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