Document Yj1ogO6qr1mXmwMJLZB0D238O

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 1-13 and Denman 4-13 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 35.455400, -94.145362. 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 ARU002268 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 11:18:51 -06'00' Date JEANNE ECKHART Date: 2025.01.10 08:04:41 -06'00' Digitally signed by JEANNE ECKHART Jeanne Eckhart Date 6ENFORM-019-R8.2 (02/12/2020) 1 Merit Energy Company, LLC / Denman 1-13 and Denman 4-13 Tank Battery (ARU002268 / 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 1-13 and Denman 4-13 Tank Battery ("facility") at 0848 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 35.455400, -94.145362. 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 1-13 and Denman 4-13 Tank Battery, which contained one (1) storage tank for produced water, two (2) separators, one (1) LACT unit, and two (2) 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 113 and Denman 4-13 Tank Battery. 2 Merit Energy Company, LLC / Denman 1-13 and Denman 4-13 Tank Battery (ARU002268 / CWA) Inspection Date 12/11/2024 Section II - OBSERVATIONS I observed the Merit Energy Company, LLC / Denman 1-13 and Denman 4-13 Tank Battery facility and associated signage and secondary containment with storage tanks; see Appendix 1 (Photograph Log), Photo No. 1 through No. 3. For additional GPS location and photo metadata, see Appendix 1. I observed one fiberglass storage tank within secondary containment, see Photo No. 4. I observed holes/tears in the liner for secondary containment for the tank referenced above, see Photo No. 5. I observed the two 2-phase gas-water separators onsite, see Photo No. 6. I observed the LACT unit onsite, see Photo No. 7. 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/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 - 7 photos taken 12/11/2024. 3 Merit Energy Company, LLC / Denman 1-13 and Denman 4-13 Tank Battery (ARU002268 / CWA) Inspection Date 12/11/2024 Appendix 1 Photograph Log 7 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 35.455400, -94.145362. City: Alma County/Parish: Crawford State: AR Photo File Name: 100-0406 Orientation: 40 NE Date of Photo: 12/11/2024 Time of Photo: 0847 Latitude: 35.455433 Longitude: -94.145383 Photographer: Kerri McCabe Description: Looking NE, this photo shows one of the two 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 35.455400, -94.145362. City: Alma County/Parish: Crawford State: AR Photo File Name: 100-0407 Orientation: 64 ENE Date of Photo: 12/11/2024 Time of Photo: 0847 Latitude: 35.455383 Longitude: -94.145333 Photographer: Kerri McCabe Description: Looking ENE, this photo shows the second of the two 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 35.455400, -94.145362. City: Alma County/Parish: Crawford State: AR Photo File Name: 100-0408 Orientation: 355 N Date of Photo: 12/11/2024 Time of Photo: 0847 Latitude: 35.455233 Longitude: -94.145217 Photographer: Kerri McCabe Description: Looking N, this photo shows an overview of 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 35.455400, -94.145362. City: Alma County/Parish: Crawford State: AR Photo File Name: 100-0409 Orientation: 184 S Date of Photo: 12/11/2024 Time of Photo: 0848 Latitude: 35.455300 Longitude: -94.145367 Photographer: Kerri McCabe Description: Looking S, this photo shows a fiberglass storage tank for produced water inside secondary containment. 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 35.455400, -94.145362. City: Alma County/Parish: Crawford State: AR Photo File Name: 100-0410 Orientation: 287 WNW Date of Photo: 12/11/2024 Time of Photo: 0848 Latitude: 35.455200 Longitude: -94.145433 Photographer: Kerri McCabe Description: Looking WNW, this photo shows holes in the synthetic liner for the secondary containment structure from Photo No. 4. 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 35.455400, -94.145362. City: Alma County/Parish: Crawford State: AR Photo File Name: 100-0411 Orientation: 343 NNW Date of Photo: 12/11/2024 Time of Photo: 0849 Latitude: 35.455317 Longitude: -94.145483 Photographer: Kerri McCabe Description: Looking NNW, this photo shows two 2-phase gas-water 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 35.455400, -94.145362. City: Alma County/Parish: Crawford State: AR Photo File Name: 100-0412 Orientation: 320 NW Date of Photo: 12/11/2024 Time of Photo: 0849 Latitude: 35.455400 Longitude: -94.145483 Photographer: Kerri McCabe Description: Looking NW, this photo shows the LACT unit(s) located at the facility.