Document B3MBqYMLDEjjjd7xGvnBQYej

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 12/11/2024 Water (CWA) Water (CWA) Brine Program (Oil & Gas inspection) Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: Merit Energy Company, LLC Denman 2-13, Denman 3-13, and Denman-Wright Humphries 1-13 Tank Battery In Alma from Highway 64 E, then Sharp Chapel Rd, then Red Hill Rd, continue onto Denman Rd, off a gas lease road at 35.454526, -94.145652. Alma, AR, 72921 13727 Noel Road, Ste. 1200 Dallas, TX 75240 Crawford County 972-628-1559 Clay Munger (501-368-4704) Person Responsible for Operation chris.heavner@meritenergy.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: N/A ARU002267 N/A 211111 1311 Personnel participating in inspection: Kerri McCabe (lead) EPA / Region 6 ECDW Michael Blaha EPA / Region 6 ECDW Uma Lad EPA / Region 6 ECDW Inspector / Enforcement Officer Inspector / Enforcement Officer Inspector / Enforcement Officer EPA Lead Inspector Signature/Date Supervisor Signature/Date KERRI MCCABE Kerri McCabe Digitally signed by KERRI MCCABE Date: 2025.01.07 11:20:34 -06'00' Date JEANNE ECKHART Date: 2025.01.10 08:09:35 -06'00' Digitally signed by JEANNE ECKHART Jeanne Eckhart Date 6ENFORM-019-R8.2 (02/12/2020) 1 Merit Energy Company, LLC / Denman 2-13, Denman 3-13, and Denman-Wright Humphries 1-13 Tank Battery (ARU002267 / CWA) Inspection Date 12/11/2024 Section I - INTRODUCTION PURPOSE OF THE INSPECTION EPA Region 6 inspectors Kerri McCabe (lead), Michael Blaha, and Uma Lad arrived at the Merit Energy Company, LLC / Denman 2-13, Denman 3-13, and Denman-Wright Humphries 1-13 Tank Battery ("facility") at 0825 on 12/11/2024 for an unannounced inspection. The facility is located from Highway 64 E, then Sharp Chapel Rd, then Red Hill Rd, continue onto Denman Rd, off a gas lease road at 35.454526, -94.145652. No facility representatives were present at the time of the inspection. The inspection was conducted by the authority of the Clean Water Act (CWA) to determine compliance with Environmental Protection Agency (EPA) regulations. There were no other federal, state, or local agency representatives present at the time of the inspection. FACILITY DESCRIPTION EPA conducted an inspection on the Merit Energy Company, LLC / Denman 2-13, Denman 3-13, and Denman-Wright Humphries 1-13 Tank Battery, which contained three (3) storage tanks for produced water, one (1) storage tank for additives, four (4) separators, one (1) compressor, and three (3) natural gas (dry) wells, which were producing at the time of the inspection. Map 1. Aerial imagery (Google Earth dated 08/24/2024) of the Merit Energy Company, LLC / Denman 213, Denman 3-13, and Denman-Wright Humphries 1-13 Tank Battery. 2 Merit Energy Company, LLC / Denman 2-13, Denman 3-13, and Denman-Wright Humphries 1-13 Tank Battery (ARU002267 / CWA) Inspection Date 12/11/2024 Section II - OBSERVATIONS I observed the Merit Energy Company, LLC / Denman 2-13, Denman 3-13, and Denman-Wright Humphries 1-13 Tank Battery facility and associated signage and secondary containment with storage tanks; see Appendix 1 (Photograph Log), Photo No. 1 through No. 4. For additional GPS location and photo metadata, see Appendix 1. I observed one large fiberglass storage tank within secondary containment, see Photo No. 5. I observed the four 2-phase gas-water separators onsite, see Photo No. 6 and No. 10. I observed three more storage tanks for produced water and additives, see Photo No. 7. I observed holes in the secondary containment structure and holes/tears in the liner for secondary containment for the tanks referenced above, see Photo No. 8 and No. 9. I observed the compressor onsite, see Photo No. 11. Section III - AREAS OF CONCERN No closing conference was held due to no personnel with Merit Energy Company, LLC being present during the inspection. Areas of concern at the time of the inspection include the following: Holes in secondary containment structures and holes/tears in the synthetic liner for secondary containment. Section IV - FOLLOW UP Inspector will conduct follow-up phone calls and emails with the company representative(s) over the coming weeks and months to ensure areas of concern are properly addressed. Section V - LIST OF APPENDICES Appendix 1 - Photograph Log - 11 photos taken 12/11/2024. 3 Merit Energy Company, LLC / Denman 2-13, Denman 3-13, and Denman-Wright Humphries 1-13 Tank Battery (ARU002267 / CWA) Inspection Date 12/11/2024 Appendix 1 Photograph Log 11 Photos UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: Alma from Highway 64 E, then Sharp Chapel Rd, then Red Hill Rd, continue onto Denman Rd, off a gas lease road at 35.454526, -94.145652. City: Alma County/Parish: Crawford State: AR Photo File Name: 100-0395 Orientation: 10 N Date of Photo: 12/11/2024 Time of Photo: 0835 Latitude: 35.454633 Longitude: -94.145700 Photographer: Kerri McCabe Description: Looking N, this photo shows the first of three signs at the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: Alma from Highway 64 E, then Sharp Chapel Rd, then Red Hill Rd, continue onto Denman Rd, off a gas lease road at 35.454526, -94.145652. City: Alma County/Parish: Crawford State: AR Photo File Name: 100-0396 Orientation: 7 N Date of Photo: 12/11/2024 Time of Photo: 0835 Latitude: 35.454550 Longitude: -94.145750 Photographer: Kerri McCabe Description: Looking N, this photo shows the second of three signs at the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: Alma from Highway 64 E, then Sharp Chapel Rd, then Red Hill Rd, continue onto Denman Rd, off a gas lease road at 35.454526, -94.145652. City: Alma County/Parish: Crawford State: AR Photo File Name: 100-0397 Orientation: 32 NNE Date of Photo: 12/11/2024 Time of Photo: 0835 Latitude: 35.454506 Longitude: -94.145794 Photographer: Kerri McCabe Description: Looking NNE, this photo shows the third of three signs at the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: Alma from Highway 64 E, then Sharp Chapel Rd, then Red Hill Rd, continue onto Denman Rd, off a gas lease road at 35.454526, -94.145652. City: Alma County/Parish: Crawford State: AR Photo File Name: 100-0398 Orientation: 206 SSW Date of Photo: 12/11/2024 Time of Photo: 0836 Latitude: 35.454733 Longitude: -94.145267 Photographer: Kerri McCabe Description: Looking SSW, this photo shows an overview of the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: Alma from Highway 64 E, then Sharp Chapel Rd, then Red Hill Rd, continue onto Denman Rd, off a gas lease road at 35.454526, -94.145652. City: Alma County/Parish: Crawford State: AR Photo File Name: 100-0399 Orientation: 306 NW Date of Photo: 12/11/2024 Time of Photo: 0836 Latitude: 35.454650 Longitude: -94.145400 Photographer: Kerri McCabe Description: Looking NW, this photo shows a large fiberglass storage tank for produced water inside secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: Alma from Highway 64 E, then Sharp Chapel Rd, then Red Hill Rd, continue onto Denman Rd, off a gas lease road at 35.454526, -94.145652. City: Alma County/Parish: Crawford State: AR Photo File Name: 100-0400 Orientation: 55 NE Date of Photo: 12/11/2024 Time of Photo: 0837 Latitude: 35.454633 Longitude: -94.145633 Photographer: Kerri McCabe Description: Looking NE, this photo shows three of four 2-phase separators located at the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: Alma from Highway 64 E, then Sharp Chapel Rd, then Red Hill Rd, continue onto Denman Rd, off a gas lease road at 35.454526, -94.145652. City: Alma County/Parish: Crawford State: AR Photo File Name: 100-0401 Orientation: 259 W Date of Photo: 12/11/2024 Time of Photo: 0837 Latitude: 35.454333 Longitude: -94.145867 Photographer: Kerri McCabe Description: Looking W, this photo shows two additional secondary containment structures with three storage tanks. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: Alma from Highway 64 E, then Sharp Chapel Rd, then Red Hill Rd, continue onto Denman Rd, off a gas lease road at 35.454526, -94.145652. City: Alma County/Parish: Crawford State: AR Photo File Name: 100-0402 Orientation: 17 NNE Date of Photo: 12/11/2024 Time of Photo: 0838 Latitude: 35.454333 Longitude: -94.145933 Photographer: Kerri McCabe Description: Looking NNE, this photo shows holes in the smaller secondary containment structure from Photo No. 7. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 Location: Alma from Highway 64 E, then Sharp Chapel Rd, then Red Hill Rd, continue onto Denman Rd, off a gas lease road at 35.454526, -94.145652. City: Alma County/Parish: Crawford State: AR Photo File Name: 100-0403 Orientation: 77 ENE Date of Photo: 12/11/2024 Time of Photo: 0838 Latitude: 35.454350 Longitude: -94.146033 Photographer: Kerri McCabe Description: Looking ENE, this photo shows a hole in the synthetic liner for the larger secondary containment structure from Photo No. 7. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 10 Location: Alma from Highway 64 E, then Sharp Chapel Rd, then Red Hill Rd, continue onto Denman Rd, off a gas lease road at 35.454526, -94.145652. City: Alma County/Parish: Crawford State: AR Photo File Name: 100-0404 Orientation: 209 SSW Date of Photo: 12/11/2024 Time of Photo: 0838 Latitude: 35.454300 Longitude: -94.145900 Photographer: Kerri McCabe Description: Looking SSW, this photo shows the fourth of the four 2-phase separators located at the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 11 Location: Alma from Highway 64 E, then Sharp Chapel Rd, then Red Hill Rd, continue onto Denman Rd, off a gas lease road at 35.454526, -94.145652. City: Alma County/Parish: Crawford State: AR Photo File Name: 100-0405 Orientation: 151 SSE Date of Photo: 12/11/2024 Time of Photo: 0839 Latitude: 35.454433 Longitude: -94.145783 Photographer: Kerri McCabe Description: Looking SSE, this photo shows the compressor located at the facility.