Document QX2B04drJq7GnmbqRRzRVX30L

Arkoma Operations LLC- Helton Well Pad Full Compliance Evaluation (FCE) On-Site Clean Air Act (CAA) Inspections Inspection Date: June 27, 2022 Inspection Report Date: July 21, 2022 EPA Representatives: Alexis North Tribal Representatives: David Heermance, Meredith Breeden, Drew Switzer Company Representatives: None onsite during inspection. Inspection Report Prepared By: Inspection Report Reviewed By: Applicable Rules: Alexis North Scott Patefield None SCOTT PATEFIELD Digitally signed by SCOTT PATEFIELD Date: 2022.10.04 10:48:50 -06'00' Compliance Assistance None Enforcement History This facility has never been inspected and has no prior enforcement history. Area of Concern None General Source Information An unannounced inspection was conducted on June 27, 2022, at the Helton well pad owned and operated by Arkoma. For reference, these wells are co-located on the same pad as the Slugger well pad owned and operated by Advanced Wireless Communication. Inspectors scanned the well sites' liquid storage tank for any detectable emissions using an optical gas imaging (OGI) camera. Table 1 lists well pad specifics for each inspection including latitude/longitude location and entry/exit details. Table 1: List of Facilities Inspected June 27, 2022 Well Name Latitude Longitude Date Helton #1A (API 05 067 08175) V.D. Helton #1 (API 05 067 05749) 37.10752 -107.75419 6/27/2022 Time In 3:15 pm Time Out Not reported Tables 2 and 3 at the end of this report includes the inspections details. Table 2 includes well head counts and storage details. Table 3 contains control device and audio, visual, or olfactory (AVO) details. Each well pad inspection followed the approach below: Page 1 of 4 1. Park on the wellpad. 2. Make notations on the site operation including the number of each major type of site process equipment present (e.g., total number of tanks, number of oil tanks, number of water tanks, number of tank emission control devices). 3. Note any AVO indications of emissions from the tanks, closed vent system, and control devices. 4. Survey the site operations in infrared modes (auto, manual, and/or high-sensitivity modes), looking for emissions. CAA Applicability As an oil and gas well site, there could be NSPS OOOO or OOOOa applicability. However, this field is producing methane from coalbed methane seams and there is no condensate production/storage at this facility, thus will not trigger the 6 tons per year VOC threshold for NSPS OOOO/a applicability. Additionally, EPA has no NSPS OOOO/a reports from Arkoma Operations indicating applicability. While the Tribal Minor NSR Oil and Gas registration program applies to all facilities operating on the Southern Ute Reservation above certain pollutant thresholds (5 tons VOC in an attainment area), there are no Part 2 registrations for these facilities. There are no natural gas powered pumping engines operating on the two Helton wells, thus no NSPS JJJJ or MACT ZZZZ applicability. No information regarding the 2 newer Slugger wells could be located in Colorado Oil and Gas database (COGIS), see screen shot below link here: Page 2 of 4 Google Earth Image: The two Arkoma wells are located in the red circle below, the co-located Advanced Wireless Communications wells are outside the red circle. Photo and Video Log Date 6/27/2022 6/27/2022 File DC_2975.jpg DC_2976.jpg Name Slugger/Helton Pad Slugger/Helton Pad Comment Pic of well sign Pic of well sign Page 3 of 4 Table 2: Inspection Details: Well Head Count and Storage Tanks Well Name # Well # WH Heads (WH) Operating? Helton #1A (API 05 067 08175) V.D. Helton #1 (API 05 067 05749) 2 2 # Total Storage Tanks 1 Vapor Recovery Tower? None CVS IR? File ID Tank Thief IR? File ID None None Table 3: Inspection Details: Control Devices and AVO Well Name Combustio CD Visibl UBHC CD n Device Coun e ? IR? (CD) Type t flame CD? Helton #1A (API 05 067 08175) None 0 NA NA NA V.D. Helton #1 (API 05 067 05749) *UBHC = unburned hydrocarbons File ID NA Smoke from CD? NA AVO No odors Notes No condensate collected on site, only water. Wells produce dry, coalbed methane. AN Page 4 of 4