Document jzaYEob71kVn7YYXYpL9mqBk

White Rock Oil & Gas, LLC - Various Well Pads and Facilities Partial Compliance Evaluation (PCE) On-Site Clean Air Act (CAA) Inspections Inspection Date(s): October 23, 2024 Inspection Report Date: December 5, 2024 EPA Representatives: US EPA Region 8 Clean Air Act Inspectors: Alexis North, Joe Wilwerding, Bob Gallagher State Representatives: Jamin Grantham, Adam Bradley, Saloma Lentz Company Representatives: Shawna Bonini. Spencer Learherman, Daniel Heggem Inspection Report Prepared By: Alexis North, Joe Wilwerding Inspection Report Reviewed By: Related Rules: Scott Patefield, Manager, Enforcement and Compliance Assurance Division, Air and Toxics Enforcement Branch SCOTT PATEFIELD PATEFIELD Digitally signed by SCOTT Date: 2024.12.05 13:07:12 -07'00' Administrative Rules of Montana, Title 17 Environmental Quality, Chapter 8 (link) 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) Compliance Assistance None Areas of Concern 1. The EPA detected hydrocarbon emissions from the storage tanks at well pads co-located with the following wells: x Steinbeisser 44 32 H 2. The EPA detected hydrocarbon emissions from an unlit flare co-located with the following wells or compressor sites: x Christiansen 14X 9 x Lowell Larson x Steinbeisser 44 32 H 3. The EPA detected unburned hydrocarbon (UBHC) emissions from operating utility flares colocated with the following wells: x None 4. The EPA detected visible emissions from operating utility flares co-located with the following wells: x None See Table 1 below for more details regarding inspected locations and Tables 3 and 4 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 Announced well pad inspections were conducted jointly by U.S. EPA and Montana State inspectors on October 23, 2024, at multiple White Rock Oil & Gas, LLC (White Rock) facilities located in the Northeast portion of the State of Montana. The EPA 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 Administrative Rules of Montana and NSPS OOOO/a. 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. 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 highsensitivity 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. Page 2 of 9 6. Using another OGI camera, 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 facility details for each inspected facility. The well pad information located in the Table 1 is from the Montana Board of Oil and Gas online data base located at https://bogapps.dnrc.mt.gov/dataminer/Production/ProductionByWell.aspx . Table 1: Inspection and Facility Details of Facilities Inspected Date 10/23/2024 10/23/2024 10/23/2024 10/23/2024 10/23/2024 10/23/2024 10/23/2024 10/23/2024 10/23/2024 10/23/2024 10/23/2024 Facility Name Christiansen 14X 9 Larson 8 28 Lowell Larson Larson 44x 18 Larson 3 19h Rocky 42x 13 Obergfell Trust and Nancy Lee Larson 1 19h Steinbeisser 44 32 H Simonsen 44x 5 Groskinsky 44x6 API Well ID 25083222870000 25083222680000 25083222030000 25083220140000 25083223010000 25083228290000 25083221570000, 25083226480000 25083224870000 25083222130000 25083223810000 25083224190000 Latitude -104.288 -104.272 -104.269 -104.316 -104.326 -104.338 -104.356 -104.319 -104.426 -104.164 -104.186 Longitude 47.76217 47.72737 47.73769 47.74873 47.7447 47.75524 47.7529 47.74598 47.70612 47.68953 47.68934 Observations and Regulatory Applicability The Administrative Rules of Montana and NSPS OOOO/a regulations which are potentially relevant to the observations noted during the inspections are summarized in this section. Administrative Rules of Montana Applicability The following emissions control requirements apply to the White Rock facilities inspected by EPA and the State of Montana: 17.8.1603 Emission Control Requirements Per 17.8.1603(1)(b), "VOC vapors greater than 500 BTU/scf from oil and condensate storage tanks with the PTE of 15 TPY or greater must be captured and routed to a gas pipeline, or if a gas pipeline is not located within a 1/2 mile of the oil and gas well facility, VOC vapors greater than 500 BTU/scf from storage tanks with the PTE of 15 TPY must be captured and routed to emissions minimizing technology, or to a smokeless combustion device equipped with an electronic ignition device or a continuous burning pilot system." 17.8.1710 Oil or Gas Well Facilities General Requirements Per 17.8.1710(3), "(3) The owner or operator of a registered oil or gas well facility shall operate all emissions control equipment to provide the maximum air pollution control for which it was designed." Page 3 of 9 17.8.1711 Oil or Gas Well Facilities Emission Control Requirements Per 17.8.1711(1)(a), "VOC vapors of 200 Btu/scf or greater from each piece of oil or gas well facility equipment, with a PTE greater than 15 tpy, must be captured and routed to a gas pipeline, routed to a smokeless combustion device equipped with an electronic ignition device or a continuous burning pilot system, meeting the requirements of 40 CFR 60.18, and operating at a 95% or greater control efficiency, or routed to air pollution control equipment with equal or greater control efficiency than a smokeless combustion device. The phrase "oil or gas well facility equipment" includes, but is not limited to, wellhead assemblies, amine units, prime mover engines, phase separators, heater treatment units, dehydrator units, tanks, and connecting tubing, but does not include equipment such as compressor engines used for transmission of oil or natural gas". NSPS OOOO/a Applicability EPA assembled data on well production information reported to the Montana Board of Oil and Gas in Table 2, in order to determine if compliance with NSPS Subparts OOOO/a is required at the inspected sites. As shown in Table 2, each of the sites started production (and was therefore constructed) prior to the August 23, 2011 initial applicability date for NSPS Subpart OOOO. Also, no additional wells have been added to the sites since original construction. Table 2: Site First Date of Operation and Other Information Facility Name Christiansen 14X 9 Larson 8 28 Lowell Larson Larson 44x 18 Larson 3 19h Rocky 42x 13 Obergfell Trust and Nancy Lee Larson 1 19h Steinbeisser 44 32 H Simonsen 44x 5 Groskinsky 44x6 First Date of Oil Production 3/1/2006 5/1/2005 12/1/2004 11/1/2003 12/1/2005 8/1/2010 7/1/2004 8/1/2006 1/1/2005 3/1/2006 5/1/2006 Date of Any Well Additions N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A Tables 3 and 4 below summarize inspection observations and findings. Table 3 includes facility storage tank information and observations. Table 4 includes details of control devices and related observations. See Appendix A for a log of images and videos taken during the inspections. Page 4 of 9 Table 3: Inspection Details: Storage Tank Observations Facility Name Christiansen 14X 9 Larson 8 28 Lowell Larson Number of Storage Tanks 3 4 2 AVO (Audio, visual, olfactory) Observations No emissions/AVO; pumper pulling load of water finished while onsite. No liquid levels in tanks; IR clear. No emissions from tanks noted. Larson 44x 18 3 Site not operating; not connected. Larson 3 19h 4 Site not operating. Rocky 42x 13 4 No emissions noted. Obergfell Trust and Nancy Lee Larson 1 19h Steinbeisser 44 32 H Simonsen 44x 5 Groskinsky 44x6 8 No emissions noted. 4 No emissions noted. 5 Saw emissions from far-left crude tank this morning, but emissions were gone when we returned to site this afternoon. As we were leaving in the afternoon, we checked the tanks one last time and the venting was back on the far-left crude oil tank. White Rock stopped the emissions while we were still onsite. 4 No emissions from tanks noted. 4 No emissions from tanks noted. Emissions/Observation Media File Name MOV_3627, MOV_3628 Table 4: Control Devices and Related Observations Facility Name Flare 1 Type Quantity of Flare 1 Type Christiansen 14X 9 Pit 1 Larson 8 28 Steffes 1 Flare 2 Type Quantity of Flare 2 Type Combustion Control Device Notes Pit flare sparking, but not igniting. Can hear sparking. Video taken of emissions. Flare caught while I was standing there; video taken. No emissions noted. Emissions/ Observation Media File Name MOV_3615, MOV_3616 Page 5 of 9 Table 4: Control Devices and Related Observations Facility Name Flare 1 Type Quantity of Flare 1 Type Lowell Larson Cimmaron 1 Larson 44x 18 Pit 1 Larson 3 19h Pit 1 Rocky 42x 13 Pit 1 Obergfell Trust and Nancy Lee Pit 1 Larson 1 19h High Pressure Steffes 1 Steinbeisser 44 32 H Pit 1 Simonsen 44x 5 Pit 1 Groskinsky 44x6 Pit 1 Flare 2 Type Steffes Cimarron Quantity of Flare 2 Type 1 1 Combustion Control Device Notes Steffes flare on and operating. Cimarron unlit and venting upon arrival. Site not operating. Site not operating. Pit flare operating with visible flame. Pit flare operating. Steffes visible flame; Cimarron on no emissions noted. Pit flare venting; spark not catching. As soon as wind died down a bit, flare ignited. Need to reconfigure flare to catch spark in windy conditions. Sales gas not being sold so going out of unlit flare for a period of time today. Flare flame visible. Pit flare was operating and sales gas flaring started while we were onsite. Emissions/ Observation Media File Name MOV_3619 MOV_3626 Page 6 of 9 APPENDIX A: Photograph and Video Log Media File IMG_0030 IMG_0031 IMG_0032 IMG_0033 IMG_0034 IMG_0035 MOV_3611 MOV_3612 MOV_3614 MOV_3615 MOV_3616 MOV_3617 MOV_3618 MOV_3619 MOV_3620 MOV_3621 MOV_3622 MOV_3623 MOV_3624 MOV_3625 MOV_3626 MOV_3627 MOV_3628 MOV_3629 MOV_3630 MOV_3631 Site White Rock Christiansen 14X-9 White Rock Larson 44x 18 White Rock Rocky 42x 13 White Rock Obergfell Trust and Nancy Lee White Rock Obergfell Trust and Nancy Lee White Rock Steinbeisser 44 32 H White Rock Steinbeisser 44 32 H White Rock Facility White Rock Christiansen 14X-9 White Rock Christiansen 14X-9 White Rock Christiansen 14X-9 White Rock Larson 8 28 White Rock Lowell Larson White Rock Lowell Larson White Rock Larson 44x 18 White Rock Larson 3 19h White Rock Rocky 42x 13 White Rock Obergfell Trust and Nancy Lee White Rock Larson 1 19h White Rock Steinbeisser 44 32 H White Rock Steinbeisser 44 32 H White Rock Steinbeisser 44 32 H White Rock Steinbeisser 44 32 H White Rock Simonsen 44x 5 White Rock Groskinsky 44x6 White Rock Groskinsky 44x6 Description Sign Sign Sign Sign Lit pit flare Sign Tank emissions far left tank Site scan from car Site video Emissions from unlit pit flare Lit pit flare Site video Site video Uncombusted emissions from enclosed combustor Site video Site video Site video Site video Site video Site video Unlit pit flare Tank with no emissions Tank with no emissions Site video Site video Pit flare lighting Page 1 of 1