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EOG Resources - Various Well Pads and Facilities Partial Compliance Evaluation (PCE) On-Site Clean Air Act (CAA) Inspections Inspection Date(s): February 6-7, 2024 Inspection Report Date: March 8, 2024 EPA Representatives: US EPA Region 8, Clean Air Act Inspector US EPA Region 8, Clean Air Act Inspector Tribal Representatives: MHA Energy MHA Energy Company Representatives: None Inspection Report Prepared By: , US EPA Region 8 US EPA Region 8, Clean Air Act Inspector Inspection Report Reviewed By: anager, Enforcement and Compliance Assurance Division, Air and Toxics Enforcement Branc 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 OOOOa: Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification or Reconstruction Commenced After September 18, 2015 (NSPS OOOOa) Other Rules Investigated: 40 C.F.R Part 60, Subpart JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines (NSPS JJJJ) 40 CFR Part 49 Subpart C - Federal Implementation Plan for Managing Air Emissions From True Minor Sources in Indian Country in the Oil and Natural Gas Production and Natural Gas Processing Segments of the Oil and Natural Gas Sector (OGFIP) 40 C.F.R Part 63, Subpart HH National Emission Standards for Hazardous Air Pollutants From Oil and Natural Gas Production Facilities (MACT HH) 40 C.F.R Part 71--Federal Operating Permit Programs (Part 71) Compliance Assistance None Enforcement History EOG Resources, Inc. (EOG) was issued an administrative complaint and consent agreement for constructing major stationary sources located in Fort Berthold Reservation without first obtaining a PSD permit (Court Docket Number CAA-08-2011-0023) in 2012. Areas of Concern 1. The EPA detected hydrocarbon emissions from the storage tanks at well pads co-located with the following wells: Liberty LR 14-1109H Clarks Creek 08 SESE 1 Pad, latitude: 47.90753, latitude: -102.72965 (Note: pad sign shows Clarks Creek 08 SESE 2) Liberty 11 SESE 1 Pad and Liberty 11 NWSE 1 Pad 2. The EPA detected hydrocarbon emissions from an unlit flare co-located with the following wells or compressor sites: Van Hook 15 NENW Parshall 33 SWSE 1 3. The EPA detected visible emissions from operating utility flares co-located with the following wells: Van Hook 35 SESE Pad 4. The EPA has concerns that the following facilities may have exceeded 100 tpy at one point since the facilities began operation: Mandaree 10 NENW Pad and Mandaree 10 (both facilities may be co-located, EPA noted 3 engines, one dehydration unit, 4 wells, 8 tanks and 2 control devices onsite). Mandaree 10 NWNW Pad: On March 7, 2024, EOG provided information that Mandaree 10 NWNW had cumulative VOC emissions greater than 100 tpy, shown below. VOC would be 105.47 tpy according to information provided by EOG. Additionally, EOG provided information about the dehydration unit operating at Mandaree 10 NWNW where the dehydration unit showed benzene in excess of 0.9 Mg/yr. EPA has concerns that this unit shall comply with the major source requirements of MACT HH. Liberty 11 SESE 1 Pad and Liberty 11 NWSE 1 Pad (both facilities listed as same latitude and longitude on two separate registrations, combined emissions exceed 100 tpy for VOC's) Liberty 23 NENW and Liberty LR 56-2320H (both facilities listed as same latitude and longitude on registration, combined emissions exceed 100 tpy for VOC's) Clarks Creek 08 SESE: EOG provided PTE from a Part 2 Registration submitted December 12, 2019 that shows, among other criteria pollutants, 93.54 tpy of VOC and 8.09 tpy of HAP, shown below. During the onsite inspection, EPA inspectors observed a Moser Engine Service Generator onsite that EOG confirmed was a PSI Heavy Duty Engine, D146L also shown in a screenshot below. EOG confirmed that a generator was onsite since August 8, 2018, and two generators (D146L and D219L) located onsite between 1/7/2020 and 3/14/2020. The D146L generator has 402 hp and the D219L has 684 hp. EOG did not account for second or third engines being onsite for greater than 12 months in the Part 2 Registration. Based on the duration these engines may have been required to notify EPA of their operation as a Page 3 of 9 registration. These two engines may add to the VOC PTE to be greater than 100 tpy. 5. The EPA noted equipment onsite at Clarks Creek 08 SESE that was not included in the Part 2 Registration and EOG informed EPA in a submittal provided February 22, 2024 that two emission sources (Caterpillar Engine and a dehydration unit) were added at Mandaree 10 NWNW without registration forms submitted. 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 February 6-7, 2023, at multiple EOG facilities located on the FBIR. The EPA evaluated each EOG 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, NSPS OOOOa, NSPS JJJJ, OGFIP, and Part 71 Title V Operating Permits. Each well pad inspection followed the approach below: 1. Record the entry sign of the well pad when available. Survey the entire well pad with OGI camera. Record the number and type of site process equipment such as well heads, tanks, engines, dehydration units and emission control devices. 2. Record AVO indications of emissions from the storage tanks, closed vent system to the control devices and control devices. 3. Using the OGI camera, survey each process in infrared modes (auto, manual, and/or highPage 4 of 9 2/6/2024 14:35 3:04 2/7/2024 10:40 11:07 2/6/2024 15:12 15:31 2/6/2024 15:54 16:16 2/6/2024 10:30 11:05 2/7/2024 9:07 9:22 2/6/2024 12:24 12:45 2/6/2024 9:58 10:20 2/7/2024 9:35 9:49 2/6/2024 14:00 14:30 Liberty 14 NWSE 033-061- 37252, 37253, 47.895717 14 1 Pad (possibly 04652, 033- 37254, 37255 Liberty LR18-14H) 061-04653, 033-061- 04654, 033- 061-04655 Clarks Creek 08 33-053-07918, 33278, 33279, 47.907531 SESE 33-053-07919, 20602, 19790 33-053-03535, 33-053-03320 Liberty LR 562320H AND Liberty 23 NENW FERTILE LCS Compressor Station 33-061-04894, 38324, 38325, 47.88912092 33-061-04895, 30594, 30593 33-061-03556, 33-061-03555 NA NA 47.8705 PARSHALL LCS (1, NA NA 47.9628 2 3 & 4) -102.28845 -102.72965 -102.2908038 -102.2159 -102.1744 Fertile 7 SESE 2 Pad 33-061-03983, 33019, 33021, 47.906848 33-061-03985, 33020 33-061-03984 Van Hook 35 SESE 33-061-03724, 31399, 32119 47.935902 Pad 33-061-03858 Van Hook 14 SESE 33-061-03628, 30950, 30951, 47.978934 Pad 33-061-03629, 30989, 30988, 33-061-03646, 19662 33-061-03645, 33-061-01517 Liberty 13 NESE 1 33-061-04154, 34271, 33373, 47.897591 Pad 33-061-04009, 33374 33-061-04010 Liberty 11 SESE 1 33-061-04043, 33511, 34361 47.9065444 Pad and Liberty 33-061-04160 11 NWSE 1 Pad -102.23982 -102.281728 -102.280141 -102.258476 -102.27985 Page 6 of 9 Observations and Regulatory Applicability Fort Berthold FIP, NSPS OOOOa, NSPS JJJJ, OGFIP, and Part 71 Title V Operating Permit 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 includes well head counts and 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 EOG, 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 three out of 14 oil and natural gas production facilities evaluated. See Area of Concern #1 above. Utility Flare Requirements [ 49.4165(c)] Per 49.4165(c)(6)(vi), "The owner or operators must ensure that each enclosed combustor and utility flare is maintained in a leak-free condition." The EPA, using an OGI camera, detected emissions from an unlit flare at two out of 14 oil and natural gas production facilities. See Area of Concern #2 above. Per 49.4165(c)(6)(vii), "The owner or operator must ensure that each enclosed combustor and utility flare is operated with no visible smoke emissions." Per 49.4166(g)(3) and EPA Reference Method 22, the EPA noted smoke emissions at one out of 14 oil and natural gas production facilities evaluated. See Area of Concern #3 above. NSPS OOOOa Applicability Based on well production information reported by EOG in NSPS OOOOa reports, data submitted to the NDIC and the date of construction, reconstruction, or modification of the storage vessels, the EPA believes that storage vessels, reciprocating compressors and associated emissions control equipment at all identified in Table 1 are subject to requirements for storage vessel affected facilities in NSPS OOOOa. Page 7 of 9 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 60.5412(c) and (d), or to a process." The EPA, using an OGI camera, observed emissions from the closed vent system at the Liberty LR 43-1109H, Clarks Creek 08 SESE, Liberty 11 SESE/ Liberty 11 NWSE facility. See Area of Concern #1 above. Control Device Requirements [ 60.5412a(d) and 60.5413a(e)] Per 60.5412a(d)(1)(ii), owners and operators must, for each combustion control device, "install and operate a continuous burning pilot flame." The EPA observed unlit pilot flames at the Van Hook 15 NENW and Parshall 33 SWSE 1 facilities. See Area of Concern #2 above. Per 60.5412a(d)(1)(iii), owners and operators must, "Operate the combustion control device with no visible emissions, except for periods not to exceed a total of 1 minute during any 15-minute period." The EPA observed black smoke continuously for more than one minute (per Method 22) at the Van Hook 35 SESE Pad facility. See Area of Concern #3 above. NSPS JJJJ Applicability A stationary internal combustion engine (ICE) means any internal combustion engine, except combustion turbines, that converts heat energy into mechanical work and is not mobile. Stationary ICE differ from mobile ICE in that a stationary internal combustion engine is not a nonroad engine as defined at 40 CFR 1068.30 (excluding paragraph (2)(ii) of that definition), and is not used to propel a motor vehicle, aircraft, or a vehicle used solely for competition. Stationary ICE include reciprocating ICE, rotary ICE, and other ICE, except combustion turbines. The Moser engines located at Clarks Creek 08 SESE were manufactured after the trigger dates of NSPS JJJJ at 60.4230(a)(4), have continually been located at the facility for greater than 12 months (ie, not a mobile source engine) and therefore should comply with the requirements for stationary ICE. 40 CFR Part 49 Subpart C - Federal Implementation Plan for Managing Air Emissions From True Minor Sources in Indian Country in the Oil and Natural Gas Production and Natural Gas Processing Segments of the Oil and Natural Gas Sector As specified in 49.160(c)(1)(iv), "Minor sources complying with 49.101 through 49.105 for the oil and natural gas production and natural gas processing segments of the oil and natural gas sector, as defined in 49.102, must submit, at least 30 days prior to beginning construction, the Part 1 Registration Form containing the information in paragraph (c)(2) of this section. The Part 2 Registration Form, including emissions information, must be submitted within 60 days after the startup of production as defined in 49.152(d). The source must determine the potential for emissions within 30 days after startup of production. The combination of the Part 1 and Part 2 Registration Forms submittals satisfies the requirements in paragraph (c)(2) of this section. These forms are submitted to the EPA instead of the application form required in paragraph (c)(1)(iii) of this section. The forms are available at: https://www.epa.gov/tribalair/tribal-minor-new-source-review or from the EPA Regional Offices." Page 8 of 9 EPA noted equipment onsite at Clarks Creek 08 SESE that was not included in the Part 2 Registration and EOG informed EPA in a submittal provided February 22, 2024 that two emission sources (Caterpillar Engine and a dehydration unit) were added at Mandaree 10 NWNW without registration forms submitted. MACT HH Applicability EOG provided information about the dehydration unit that operated at Mandaree 10 NWNW showing benzene PTE greater than 0.90 Mg/yr. Benzene PTE was calculated by EOG to be 7.899 tpy. The dehydration unit operated April 26, 2023 through January 4, 2024. Therefore, EOG should have complied with the major source requirements of MACT HH at 40 C.F.R. 63.764(c). The EPA does not have records of startup notifications according to 40 C.F.R. 63.775 or startup notifications under the General Provisions of Part 63. Part 71 Title V Applicability Per 71.3(a), any major source is subject to the permitting requirements under Part 71. Based on well production information reported by EOG in facility registrations, NSPS OOOOa reports, data submitted to the NDIC and facility throughputs, the EPA believes that the facilities identified in Area of Concern #4 may be or have had emissions greater than 100 tpy and therefore may be or have been subject to Part 71 Title V. As specified in 40 C.F.R. 71.7(b), "no part 71 source may operate after the time that it is required to submit a timely and complete application under this part." Page 9 of 9 LIBERTY LR 43- 2 1109H Mandaree 10 2 NENW Pad and Mandaree 10 NWNW Liberty 14 2 NWSE 14 1 Pad (possibly Liberty LR1814H) Clarks Creek 3 08 SESE 2 Pad (sign says SESE 1 pad) Liberty LR 56- 2 2320H AND Liberty 23 NENW FERTILE LCS 2 Compressor Station 1, LP Steffes Air Y Y assist. 1 HP Steffes 1, LP Steffes Air No No assist. 1 HP Steffes 1 HP Steffes, 1 LP Air assist Steffes. Yes, Yes Y 2 Steffes, 1 Air Y Y Assist HP, 1 Zeeco HEIC-1-TS- S 1 HP Steffes, 1 Y Y LP Air assist Steffes. Air assist Y, N Y shows pilot failure light on. None None None None None Flares on, no emission concerns DC_3482 None None None Large air assist (likely MOV_3486, Flare Industries similar to MOV_3488 Parshall LCS), unlit. UBHC from large air assist. Page 12 of Slope of flare. Pilot light out on FLIR, control panel also alarm shows Pilot Failure. Photo DC_3460. Temps for thermocouple on control panel above 1400F for both flares NA Downward Low temp alarm on flare control panel. One panel was 1356F, low alarm panel shows negative (-) 153F but flare pilot is burning/flare on. Downward Air assist flares noted as operating greater than 1000F on control panel PARSHALL LCS 2 (1, 2 3 & 4) Fertile 7 SESE 2 2 Pad Air assist Y No None 1 HP Steffes, 1 Y Y LP Air assist Steffes. None Van Hook 35 1 SESE Pad Van Hook 14 2 SESE Pad Liberty 13 2 NESE 1 Pad Liberty 11 3 SESE 1 Pad and Liberty 11 NWSE 1 Pad Zeeco, MTAG- Y 3T-20, manufactured 2013. Zeeco, likely HP- Yes, Yes LP Y Yes, Yes Yes None 1 HP Steffes, 1 LP Air assist Steffes. 1 HP Steffes, 1 LP Air assist Steffes, 1 Zeeco Y Yes, Yes, Yes No Y, Y, Y None None Other flare, smaller Cimarron flare, operating and flaring (truck loading during onsite inspection). Manual mode used for second OGI video None DC_3490 Failed Method 22. IMG_0023, IMG_0024 UBHC on one but pilot on MOV_3455 None None Downward Downward Air assist flares, one was Flare Industries, #100246 No pilot detected on control panel but heat signature detected with FLIR. Pilot alarm on LP flare. 5-15% opacity for >70 seconds. Downward Downward Downward Both Steffes noted with thermocouple temps each between 12501350F. Page 13 of DC/MOV DC/MOV DC/MOV DC/MOV DC/MOV DC/MOV DC/MOV DC/MOV DC/MOV DC/MOV DC/MOV DC/MOV DC/MOV DC/MOV DC/MOV DC/MOV DC/MOV DC/MOV DC/MOV DC/MOV DC/MOV DC/MOV DC/MOV DC/MOV DC/MOV DC/MOV DC/MOV DC/MOV DC/MOV DC/MOV DC/MOV DC/MOV 3459 3460 3461 3462 3463 3464 3465 3466 3467 3468 3469 3470 3471 3472 3473 3474 3475 3476 3477 3478 3479 3480 3481 3482 3483 3484 3485 3486 3488 3489 3490 3492 Unlit flare Control panel showing pilot failure light on Significant emissions from hotizontal separator T-12 On other side of separator, leak detected on FLIR but could not pinpoint exact location Staining on ground behind heater treater Staining on ground behind heater treater Staining on ground behind heater treater Site Overview Site Overview Site Overview Yellow probe leak tank 8369 TH leak on tank 8368 TH leak on tank 8373 TH leak on tank 8372 Vac breaker leak on tank 1790 TH leak on tank 8371 TH leak on tank 1789 FLIR video taken showing liquids in tanks South heater treater emissions on FLIR from insulation by burner/exhaust Site Overview Thief hatch leaks Thief hatch leaks Thief hatch leaks Flare video Site Overview Site Overview Site Overview Unlit flare Unlit flare Site Overview Control panel showing pilot failure light on Site Overview Page 2 of 2 Parshall 33 SWSE 1 Parshall 33 SWSE 1 Parshall 33 SWSE 1 Parshall 33 SWSE 1 Van Hook 35 SESE Pad Van Hook 35 SESE Pad Van Hook 35 SESE Pad Van Hook 36 SESW Van Hook 36 SESW LIBERTY LR 43-1109H LIBERTY LR 43-1109H LIBERTY LR 43-1109H LIBERTY LR 43-1109H LIBERTY LR 43-1109H LIBERTY LR 43-1109H LIBERTY LR 43-1109H LIBERTY LR 43-1109H LIBERTY LR 43-1109H LIBERTY LR 43-1109H Liberty 11 SESE 1 Pad and Liberty 11 NWSE 1 Pad Liberty 11 SESE 1 Pad and Liberty 11 NWSE 1 Pad Liberty 11 SESE 1 Pad and Liberty 11 NWSE 1 Pad Liberty 11 SESE 1 Pad and Liberty 11 NWSE 1 Pad Liberty 14 NWSE 14 1 Pad (possibly Liberty LR18-14H) Liberty 14 NWSE 14 1 Pad (possibly Liberty LR18-14H) Liberty LR 56-2320H AND Liberty 23 NENW FERTILE LCS Compressor Station FERTILE LCS Compressor Station FERTILE LCS Compressor Station Fertile 7 SESE 2 Pad Fertile 7 SESE 2 Pad Liberty 13 NESE 1 Pad DC/MOV DC/MOV DC/MOV DC/MOV DC/MOV 3493 3494 3496 3497 3498 Site Overview Following tank leaks seen on FLIR as tank emissions; large/significant: PW tank emissions 1 VRU disconnected from tanks Following tank leaks seen on FLIR as tank emissions; large/significant: PO tank emissions Entry Sign Photo Clarks Creek 08 SESE 2 Pad (sign says SESE 1 pad) Clarks Creek 08 SESE 2 Pad (sign says SESE 1 pad) Clarks Creek 08 SESE 2 Pad (sign says SESE 1 pad) Clarks Creek 08 SESE 2 Pad (sign says SESE 1 pad) Mandaree 10 NENW Pad and Mandaree 10 NWNW Page 3 of 2