 III. 40 CFR Part 63, Subpart HH- National Emission Standards for Hazardous Air Pollutants from Oil and Gas Production Facilities A. Applicability [40 CFR 63.760(a)-(d)] 1. 40 CFR part 63, subpart HH applies to the following emission units: (a) TEG Dehydration Unit identified as Emission Unit D-2 in Table 2 of this permit; (b) TEG Dehydration identified as Emission Unit D-3 in Table 2 of this permit. 2. Notwithstanding conditions in this permit, the Permittee shall comply with all applicable requirements of 40 CFR part 63, subpart HH for large glycol dehydration units located at a major source of HAP. There is nothing to evaluate with this general condition. B. General Standards [40 CFR part 63, subpart A and 63.764] 1. The General Provisions at 40 CFR part 63, subpart A apply as specified in Table 2 of 40 CFR part 63, subpart HH. Notwithstanding conditions in this permit, the Permittee shall comply with all applicable requirements of 40 CFR part 63, subpart A. 2. All reports required under 40 CFR part 63, subpart A shall be sent to the EPA at the following address as listed in 63.13: Director, Air and Toxics Technical Enforcement Program, 8ENF-AT Office of Enforcement, Compliance and Environmental Justice 1595 Wynkoop Street, Denver, Colorado 80202-1129 3. Except as specified in 63.764(e), the Permittee shall comply with the following requirements for the glycol dehydration unit: (a) The control requirements for large glycol dehydration unit process vents specified in 63.765; (b) The monitoring requirements for large dehydration units specified in 63.773; and (c) The recordkeeping and reporting requirements for large glycol dehydration units specified in 63.774 and 63.775. During the previous onsite inspection both dehydration units were observed to be shut down and had the inlets and outlets skillet flanged preventing operation. Neither dehydration units have operated since the previous onsite inspection in July 2018. During the onsite inspection the units were observed to be skillet flanged and inoperable. 9 4. At all times, the Permittee shall operate and maintain any glycol dehydration unit, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. Determination of whether such operation and maintenance procedures are being used will be based on information available to the EPA which may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records and inspection of the unit. Both dehydration units have been shut down and remained skillet flanged since the previous onsite inspection in July 2018. C. Glycol Dehydration Unit Process Vent Standards [40 CFR 63.765 and 40 CFR 63.771] The Permittee shall comply with the control equipment requirements as follows: 1. Except as specified in 63.765(c), the Permittee shall comply with the applicable requirements for controlling air emissions large glycol dehydration units at major sources of HAP specified in 63.765(b); The source complies with 63.765(b) by meeting the closed-vent system requirements of 63.771(c) and the control device requirements of 63.771(d). 2. For each closed-vent system, the Permittee shall comply with the closed-vent system requirements specified in 63.771(c); Section 771(c) requires the closed-vent system shall be designed and operated with no detectable emissions and for all bypass valves shall meet the requirements specified in paragraphs (c)(3)(i) and (c)(3)(ii). Both dehydration units have been shut down and remained skillet flanged since the inspection in 2018. During the inspection, although the units were shut down at the time, it was observed that both dehydrators' process vents were connected via a closed-vent system to both a condenser and an enclosed combustor and all bypass valves were in compliance with paragraphs 771(c)(3). 3. For each control device, the Permittee shall comply with the applicable control device requirements for large glycol dehydration units at major sources of HAP specified in 63.771(d) or 63.771(f); and Section 771(d) requires the control device to be an enclosed combustion device or vapor recovery device that reduces TOC or HAP emissions by 95% or a flare that meets requirements in 63.11(b). 10 Both dehydration units have been shut down and remained skillet flanged since the 2018 inspection. During the onsite inspection it was observed that both dehydration units route emissions to two control devices, a condenser and enclosed combustor. These devices were identified as manufacturer designed to have 95% destruction efficiency meeting the control device requirements. 4. For each process modification made to comply with the large glycol dehydration unit process vent standards at 63.765(c)(2), the Permittee shall comply with the process modification standards specified in 63.771(e). The source complies with the requirements 63.765(b) not 63.765(c)(2). D. Test Methods, Compliance Procedures, and Compliance Determination Requirements [40 CFR 63.772] The Permittee shall determine compliance with the requirements of 40 CFR part 63, subpart HH using the applicable test methods and compliance procedures specified in 63.772. The facility is subject to 63.772(c) for closed-vent system inspections and 63.772(e) for control device demonstrations. 772(c) requires all closed vent system to be conducted using method 21 and sets thresholds for leak detection. 772(e) identifies the performance test requirements. Both dehydration units have been shut down and remained skillet flanged since the 2018 inspection. E. Inspection and Monitoring Requirements [40 CFR 63.773] 1. For each closed-vent system or cover required for the Permittee to comply with 40 CFR part 63, subpart HH, the Permittee shall comply with the inspection and monitoring requirements specified in 63.773(c). Section 773(c) identifies the requirements for closed vent system inspections. These requirements include initial and annual inspections and leak detection response timeframes and records retention. Both dehydration units have been shut down and remained skillet flanged since the 2018 inspection. 2. For each control device required for the Permittee to comply with 40 CFR part 63, subpart HH, the Permittee shall comply with the inspection and monitoring requirements as specified in 63.773(b) or 63.773(d). Section 773(b) requires the owner or operator of a control device whose model was tested under 63.772(h) (i.e. manufacturer tested) shall develop an inspection and maintenance plan for each control device. At a minimum, the 11 plan shall contain the control device manufacturer's recommendations for ensuring proper operation of the device. Semi-annual inspections shall be conducted for each control device with maintenance and replacement of control device components made in accordance with the plan. Both dehydration units have been shut down and remained skillet flanged since the 2018 inspection. F. Recordkeeping Requirements [40 CFR 63.774] 1. The recordkeeping provisions of 40 CFR part 63, subpart A, that apply and those that do not apply to the Permittee are listed in Table 2 of 40 CFR part 63, subpart HH. 2. The Permittee shall maintain the records specified in 63.774(b), (c), (d), (e), (g) and (h). 3. Except as specified in 63.774(c), 63.774(d) and 63.774(f), the Permittee shall maintain the records specified in 63.774(b). 4. If compliance with the benzene emission limit specified in 63.765(b)(1)(ii) is elected, the Permittee shall document, to the Administrator's satisfaction, the items in 63.774(c). 5. For glycol dehydration units operating at the source that meet the exemption criteria in 63.764(e)(1)(i) or 63.764(e)(1)(ii), the Permittee shall maintain records as specified in 63.774(d). 6. The Permittee shall keep records of the requirements of 63.774(e) when using a flare to comply with 63.771(d). 7. The Permittee shall maintain records, pursuant to 63.774(g), of the occurrence and duration of each malfunction of operation (i.e., process equipment) or the air pollution control equipment and monitoring equipment. The Permittee shall maintain records of actions taken during periods of malfunction to minimize emissions in accordance with 63.764(j), including corrective actions to restore malfunctioning process and air pollution control and monitoring equipment to its normal or usual manner of operation. 8. The Permittee shall keep records of the requirements of 63.774(h) when using a control device whose model is tested under 63.772(h) to comply with 63.771(d), (e)(3)(ii) and (f)(1). 9. The Permittee shall keep records, pursuant to 63.774(i), of the date the semi-annual maintenance inspection required under 63.773(b) is performed when using a control device whose model was tested under 63.772(h). The facility provided all requested records during this inspection. 12 G. Reporting Requirements [40 CFR 63.775] 1. The reporting provisions of subpart A of this part, that apply and those that do not apply to the Permittee are listed in Table 2 of this subpart. 2. The Permittee shall submit the information specified in 63.775(b). Initial notification was completed over ten years ago. Records retention requirements only requires the facility to keep these records for five years. As such, this requirement was not evaluated during this inspection. 3. The Permittee shall submit Notification of Compliance Status Reports as specified in 63.775(d). Notification of Compliance Status Report was completed over ten years ago. Records retention requirements only requires the facility to keep these records for five years. As such, this requirement was not evaluated during this inspection. 4. The Permittee shall submit Periodic Reports as specified in 63.775(e). Because the dehydration unit hasn't operated during the previous 3 years, no periodic reports were submitted. 5. The Permittee shall submit notifications of process changes as specified in 63.775(f). No process changes have occurred since the previous inspection. 6. The Permittee shall comply with any applicable electronic reporting provisions specified at 63.775(g). Section 775(g) requires all performance tests to be submitted to Webfire within 60 days. No performance tests have been conducted since the previous inspection. 13 IV. 40 CFR Part 63, Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants from Reciprocating Internal Combustion Engines A. Applicability [40 CFR 63.6585] 40 CFR part 63, subpart ZZZZ applies to the following emission units: 1. Arrow engine identified as Emission Unit C-4 in Table 3 of this report; 2. Cummins engine identified as Emission Unit G-1 in Table 3 of this report. B. General Provisions [40 CFR 63.6665] 1. The General Provisions at 40 CFR part 63, subpart A apply as specified in Table 8 of 40 CFR part 63, subpart ZZZZ. Notwithstanding conditions in this permit, the Permittee shall comply with all applicable requirements of 40 CFR part 63, subpart A. Nothing to evaluate with this general condition 2. All reports required under 40 CFR part 63, subpart A shall be sent to the EPA at the following address as listed in 63.13: Director, Air and Toxics Technical Enforcement Program, 8ENF-AT Office of Enforcement, Compliance and Environmental Justice 1595 Wynkoop Street, Denver, CO 80202-1129 Nothing to evaluate with this general condition C. Requirements for Engine G-1 [40 CFR 63.6590(c)(4)] For engine G-1, the Permittee shall meet the requirements of 40 CFR part 63, subpart ZZZZ by meeting the requirements of 40 CFR part 60, subpart JJJJ, for stationary SI engines. No further requirements apply to emissions unit G-1 under 40 CFR part 63. The applicable requirements of 40 CFR part 60, subpart JJJJ are specified in Section II of this permit. For NSPS JJJJ compliance evaluation see section II of this report. D. Operating Limitations for Engine C-4 [40 CFR 63.6602] 1. Emissions from engine unit C-4 shall meet the following operating requirements according to Table 2c for non-emergency, non-black start stationary SI RICE less than 100 hp that are not 2SLB stationary RICE to 40 CFR part 63, subpart ZZZZ: (a) Change oil and filter every 1,440 hours of operation or annually, whichever comes first; 14 (b) Inspect spark plugs every 1,440 hours of operation or annually, and replace as necessary; and (c) Inspect all hoses and belts every 1,440 hours of operation or annually, whichever comes first, and replace as necessary. Following a record review, this engine operated for 566 hours in 2020, 504 hours in 2021 and 288 hours in 2022 and one maintenance activity has been conducted on 10/19/2020. It appears this engine isn't meeting the maintenance requirements. E. General Compliance for Engine C-4 [40 CFR 63.6605] 1. The Permittee shall be in compliance with the emission limitations, operating limitations and other requirements that apply at all times. 2. The Permittee shall operate and maintain any affected source, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. Nothing to evaluate with this general condition. F. Continuous Compliance Requirements for Engine C-4 [40 CFR 63.6640] The Permittee shall demonstrate continuous compliance with each emission limitation, operating limitation, work or management practice, or other requirements in Table 2c according to methods specified in Table 6 of MACT ZZZZ. Table 2c requires regular maintenance and is evaluated for compliance above in section IV.D. Table 6 requires the RICE to be operated and maintained according to the manufacturer's emission-related operation and maintenance instructions or to develop its own maintenance plan which must provide to the extent practicable for the maintenance and operation of the engine in a manner consistent with good air pollution control practice for minimizing emissions. According to the facility's engine maintenance plan, this engine has been operated and maintained according to manufacturer's instructions. G. Recordkeeping Requirements for Engine C-4 [40 CFR 63.6655, 63.6660] 1. The Permittee shall keep records as specified in 63.6655. 2. The Permittee shall keep the records in the format and for the duration as specified in 63.6660. The source provided all requested records. 15 V. Facility-Wide Requirements [40 CFR 71.6(a)(1)] Conditions in this section of this permit apply to all emissions units located at the source, including any units not specifically listed in Table 2 of the Facility Emission Points section of this permit. A. Recordkeeping Requirements [40 CFR 71.6(a)(3)(ii)] The Permittee shall comply with the following generally applicable recordkeeping requirements: 1. If the Permittee determines that his or her stationary source that emits (or has the potential to emit, without considering controls) one or more hazardous air pollutants (HAPs) is not subject to a relevant standard or other requirement established under 40 CFR part 63, the Permittee shall keep a record of the applicability determination on site at the source for a period of 5 years after the determination, or until the source changes its operations to become an affected source, whichever comes first. The record of the applicability determination shall include an analysis (or other information) that demonstrates why the Permittee believes the source is unaffected (e.g., because the source is an area source). [40 CFR 63.10(b)(3)] Nothing to evaluate with this general condition. 2. Records shall be kept of off permit changes, as required by the Off Permit Changes section of this permit. Nothing to evaluate with this general condition. B. Reporting Requirements [40 CFR 71.6(a)(3)(iii)] 1. The Permittee shall submit to the EPA all reports of any required monitoring under this permit semiannually. The first report shall cover the period from the effective date of this permit through December 31, 2018. Thereafter, the report shall be submitted semiannually, by April 1st and October 1st of each year. The report due on April 1st shall cover the 6-month period ending on the last day of December before the report is due. The report due on October 1st shall cover the 6-month period ending on the last day of June before the report is due. All instances of deviations from permit requirements shall be clearly identified in such reports. All required reports shall be certified by a responsible official consistent with the Submissions section of this permit. The source has submitted a semi-annual reports covering July 1-December 31, 2020 (submitted on 3/29/2021); January 1-June 30, 2021 (submitted on 8/10/2021); July 1-December 31, 2021 (submitted on 2/16/2022); January 1June 30, 2022 (submitted on 9/10/2022); July 1-December 31, 2022 (submitted on 3/29/2022). 2. "Deviation" means any situation in which an emissions unit fails to meet a permit term or 16 condition. A deviation is not always a violation. A deviation can be determined by observation or through review of data obtained from any testing, monitoring, or recordkeeping established in accordance with 71.6(a)(3)(i) and (a)(3)(ii). For a situation lasting more than 24 hours which constitutes a deviation, each 24-hour period is considered a separate deviation. Included in the meaning of deviation are any of the following: (a) A situation where emissions exceed an emission limitation or standard; (b) A situation where process or emissions control device parameter values indicate that an emission limitation or standard has not been met; or (c) A situation in which observations or data collected demonstrate noncompliance with an emission limitation or standard or any work practice or operating condition required by the permit. Nothing to evaluate with this general condition. 3. The Permittee shall promptly report to the EPA deviations from permit requirements, including those attributable to upset conditions as defined in this permit, the probable cause of such deviations, and any corrective actions or preventive measures taken. "Prompt" is defined as follows: (a) Any definition of "prompt" or a specific time frame for reporting deviations provided in an underlying applicable requirement as identified in this permit. (b) Where the underlying applicable requirement fails to address the time frame for reporting deviations, reports of deviations will be submitted based on the following schedule: (i) For emissions of a HAP or a toxic air pollutant (as identified in the applicable regulation) that continue for more than an hour in excess of permit requirements, the report shall be made within 24 hours of the occurrence. (ii) For emissions of any regulated air pollutant, excluding a HAP or a toxic air pollutant that continues for more than two (2) hours in excess of permit requirements, the report shall be made within 48 hours. (iii) For all other deviations from permit requirements, the report shall be submitted with the semi-annual monitoring report. (c) If any of the conditions in (i) or (ii) of paragraph (b) above are met, the Permittee shall notify the EPA by telephone (1-800-227-6312), facsimile (303-312-6409), or by email to r8airreportenforcement@epa.gov based on the timetables listed above. [Notification shall specify that this notification is a deviation report for a Part 71 permit]. A written notice, certified consistent with the Submissions section of this permit shall be submitted within ten working days of the occurrence. All deviations reported under this section shall also be identified in the 6-month report required under Condition 1 in this section of this permit. 17 No deviations were reported in any of the semi-annual reports. General Provisions A. Annual Fee Payment [40 CFR 71.9] The facility submitted the proper form FEE and payments per their Part 71 application for 2020-2022. 2020 fee - $163.80 2021 fee - $56.23 2022 fee - $112.46 B. Annual Emissions Inventory [40 CFR 71.9(h)(1) and (2)] 1. The Permittee shall submit an annual emissions report of its actual emissions for both criteria pollutants and regulated HAPs for this source for the preceding calendar year for fee assessment purposes. The annual emissions report shall be certified by a responsible official and shall be submitted each year to the EPA by April 1st. 2. The annual emissions report shall be submitted to the EPA at the address listed in the Submissions section of this permit. The facility submitted the emission inventory for 2020-2022. Reported Actual Emissions Actual Emission in Tons per Pollutant Year 2020 2021 2022 NOx 1.97 0.89 1.32 VOC 0.53 0.06 0.57 SO2 0.00 0.00 0.00 PM10 0.00 0.01 0.04 The 2020 and 2021 emissions inventory does not include any VOC emissions from TK-01 and TK-02. The 2022 emissions inventory includes 0.49 tons of VOC emissions from TK-01 and TK-02. The 2022 emissions are calculated using E&P Tank version 2.0 and assumes 0.83 bbl/day throughput and 10 hours per year operation. Based on the OGI observed venting from the uncontrolled tanks during these liquid dump events and how both tanks were full there is concern that these emissions were underestimated during 2022 and that these emissions were not included in 2020 and 2021 annual emissions inventory. 18 19 Appendix A: Satellite Imagery of Facility 20 Appendix B - Infrared Still Images from TK-1 and TK-2 Image 1 from MOV_3163.mp4 Image 2 from MOV_3163.mp4 21 Image 3 from MOV_3163.mp4 22 Region 8 Enforcement and Compliance Assurance Division INSPECTION REPORT Inspection Date: Time: Media: Statute(s)/Program(s): Type of inspection: 07/12/2022 Announced: Yes Entry: 09:00 AM (CT) Exit: 12:55 PM (CT) Water Clean Water Act, NPDES, Wastewater Treatment Facility (WWTF) CEI - Compliance Evaluation Inspection Permittee Name: Facility or Site Name: Facility/Site Physical Address: (City, state, zip code) Facility GPS Coordinates: Fort Yates Lagoon System Fort Yates Lagoon System P.O. Box 429 Fort Yates, North Dakota 58538 46.083889, -100.656306 Permit Number: Inspection Identification Number: SIC or NAICS: NDG589312 202207_NDG589312 221320 Sewage Treatment Facilities Persons Participating in Inspection: Name Affiliation Emilio Llamozas Stephanie Meyers Tyler Timmons Randez Bailey Leon Spotted Bull Wyatt Red Tomahawks Sr. Jake Luger EPA Region 8 EPA Region 8 Indian Health Service (IHS) Standing Rock Municipal, Rural & Industrial (MR&I) Program Standing Rock MR&I Program Standing Rock MR&I Program Standing Rock Sioux Tribe Environmental Program Title Lead Inspector Inspector Tribal Utility Consultant Rural Water System Director Present at Present at Opening Conf. Closing Conf. Yes Yes Yes Yes Yes Yes Yes Yes Wastewater Supervisor Yes Yes Wastewater Operator Yes Yes Acting Environmental Director Yes No 1 of 13 FORT YATES LAGOON SYSTEM Inspection Date(s): 07/12/2022 - 07/12/2022 Lead Inspector: Emilio Llamozas Region 8 llamozas.Emilio@epa.gov 8/5/2022 (303) 312-6407 Reviewer: Stephanie Meyers Region 8 Supervisor Review: Michael Boeglin Boeglin, Michael Digitally signed by Boeglin, Michael Date: 2022.08.09 06:25:07 -06'00' Region 8 meyers.stephanie@epa.gov 8/8/2022 (303) 312-6938 boeglin.michael@epa.gov 8/9/2022 (303) 312-6250 SECTION I - INTRODUCTION Site Entry and Inspection Objectives Region 8 Lead Inspectors, Emilio Llamozas and Stephanie Meyers, arrived at the Fort Yates Lagoon System (the "Site" or "Facility"), at 09:00 AM (CT) on 07/12/2022 for an announced inspection. The Inspectors presented their credentials to Randez Bailey, Leon Spotted Bull and Wyatt Red Tomahawk and informed them that this was a Region 8 inspection to determine compliance with the Clean Water Act (CWA) and the National Pollutant Discharge Elimination System (NPDES) permit program. The inspection was conducted under the authority of Section 308 of the CWA. The table above identifies the attendees that participated in the inspection. This report is based on information supplied by Fort Yates Lagoon System representatives, observations made by the Inspectors, and records and reports maintained by the permittee and the EPA Region 8 including: photographs taken by the inspectors; verbal or written statements made by Fort Yates Lagoon System representatives (the permittee) during, or subsequent to, the on-site Inspection; and materials, processes, data, photographs, or documents made available to the inspectors by the permittee during, or subsequent to, the onsite Inspection. In addition, information gathered from a review of USEPA, and public records may be included in this report. Facility/Site Description The City of Fort Yates wastewater collection system consists of four lift stations (Douglas Skye lift station, Burger Queen lift station, Sioux Village lift station, and the Standing Rock Community School lift station) a wastewater treatment facility with three cells, and a constructed wetland. It was constructed in 1960 and was updated in 1994 and 2008. The cells typically operate in series; the wastewater first goes to cell 1 (18.5 acres, 30.1 MG at 5 feet depth), it is then sent to cell 2 (13 acres, 21.2 MG at 5 feet depth), and then it goes to cell 3 (11 acres, 17.9 MG at 5 feet depth). The cell 1 inlet manhole has a splitter, which could bypass cell 1, and go to cell 2, if necessary (photo 57). Cell 1 has an emergency overflow to cell 3, which would bypass cell 2. Cell 3 can be discharged to the constructed wetland (12.5 acres, 8.1 MG at 2 feet depth). The constructed wetland has a valve on the southwest corner that could discharge (photo 62), if necessary. The facility is permitted as a no discharge facility, under the Lagoon General Permit for the Standing Rock Reservation. Any discharge from the facility is expected to be under emergency circumstances. They have not discharged from the lagoons in the last 2 of 13 FORT YATES LAGOON SYSTEM Inspection Date(s): 07/12/2022 - 07/12/2022 five years. The Notice of Intent (NOI) indicated that the receiving water for any discharge was the Missouri River. Currently, the lagoon system services the City of Fort Yates with approximately 2,000 people and several businesses (Hospital, dialysis treatment, one restaurant (Rand B tacos), small college, and a welding shop). Estimated flows from non-domestic industrial sources are 0.02 MGD. No industrial hauled waste is accepted at the facility. The facility accepts septic waste from two septic haulers (Standing Rock Propane and Randy Carlson from Mobridge, South Dakota). The septic haulers have keys to the lagoon. They haul septic waste from homes in the area in the spring and fall. MR&I provides training to the septic haulers on how to dispose of the septic at the lagoons (photo 54). MR&I has two wastewater operators. Leon Spotted Bull was wastewater certified, but needs to renew his certification. Wyatt Red Tomahawk is working on getting his wastewater certification. The facility manages four lift stations that are located at the following locations: Douglas Skye lift station (photo 51) - Lat: 46.09703 Long: -100.62935; Burger Queen lift station (photo 53) - Lat: 46.08830 Long: -100.63337; Standing Rock Community School lift station - Lat: 46.093181 Long: -100.673479; Sioux Village lift station (photo 65) - Lat: 46.089522 Long: -100.656943 MR&I maintains a log of lift station pump hours (photos 50, 52, 64 and 66). MR&I has a contract with Dakota Pump to maintain the lift station. Once a year, Dakota Pump removes the solids out of the bottom of the lift station. If a pump in the lift station goes down, MR&I calls Dakota Pump to haul the wastewater to the lagoon while the lift station is being fixed. Dakota Pump also performs maintenance at the lift station and makes sure the floats are working correctly. The facility representatives indicated that no sanitary sewer overflows (SSOs) have occurred at the lift stations. There are some spare pumps, but they don't work. If a pump breaks they will fix it. There is a small lift station at the Tribal Game and Fish Offices, which is maintained by Game and Fish. There is also a small lift station at the Sitting Bull College that is maintained by the college maintenance staff. Facility representatives indicated that they have a separate collection system between wastewater and stormwater. There has been no testing for inflow and infiltration in the last 5 years. Jetting operations of the wastewater collection system are performed in problem areas by the hospital, Sioux Village and by the prison to remove blockages in the collection system. MR&I has their own jetter. MR&I operators mow the lagoons on a rotating schedule. They had a log book that had very general information on what they do day-to-day (for example the date the lagoons were mowed). The Fort Yates Lagoon system was last mowed two weeks prior to the inspection. However, the tractor used to mow the berms of the lagoon broke down, so they have not mowed the berms of the lagoon. Cells 1, 2 and 3 had cattails and vegetation growing on the inside of the berms (photos 54-56 and 58-59). There are also several prairie dog burrows next to the lagoons (photos 56), which could cause issues with the integrity of the berms. MR&I is working on removing the prairie dogs. Facility/Site Information Responsible official WWTP Design Capacity & Average Daily Flow WWTP Approx. # of residents served Outfalls: (and do the numbers, locations, and receiving waters match the permit?) Randez Bailey 0.3 MGD, 562.5 pounds of BOD5 per day 2,000 people One outfall on the southwest corner of the constructed wetland (photo 62). No discharge lagoon. If there was an emergency discharge it would go to the Missouri River. 3 of 13 FORT YATES LAGOON SYSTEM Inspection Date(s): 07/12/2022 - 07/12/2022 Do you use in-house or contract out for laboratory analyses? (including for metals or WET testing?) Do you accept waste from septage haulers? If so, what problems have you experienced? Is there currently any portion of the treatment train that is non-operational? Are there any plans for renovation or additional equipment to allow for increased wastewater flow? No discharge lagoon so no analyses have been conducted. Yes from two septage haulers (Standing Rock Propane and Randy Carlson from Mobridge, South Dakota). The valve from cell 1 to cell 3 No plans for any upgrades SECTION II - OBSERVATIONS Following the opening conference, Mr. Spotted Bull and Mr. Red Tomahawk accompanied the Inspectors on a facility walkthrough of the four lift stations maintained by MR&I, the three lagoon cells and the constructed wetland. To document and record conversation and inspection observations, the inspectors took notes using the Smart Tools Software and bound checklists with questions applicable to the facility. Photographs taken during the inspection are included in the photo log. Inspectors took photos with a camera and with the Smart Tools Software via a tablet. Observations may not be in sequential order. Unit: Unassigned Observation #: EL1-OB-003 Contains CBI: No Date: 07/12/2022 There were prairie dog burrows on the berms of cells 1, 2 and 3 (photo 56). Unit: Unassigned Observation #: EL1-OB-002 Contains CBI: No Date: 07/12/2022 There was algae in cell 3. However, they were not planning to discharge this cell. Unit: Unassigned Observation #: EL1-OB-001 Contains CBI: No Date: 07/12/2022 Cells 1, 2 and 3 had cattails and vegetation growing on the inside of the berms (photos 54-56 and 58-59). SECTION III - RECORDS REVIEW Records may not be in sequential order. Record: Other - Lagoon weekly inspections Ref #: EL1-RR-002 Reviewed By: Emilio Llamozas AOC: Yes Reviewed Date: 07/12/2022 The lagoon weekly inspections were not documented. We provided the inspection template checklist that was in the Appendix to the Lagoon General permit. Record: Other - Lift Station Inspections Ref #: EL1-RR-001 Reviewed By: Emilio Llamozas AOC: No Reviewed Date: 07/12/2022 4 of 13 FORT YATES LAGOON SYSTEM Inspection Date(s): 07/12/2022 - 07/12/2022 They are documenting the lift station pump hours. They had operation and maintenance manuals for each of the lift stations at Fort Yates. SECTION IV - FINDINGS, CORRECTIVE ACTIONS AND RECOMMENDATIONS Unit: EL1-OB-001 Area: Cells 1, 2 and 3 Sub-area: Finding #1: There were cattails and vegetation growing on the inside berms of cells 1, 2 and 3. Cells 1, 2 and 3 had cattails and vegetation growing on the inside of the berms (photos 54-56 and 58-59). Permit Requirement: Part 6.5 of the Permit states, "Proper Operation and Maintenance. The permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the permittee to achieve compliance with the conditions of this permit. Proper operation and maintenance also includes adequate laboratory controls and appropriate quality assurance procedures. This provision requires the operation of back-up or auxiliary facilities or similar systems which are installed by a permittee only when the operation is necessary to achieve compliance with the conditions of the permit. However, the permittee shall operate, at a minimum, one complete set of each main line unit treatment process whether or not this process is needed to achieve permit effluent compliance. In addition to the operation and maintenance items in the manual for the lagoon system, the permittee shall do the following maintenance: 6.5.1. Take necessary action to promptly correct the problem of leakage through the dikes; 6.5.2. Take necessary action to promptly remove burrowing animals from the dikes; 6.5.3. Promptly repair damage to dikes caused by burrowing animals and/or erosion; 6.5.4. Remove rooted plants, including weeds, from the water on a regular basis or as needed; and 6.5.5. Keep the dikes mowed on a regular basis during the growing season or as needed (e.g., keep growth below 6" in height)." Corrective Action: Remove the overgrown vegetation and cattails growing on the inside berms of cells 1, 2 and 3. Submit to the EPA, the Standing Rock Sioux Tribe Environmental Program (Tribe) and IHS photos of the cells after the vegetation and cattails have been removed. EL1-OB-003 Cells 1, 2 and 3 Finding #2: There were animal burrows on the berms of cells 1, 2 and 3. There were prairie dog burrows on the berms of cells 1, 2 and 3 (photo 56). Permit Requirement: Part 6.5 of the Permit states, "Proper Operation and Maintenance. The permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the permittee to achieve compliance with the conditions of this permit. Proper operation and maintenance also includes adequate laboratory controls and appropriate quality assurance procedures. This provision requires the operation of back-up or auxiliary facilities or similar systems which are installed by a permittee only when the operation is necessary to achieve compliance with the conditions of the permit. However, the permittee shall operate, at a minimum, one complete set of each main line unit treatment process whether or not this process is needed to achieve permit effluent compliance. In addition to the 5 of 13 FORT YATES LAGOON SYSTEM Inspection Date(s): 07/12/2022 - 07/12/2022 operation and maintenance items in the manual for the lagoon system, the permittee shall do the following maintenance: 6.5.1. Take necessary action to promptly correct the problem of leakage through the dikes; 6.5.2. Take necessary action to promptly remove burrowing animals from the dikes; 6.5.3. Promptly repair damage to dikes caused by burrowing animals and/or erosion; 6.5.4. Remove rooted plants, including weeds, from the water on a regular basis or as needed; and 6.5.5. Keep the dikes mowed on a regular basis during the growing season or as needed (e.g., keep growth below 6" in height)." Corrective Action: Remove burrowing animals from the berms and repair damage to berms caused by burrowing animals. Submit to the EPA, the Tribe and IHS photos of the cells after repairing damage to berms caused by burrowing animals. EL1-RR-002 Finding #3: Weekly lagoon inspections were not being conducted. Weekly lagoon inspections were not being conducted. The inspectors provided the facility representatives with a lagoon inspection report template form that the facility representatives could use to document the weekly lagoon inspections. Permit requirement: Part 4.3.1 of the Permit states, "On at least a weekly basis, unless otherwise modified by written approval from the EPA, the permittee shall inspect its wastewater treatment facility. The permittee shall maintain a notebook recording all information obtained during the inspection. At a minimum, the notebook shall include the following: 4.3.1.1. Name of facility and permit number; 4.3.1.2. Date and time of the inspection; 4.3.1.3. Name of the inspector(s); 4.3.1.4. The facility's discharge status; 4.3.1.5. The flow rate of the discharge if occurring; 4.3.1.6. If a discharge is occurring, has occurred since the previous inspection, and/or if a discharge is likely to occur before the next inspection. (Note: If a discharge has occurred or is likely to occur before the next inspection, perform the appropriate monitoring and reporting requirements in Parts 3.2 and 5.4 of this permit if not already done.); 4.3.1.7. Is there is any leakage through the dikes; 4.3.1.8. Are there are any animal burrows in the dike; 4.3.1.9. Is there any erosion of the dikes (e.g., rills, cracks or other structural indications of erosion); 4.3.1.10. Are there are any rooted plants, including weeds growing in the water; 4.3.1.11. Does the vegetation growth on the dikes needs mowing (e.g. greater than 6" tall); 4.3.1.12. List the date scheduled for operation and maintenance procedures to be undertaken at the wastewater treatment facility. 4.3.1.13. Identification of operational problems and/or maintenance problems; 4.3.1.14. Recommendations, as appropriate, to remedy identified problems; 4.3.1.15. A brief description of any actions taken with regard to problems identified; and, 4.3.1.16. Other information, as appropriate. The permittee shall maintain the notebook in accordance with required record-keeping items listed above and shall make the log available for inspection, upon request, by authorized representatives of the U.S. Environmental Protection Agency or the applicable Tribe (see Part 5.10 of this permit)." Part 5.7 of the Permit states, "The permittee shall retain records of all monitoring information, including all calibration and maintenance records and all original strip chart recordings for continuous monitoring 6 of 13 FORT YATES LAGOON SYSTEM Inspection Date(s): 07/12/2022 - 07/12/2022 instrumentation, copies of all reports required by this permit, and records of all data used to complete the application for this permit, inspection records, notifications to the EPA per this permit, and DMRs, for a period of at least five years from the date of the sample, measurement, report, application or submittal. Records of monitoring required by this permit related to sludge use and disposal activities must be kept at least five years (or longer as required by 40 C.F.R. Part 503). This period may be extended by request of the Director at any time. Data collected on site, data used to prepare the DMR, copies of DMRs, a copy of this NPDES permit, and the notice of intent for permit coverage, must be maintained on site." Corrective Action: Ensure that inspections are conducted on a weekly basis and documented in accordance with the permit. Ensure that inspection reports are kept in accordance with the recordkeeping requirements of the permit. Provide the EPA, the Tribe and IHS with a description of the corrective actions taken to address this finding. Finding #4: The valve to transfer wastewater from cell 1 to cell 3 was not working. The valve to transfer wastewater from cell 1 to cell 3 is not working. Permit requirements: Part 6.5 of the Permit states, "The permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the permittee to achieve compliance with the conditions of this permit. Proper operation and maintenance also includes adequate laboratory controls and appropriate quality assurance procedures. This provision requires the operation of back-up or auxiliary facilities or similar systems which are installed by a permittee only when the operation is necessary to achieve compliance with the conditions of the permit. However, the permittee shall operate, at a minimum, one complete set of each main line unit treatment process whether or not this process is needed to achieve permit effluent compliance." Corrective Action: Repair the valve from cell 1 to cell 3. Properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) including the valves, which are installed or used by the permittee to achieve compliance with the conditions of the permit. Provide the EPA, the Tribe and IHS with photos and a description of the corrective actions taken to address this finding. SECTION V - CLOSING CONFERENCE AND FOLLOW UP Closing Conference At the end of the day on July 13, 2022, on the second day of the MR&I inspections the Inspectors returned to the MR&I main office and held a closing conference with Ms. Bailey, Mr. Spotted Bull and Mr. Red Tomahawk where preliminary findings were discussed. On July 22, 2022, the EPA sent an email to Ms. Bailey with the preliminary findings from the inspection. 7 of 13 FORT YATES LAGOON SYSTEM Inspection Date(s): APPENDIX 1: PHOTOLOG Photo 50 IMG-202207121050575057188519.jpg 07/12/2022 11:50 AM (CT) Photographer: Emilio Llamozas Douglas Skye Lift station pump hours log. Photo 51 IMG-202207121054075471423151.jpg 07/12/2022 11:54 AM (CT) Photographer: Emilio Llamozas Overview of Douglas Skye lift station. Photo is facing west. Photo 52 IMG-20220712110010010760481.jpg 07/12/2022 12:00 AM (CT) Photographer: Emilio Llamozas Burger Queen lift station pump hours logs. 8 of 13 07/12/2022 - 07/12/2022 FORT YATES LAGOON SYSTEM Inspection Date(s): Photo 53 IMG-202207121102152151419517.jpg 07/12/2022 12:02 AM (CT) Photographer: Emilio Llamozas Overview of Burger Queen Lift Station. Photo is facing Southwest. Photo 54 IMG-2022071211102210222865548.jpg 07/12/2022 12:10 AM (CT) Photographer: Emilio Llamozas Overview of cell 1 with septage dumping station in the foreground. Photo is facing Southwest. Photo 55 IMG-2022071211105710572921821.jpg 07/12/2022 12:10 AM (CT) Photographer: Emilio Llamozas North berm of cell 1 with cattails growing on the berms. Photo is facing West. 07/12/2022 - 07/12/2022 9 of 13 FORT YATES LAGOON SYSTEM Inspection Date(s): Photo 56 RIMG0056.JPG 07/18/2022 12:16 PM (CT) Photographer: Emilio Llamozas Overview of cell 1. Animal burrow along the cell berm and cattails growing inside of cell 1. Photo is facing Northeast. Photo 57 RIMG0057.JPG 08/04/2022 12:18 PM (CT) Photographer: Emilio Llamozas Inside view of manhole where wastewater can be diverted to cell 1 or cell 2. Photo 58 RIMG0058.JPG 07/18/2022 12:18 PM (CT) Photographer: Emilio Llamozas Overview of cell 2. Cattails and vegetation growing around cell 2. Photo is facing Southwest. 07/12/2022 - 07/12/2022 10 of 13 FORT YATES LAGOON SYSTEM Inspection Date(s): Photo 59 RIMG0059.JPG 07/18/2022 12:22 PM (CT) Photographer: Emilio Llamozas Overview of cell 3. Cattails and vegetation growing around cell 3. There was also algae growing in cell 3. Photo is facing Northwest. Photo 60 RIMG0060.JPG 08/04/2022 12:28 PM (CT) Photographer: Emilio Llamozas Overview of the wetland cell. Photo is facing North. Photo 61 RIMG0061.JPG 07/18/2022 12:29 PM (CT) Photographer: Emilio Llamozas Overview of the wetland cell discharge pipe from cell 3. Photo is facing North. 07/12/2022 - 07/12/2022 11 of 13 FORT YATES LAGOON SYSTEM Inspection Date(s): Photo 62 RIMG0062.JPG 08/04/2022 12:32 PM (CT) Photographer: Emilio Llamozas Outfall from the wetland cell. Photo is facing West. Photo 63 RIMG0063.JPG 07/18/2022 12:32 PM (CT) Photographer: Emilio Llamozas Outfall pipe from the wetland cell. The facility was not discharging at the time of the inspection. Photo is facing South. Photo 64 RIMG0064.JPG 08/04/2022 12:41 PM (CT) Photographer: Emilio Llamozas Lift station log from the Sioux Village lift station. 07/12/2022 - 07/12/2022 12 of 13 FORT YATES LAGOON SYSTEM Inspection Date(s): Photo 65 RIMG0065.JPG 08/04/2022 12:44 PM (CT) Photographer: Emilio Llamozas Overview of Sioux Village lift station. Photo is facing South. Photo 66 RIMG0066.JPG 08/04/2022 12:49 PM (CT) Photographer: Emilio Llamozas Lift station log from the Standing Rock Community School lift station. 07/12/2022 - 07/12/2022 13 of 13