Document EqBQ1b8DJXkEkONJV9zK5vX5g

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 SUBJECT: FROM: THRU: TO: CLEAN AIR ACT INSPECTION REPORT Pin Oak Energy Partners (Pin Oak) - Spencer Well Pad, Spencer, Ohio Veronica Fischer, Environmental Engineer AECAB (MI/WI) Sarah Marshall, Section Supervisor AECAB (MI/WI) File BASIC INFORMATION Facility Name: Pin Oak Energy Partners (Pin Oak) - Spencer Well Pad Facility Location: 39.922159, -81.625839 (Spencer, Ohio) Date of Inspection: August 30, 2022 EPA Inspector(s): 1. Veronica Fischer, Environmental Engineer 2. Constantinos Loukeris, Environmental Engineer Other Attendees: 1. Leslie Gearhart, Pin Oak, Regulatory Compliance Manager 2. Joseph Baker, Pin Oak, Technician 3. Jake L., Pin Oak, Technician Contact Email Address: Leslie.Gearhart@pinoakep.com Purpose of Inspection: To assess compliance with requirements of New Source Performance Standards (NSPS) Subparts OOOO and OOOOa and facility permit to install and operate (PTIO) Facility Type: oil and natural gas well pad Regulations Central to Inspection: NSPS Subparts OOOO and OOOOa Arrival Time: 1:40 PM EST Appendices Page 1 of 3 Departure Time: 1:55 PM EST Inspection Type: Unannounced Inspection Announced Inspection OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Small Business Resource Information Sheet not provided. Reason: Not a small business. Provided CBI warning to facility The following information was obtained verbally from facility personnel unless otherwise noted. Process Description: Pin Oak personnel indicated that it purchased all the Ohio well pads approximately two years ago (2020). The Spencer well pad was originally owned by EPG and started up in the 2012 - 2013 timeframe. At the well pad, an oil/gas/water emulsion is extracted from the formation through wells on-site. The emulsion from each well goes to a separator, from which the gas is sent to the sales line and the oil and water are piped to separate atmospheric pressure, fixed-roof tanks on-site. The vapors from the tank headspaces are piped together and to one atmospheric stack. Each tank has a "thief" hatch on top for gaining access to the liquid when necessary. The thief hatches are set to relieve pressure should the pressure due to flashing, working, or breathing emissions from the liquids contained within the tanks get too high for the piping of the vapor capture system and combustor to accommodate. In addition to the thief hatch, each tank has a pressure relief valve that vents to atmosphere upon release. Staff Interview: The Spencer well pad has one well and four tanks. TOUR INFORMATION EPA Tour of the Facility: Yes Data Collected and Observations: We climbed the tank battery and viewed the thief hatches and pressure relief devices with a FLIR GF320 camera (FLIR camera). Pin Oak indicated that the pneumatic controllers are low bleed. When Pin Oak purchased this well pad, a vapor recovery compressor was on the well pad but not in use. This compressor has not been decommissioned. Photos and/or Videos: were not taken during the inspection. Field Measurements: were not taken during this inspection. Appendices Page 2 of 3 CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: We requested the following documents, and summarized via e-mail on October 20, 2022: Permits for each well pad inspected; Past two years of annual optical gas imaging survey results conducted by Pin Oak; Past two years of monthly visuals conducted by Pin Oak; Replacements of seals associated with past two years of inspections by Pin Oak; Potential-to-emit calculations for each of the well pads inspected and any updated calculations (if applicable); Tank levels at the time of our inspection for each tank and each well pad inspected; Tank contents by tank number; Well pad names and identification numbers, and include which wells were active during our inspection; Pressure setpoints for each thief hatch and pressure relief valve by tank and well pad; Any repairs made as a result of our inspection. DIGITAL SIGNATURES VERONICA Digitally signed by VERONICA FISCHER FISCHER Date: 2022.10.26 09:20:06 -05'00' Report Author: _________________________________ Section Supervisor: SARAH Digitally signed by SARAH MARSHALL MARSHALL Date: 2022.10.26 10:40:46 -05'00' __________________________________ Appendices Page 3 of 3