Document Kjae133mpQ017ee7z6VqBYeQ
XTO Energy, Inc. - Various Well Pads and Facilities Located on Tribal Lands
Partial Compliance Evaluation (PCE) On-Site Clean Air Act (CAA) Inspections
Inspection Date(s):
October 23 and 24, 2024
Inspection Report Date:
December 27, 2024
EPA Representatives:
Katelyn Bergl, US EPA Region 8, Clean Air Act Inspector Youn Joo Kim, US EPA Region 8, Clean Air Act Inspector Taylor Waanders, US EPA, Clean Air Act Inspector
Tribal Representatives:
Dwight Bruce, MHA Energy
Company Representatives: None
Inspection Report Prepared By:
Katelyn Bergl, US EPA Region 8, Clean Air Act Inspector Youn Joo Kim, US EPA Region 8, Clean Air Act Inspector
Inspection Report Reviewed By:
Scott Patefield, Manager, Enforcement and Compliance Assurance Division, Air and Toxics Enforcement Branch
SCOTT PATEFIELD Date: 2024.12.27 15:52:05 -07'00' Digitally signed by SCOTT PATEFIELD
Applicable Rules:
40 C.F.R Part 49, Subpart K - Federal Implementation Plan for Oil and Natural Gas Well Production Facilities; Fort Berthold Indian Reservation (Mandan, Hidatsa and Arikara Nation), North Dakota (Fort Berthold FIP)
40 C.F.R. Part 60, Subpart OOOO - Standards of Performance for Crude Oil and Natural Gas Facilities for Which Construction, Modification, or Reconstruction Commenced After August 23, 2011, and on or Before September 18, 2015
40 C.F.R Part 60, Subpart OOOOa - Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification or Reconstruction Commenced After September 18, 2015 (NSPS OOOOa)
40 C.F.R Part 60, Subpart OOOOb - Standards of Performance for Crude Oil and Natural Gas Facilities for Which Construction, Modification or Reconstruction Commenced After December 6, 2022 (NSPS OOOOb)
Compliance Assistance None
Enforcement History XTO Energy, Inc. (XTO) was issued a Notice of Violation (NOV) on August 28, 2024, under Docket Number CAA-08-2024-0015.
Areas of Concern 1. The EPA detected hydrocarbon emissions from the storage tanks co-located with the following well pads: x FBIR Stephen 31X-9 x FBIR Walker 34X-25
2. The EPA detected unburned hydrocarbon (UBHC) emissions from an operating utility flare at the following well pad: x FBIR Bird 21X-19A
See Table 1 below for more details regarding inspected locations and Tables 2 and 3 for inspection observation details for all pads. A log of images and videos captured during the inspections is provided in Appendix A.
General Inspection Information Unannounced well pad inspections were conducted jointly by U.S. EPA and Fort Berthold Indian Reservation (FBIR) Tribal inspectors on October 23, and 24, 2024, at multiple XTO facilities located on the FBIR. XTO is a wholly-owned subsidiary of Exxon Mobil that operates under the XTO Energy name.
The EPA inspectors evaluated each well site listed in Table 1 using audio, visual, and olfactory (AVO) inspection methods including the use of an optical gas imaging (OGI) camera and EPA Reference Method 22. At each facility, inspectors scanned the crude and/or water storage tanks, closed vent system and flares onsite for any detectable emissions. Specifically, inspectors scanned storage tank covers and closed vent systems for hydrocarbon emissions to determine compliance with the Clean Air Act, including the Fort Berthold FIP and NSPS regulations.
Each well pad inspection followed the approach below: Page 2 of 8
1. Record the entry sign of the well pad when available. Survey the entire well pad with OGI camera.
2. Record the number and type of site process equipment such as well heads, tanks, and emission control devices.
3. Record AVO indications of emissions from the storage tanks, closed vent system to the control devices and control devices.
4. Using the OGI camera, survey each process in infrared modes (auto, manual, and/or high-sensitivity modes). Record any uncontrolled emissions with the OGI camera and describe the frequency and magnitude of emissions in the field notebook.
5. Observe control devices (enclosed combustor or utility flare) for visible emissions. If there is visible emissions present, conduct Method 22 and record the observations.
6. Using another OGI camera, if available, confirm any observations of uncontrolled emissions with another inspector.
7. If there are operators present onsite, share any Areas of Concern.
Table 1 lists general inspection and well pad details for each inspected well pad. The well pad information located in Table 1 is from the North Dakota Industrial Commission (NDIC) well index located online at https://www.dmr.nd.gov/oilgas/.
Table 1: Inspection and Facility Details of Facilities Inspected
Arrival Departure
API
Date
Time Time
Well Pad Name Number Latitude
10/23/2024 10:44 10:49
FBIR
3302501341 47.705035
Blackmedicine 3302503068
24X-21A Pad
3302503069
3302503070
3302503071
3302503072
3302503073
3302503074
3302503076
3302503107
3302503148
10/23/2024 12:23 12:33
FBIR Stephen
3302501197 47.716519
31X-9
3302501198
3302501872
3302501873
3302501874
3302501875
3302501876
3302501919
10/23/2024 12:36 12:46
FBIR Bird 21X- 3302503637 47.717218
19A
3302503638
3302503639
3302503640
3302503641
Page 3 of 8
Longitude -102.33685
102.37429 -102.37586
10/23/2024 12:53 12:59
10/23/2024 13:02 13:20 10/23/2024 13:35 13:41
10/24/2024 8:10
8:17
10/24/2024 8:20
8:24
10/24/2024 8:31
8:37
FBIR Walker 34X-25
FBIR Walker 31X-36D FBIR Lawrence 24X-26A
FBIR Ironwoman 21X-10
FBIR Yellowwolf 31X-10C
FBIR Youngbear 31X-9A
3302503642 3302503643 3302503644 3302501142 3302501143 3302501820 3302501821 3302501822 3302503740 3302503741 3302503742 3302503743 3302503353 3302503354 3302503390 3302503391 3302503399 3302501250 3302502360 3302503876 3302503877 3302503878 3302503879 3302503880 3302503881 3302501219 3302501220 3302501882 3302501883 3302501884 3302501885 3302501886 3302501887 3302503493 3302503494 3302503433 3302503434 3302503435 3302503456 3302503457 3302503458 3302503459 3302501248 3302502136 3302502137 3302502138 3302503511 3302503512 3302503513
47.688776 47.687643 47.689433 47.659883
47.659644 47.6592
-102.39458 -102.39305 -102.41931 -102.38812
-102.3843 -102.40756
Page 4 of 8
3302503514 3302503515
Observations and Regulatory Applicability Fort Berthold FIP, NSPS OOOO, NSPS OOOOa, and NSPS OOOOb regulations which are potentially relevant to the Areas of Concern observed during inspections are summarized in this section.
Tables 2 and 3 at the end of this report summarize inspection observations and findings. Table 2 summarizes storage tank observations. Table 3 includes details of control devices and related observations. See Appendix A for a log of images and videos taken during the inspections.
Fort Berthold FIP Applicability Based on drilling information reported to the NDIC well index by XTO, the facilities listed in Table 1 were completed after the August 12, 2007, applicability date (per 40 C.F.R. 49.4161) and are producing from the Bakken Pool (per 40 C.F.R 49.4163(a)(1)) and are thus subject to the Fort Berthold FIP.
Closed Vent System Equipment Requirements [ 49.4165(b)] Per 49.4165(b)(1), "Each closed-vent system must route all produced natural gas and natural gas emissions from production and storage operations to the natural gas sales pipeline or the control devices...". The EPA, using an OGI camera, detected natural gas emissions from production and storage tanks at the FBIR Stephen 31X-9 and FBIR Walker 34X-25 Pads. See Area of Concern #1 above.
Utility Flare Requirements [ 49.4165(c)] Per 49.4165(c)(1), "For each enclosed combustor or utility flare, the owner or operator must follow the manufacturer's written operating instructions, procedures and maintenance schedule to ensure good air pollution control practices for minimizing emissions." The EPA noted UBHC emissions indicating poor air pollution control practices from a lit flare at the FBIR Bird 21X-19A Pad. See Area of Concern #2 above.
NSPS OOOO Applicability Based on well production information reported by XTO to the NDIC and the date of construction, reconstruction, or modification of the storage vessels, the EPA believes that storage vessels and associated emissions control equipment at the FBIR Stephen 31X-9 Pad are potentially subject to requirements for storage vessel affected facilities in NSPS OOOO.
Closed Vent System Equipment Requirements [ 60.5411(c)(1)] Per 60.5411(c)(1), owners and operators must "design the closed vent system to route all gases, vapors, and fumes emitted from the material in the storage vessel to a control device that meets the requirements specified in 60.5412(c) and (d), or to a process." The EPA, using an OGI camera, observed emissions from the closed vent system at the FBIR Stephen 31X-9 Pad. See Area of Concern #1 above.
Page 5 of 8
NSPS OOOOa Applicability Based on XTO's NSPS OOOOa annual reporting, the EPA believes that storage vessels and associated emissions control equipment at the FBIR Walker 34X-25 Pad are potentially subject to requirements for storage vessel affected facilities in NSPS OOOOa.
Closed Vent System Equipment Requirements [ 60.5411a(c)] Per 60.5411a(c)(1), owners and operators must "Design the closed vent system to route all gases, vapors, and fumes emitted from the material in the storage vessel to a control device that meets the requirements specified in 60.5412a(c) and (d), or to a process." The EPA, using an OGI camera, observed emissions from the closed vent system at the FBIR Walker 34X-25 Pad. See Area of Concern #1 above. NSPS OOOOb Applicability Based on well production information reported by XTO to the NDIC; and the date of construction, reconstruction, or modification of the storage vessels; the EPA believes that storage vessels and associated emissions control equipment at the FBIR Bird 21X-19A Pad are potentially subject to requirements for storage vessel affected facilities in NSPS OOOOb. Utility Flare Requirements [ 60.5413b(e)] Per 60.5413b(e)(8), owners and operators must, "Operate each control device following the manufacturer's written operating instructions, procedures and maintenance schedule to ensure good air pollution control practices for minimizing emissions." The EPA noted UBHC emissions indicating poor air pollution control practices from a lit flare at the FBIR Bird 21X-19A facility. See Area of Concern #2 above.
Page 6 of 8
Table 2: Inspection Details: Storage Tank Observations
Number of
AVO (Audio, visual,
Storage
olfactory)
Well Pad Name
Tanks
Observations
FBIR Stephen 31X-9
20
None
FBIR Walker 34X-25
6
None
Emissions Description Continuous emissions from the thief hatch. Continuous emissions from the top of the tank.
Media File Name MOV_3544.mp4 MOV_3545.mp4
MOV_3547.mp4
Table 3: Inspection Details: Control Devices and AVO/OGI Observations
Number
Visible
of
Pilot Active
Well or Well Control Control Device Flame Flaring Method 22
Pad Name Device(s) Type(s)
(Y/N) (Y/N) Observations
FBIR Blackmedicine 24X- 3 21A Pad
Air Assisted Steffes N
N
None
Air Assisted Steffes N
N
None
Air Assisted Steffes N
N
None
Emission Observation Description
N/A
Media File Name
N/A
Slope to K/O Drum
FBIR Stephen 2 31X-9 FBIR Bird 2 21X-19A
Air Assisted Steffes Y
Y
None
Air Assisted Steffes Y
Y
None
Air Assisted Steffes Y
N
None
2-Prong HP
Y
N
None
N/A
N/A
Continuous emissions from pilot gas piping next to the flare tip.
MOV_3546.mp4
Page 7 of 8
Air Assisted Steffes Y
Y
None
FBIR Walker 2
N/A
N/A
34X-25
2-Prong HP
Y
N
None
Air Assisted Steffes Y
Y
None
FBIR Walker 2
N/A
N/A
31X-36D
2-Prong HP
Y
Y
None
FBIR
Air Assisted Steffes Y
Y
None
Lawrence
2
N/A
N/A
24X-26A
2-Prong HP
Y
Y
None
Air Assisted Steffes Y
Y
None
FBIR
Ironwoman 3
2-Prong HP
Y
N
None
N/A
N/A
21X-10
LP
Y
N
None
FBIR
Air Assisted Steffes Y
Y
None
Yellowwolf
2
N/A
N/A
31X-10C
2-Prong HP
Y
Y
None
FBIR
Air Assisted Steffes Y
Y
None
Youngbear
2
N/A
N/A
31X-9A
2-Prong HP
Y
Y
None
Page 8 of 8
APPENDIX A: Photograph and Video Log
Media File MOV_3544.mp4* MOV_3545.mp4* MOV_3547.mp4*
MOV_3546.mp4*
entrysign-20241023-154528.jpg
entrysign-20241023-172421.jpg entrysign-20241023-173545.jpg entrysign-20241023-175402.jpg entrysign-20241023-180330.jpg
Description
Well Pad Name
Continuous emissions from the thief hatch.
FBIR Stephen 31X-9
Continuous emissions from the top of the tank.
FBIR Walker 34X-25
Continuous emissions from pilot gas piping next to FBIR Bird 21X-19A the flare tip.
Entry Sign
FBIR Blackmedicine 24X21A Pad
Entry Sign
FBIR Stephen 31X-9
Entry Sign
FBIR Bird 21X-19A
Entry Sign
FBIR Walker 34X-25
Entry Sign
FBIR Walker 31X-36D
entrysign-20241023-183626.jpg Entry Sign
FBIR Lawrence 24X-26A
entrysign-20241024-131031.jpg entrysign-20241024-132042.jpg
Entry Sign Entry Sign
FBIR Ironwoman 21X-10 FBIR Yellowwolf 31X-10C
entrysign-20241024-133234.jpg Entry Sign
FBIR Youngbear 31X-9A
*In addition to recording metadata through the OGI camera's system, EPA collected metadata for the media files recorded during the inspections, including the date, time, and location of the recorded media, in the Survey123 ArcGIS application at the time of the inspections. Due to a technical issue experienced with the OGI camera's metadata captured for the .mp4type files, the Survey123 metadata was used as the primary reference for verifying inspection media file data.
Appendix A Page 1 of 1