Document rBv2wmBm6bOnrZqnMpqze5ELa
EPA Inspection Report - Page 1 of 53
f t E A ~ UnitedStates
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Environm ental Protectio n
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Agency
Region 6 - Enforcement & Compliance Assurance Division
INSPECTION REPORT
Inspection Date(s): Media Program: Regulatory Program(s)
09/09/2025 Air State Implementation Plan (SIP) and New Source Performance Standards (NSPS)
Company Name: Facility Name: Facility Physical Location:
(city, state, zip code) Mailing address:
(city, state, zip code) County/Parish: Facility Phone Number Facility Contact:
Spur Energy Partners, LLC (Spur)
Multiple Facilities in Eddy County, NM
New Mexico Permian Basin
Multiple
9655 Katy Freeway, Suite 500
Houston, Texas 77024
Eddy County
281-904-8811 John Nabors John@spurenergy.com
I I Executive Vice President, Operations
FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC:
Multiple Multiple
Multiple 211120 1311
Personnel participating in inspection:
Cassandra Lowder
Environmental Protection Agency (EPA) Region 6
Bailey Brown
EPA Region 6
Cale Chapman
EPA Region 6
Mitchell Schatz
New Mexico Environmental Department (NMED)
Lead Inspector Inspector Inspector Inspector
John Hermes John Connelly Paolo Bahena
Spur Energy Resource Development Inc. (ERDI) Spur
Superintendent Spur Consultant Senior Foreman
EPA Lead Signature/Date
Supervisor Signature/Date
Inspector CASSANDRA LOWDER
Cassandra Lowder
Digitally signed by CASSANDRA LOWDER Date: 2026.01 .12 10:38:52 -06'00'
JAMIE SALABOGI
Jamie Salabogi
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Date ,n-u; '11.1 J 11 0"-41 -01\'00'
Date Date
1
EPA Inspection Report - Page 2 of 53
Section I INTRODUCTION
Spur Energy Partners, LLC / New Mexico Permian Basin Inspection Date 09/09/2025
PURPOSE OF THE INSPECTION
EPA Region 6 inspectors Cassandra Lowder, Bailey Brown, and Cale Chapman arrived at the Spur Energy Partners, LLC (IISpurII) field office located at 2407 Pecos Avenue, Artesia, New Mexico, at 9:35 am on August 9, 2025, for an announced inspection. Spur was not informed of the specific facilities until the day of the inspection. We met with John Hermes, Superintendent for Spur; Paolo Bahena, Senior Foreman for Spur; and John Connolly, Consultant for Spur (Appendix 1). Inspector Brown presented her credentials to Mr. Hermes, and I, Cassandra Lowder, informed him that this was an EPA inspection to determine compliance with the facilities' permits or Notice of Intent ("NOi") applications, and the Clean Air Act ("CAA"). The scope ofthe inspection was a partial compliance evaluation ("PCE") and included evaluation of the compliance of each facility with its New Mexico State Implementation Plan (IISIPII), and federal CAA regulations. The New Mexico Environmental Department participated in the inspection, and NMED inspector Mitchell Schatz accompanied EPA Region 6 inspectors on September 9, 2025. During the opening conference, Spur staff informed us that the Spur facilities were sour gas and Level A personal protection equipment was required to be worn within tank battery berms and on tank battery walkways.
We agreed to follow Spur's safety protocol.
FACILITY DESCRIPTION
The inspection covered seven (7) Spur facilities listed in Table 1. Spur's oil and gas production facilities had slightly different layouts depending on production, modifications to the facilities, and/or equipment that was onsite prior to Spur purchasing the leases. Spur had two general processes. One included facilities with a vapor Recovery Unit (''VRU") and vapor recover tower (''VRT"), and the other included facilities without a VRU and VRT. The facility specific process descriptions with or without VRUs and VRTs are below:
Process Description without VRU and Vapor Recover Tower VRT
Production streams from well sites entered the separators to separate gas, oil, and water. The gas from the separator(s) was routed to the scrubber then to the sells line. The water from the separator(s) was routed to the produced water storage tanks or a gunbarrel tank. The oil from the separator(s) was sent to heater treater(s). The water from separator(s) was routed to the gunbarrel tank for further separation. The water off the gunbarrel tank was routed to the produced water storage tanks while the oil was routed to the skim oil tank. The gas from the gunbarrel tank was sent to the dual pressure flare. The oil from the separators was sent to heater treater(s) for further separation. The oil from the heater treater(s) was routed to the oil storage tanks. The water from heater treater(s) was routed to the produced water storage tanks. The gas generated from the heater treater(s) was used as fuel at the facility. The heater treater was also used to recirculate the bottoms from the oil storage tanks. The hydrocarbon emissions from the oil storage tanks and produced water storage tanks were routed to the dual pressure flare or the
atmosphere. The oil from the oil storage tanks was routed to a lease automatic custody transfer ("LACT")
unit then trucked off-site to sales. The produced water was piped off-site to a saltwater disposal facility.
Process Description with VRU and VRT
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Spur Energy Partners, LLC / New Mexico Permian Basin Inspection Date 09/09/2025
Production streams from well sites enter the separator(s) to separate gas, oil, and water. The gas from the separator(s) was routed to the scrubber then to the sells line. The water from the separator(s) was routed to the produced water storage tanks or a gunbarrel tank. The oil from the separator(s) was routed to the VRT. The water from the separator(s) was routed to the gunbarrel tank for further separation. The water off the gunbarrel tank was routed to the produced water storage tanks while the oil was routed to the skim oil tank. The gas from the gunbarrel tank was sent to the dual pressure flare. The oil from the VRT was routed into oil storage tanks. The gas from the VRT was routed to the VRU then to the sells line. The hydrocarbon emissions from the produced water tanks were either routed to the atmosphere or the dual pressure flare. The hydrocarbon emissions from the oil storage tanks were routed to the dual pressure flare or the VRU to the sales line. The heater treater(s) onsite was used to recirculate oil from the bottoms of the oil storage tanks. The gas generated from the heater treater(s) was used as fuel. The oil from the oil storage tanks was routed to a LACT unit then trucked off-site to sales. The produced water was piped off-site to a saltwater disposal facility.
Section II OBSERVATIONS
EPA inspectors were equipped with a FLIR-Teledyne model Gx620 optical gas imaging camera ("OGI camera"); a Ricoh Model WG-6 digital camera ("Ricoh"); a Nikon Cool pix AW120 camera ("Nikon"); and a Toxic Vapor Analyzer 2020 that measures total volatile organic compounds in parts per million. Photographs and videos taken during the inspection are found in Appendix 2 and 3, respectively. Videos recorded with Central Standard Time (CST) time stamp in image. Videos listed in Appendix 2 are reflected in Mountain Standard Time (MST). All facilities were inspected with an OGI camera. We used the Ricoh at Arkansas 23 Fee 3 and Alto Amm 21 Tank during which we observed that the date and time stamps in the images were incorrect. We used the Nikon for all remaining facilities.
Table 1: Spur Facilities inspected # Facility Name 1 Arkansas 23 Fee 3 2 Alto Amm 21 Tank 3 B&B/Ross Ranch Yeso Battery 4 Goodman 22 Battery 5 Morris Boyd State Com #5H 6 Live Oak Tank Battery 7 Lakewood Federal Com 4H,
8H, 10H, 20H and 21H Facility
Permit Type NOI NOI NOI NOI NOI GCP NOI
Permit Number 5380 9834 9305 8316 8313 9306 9110
Latitude 32.64708 32.647473 32.648341 32.64524 32.64057 32.635811 32.625808
Longitude -104.45659 -104.480757 -104.479356 -104.47354 -104.45889 -104.469561 -104.469155
September 9, 2025, Inspections
1. Arkansas 23 Fee 3 (AIRS No. 350150916)
We arrived at the facility at 10:45 am (Photo No. 1 and Photo No. 3). The facility was comprised of one (1) heater treater; one (1) two-phase flare scrubber; one (1) dual pressure flare; one (1) operational 2-phase
3
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separator and one (1) out-of-service (IIOOSII) separator; one (1) OOS VRU; one (1) OOS VRT; five (5) OOS tanks; one (1) oil storage tank; and one (1) produced water storage tank. We observed hydrocarbon emissions from the pressure relief valve (PRV) on produced water storage tank 72238 using the OGI camera (Photo No. 2, Video No. 1, and Video No. 2)[AOC 1]. Spur staff stated tank gas was routed to the dual pressure flare and should not have emitted from the produced water storage tank. We departed the facility at 11:33 am.
2. Alto Amm 21 Tank (AIRS No. 350152764)
We arrived at the facility at 11:45 am (Photo No. 4 and Photo No. 7) and immediately smelled a strong odor of hydrocarbons. The facility was comprised of one (1) heater treater; one (1) two-phase flare scrubber; one (1) dual pressure flare; three (3) three-phase separators; one (1) VRU; one (1) VRT; two (2) oil storage tanks; and two (2) produced water storage tanks. We observed un-combusted hydrocarbon emissions from the dual pressure flare using an OGI camera (Photo No. 9, Video No. 3, and Video No. 4)[AOC 2]. I observed an illuminating green light indicating a lit pilot and a temperature reading of 932.15o F at the dual pressure flare control box (Photo No. 5 and Photo No. 6). We observed hydrocarbon emissions from the manifold PRV above oil storage tank 74538 using an OGI camera (Photo No. 7 and Video No. 5)[AOC 3]. We departed the facility at 12:32 pm.
3. B&B/Ross Ranch Yeso Battery (AIRS No. 350152543)
We arrived at the facility at 12:45 pm (Photo 10) and immediately smelled a strong odor of hydrocarbons. The facility was comprised of one (1) operating heater treater and one (1) OOS heater treater; one (1) two-phase scrubber for the sales line; one (1) dual pressure flare; four (4) 3-phase separators; two (2) operating oil tanks and two (2) OOS oil tanks; two (2) produced water tanks; one (1) gunbarrel tank; and one (1) slop tank. We observed hydrocarbon emissions from the PRV on the produced water tank using the OGI camera (Photo No. 11 and Video No. 6)[AOC 4]. Spur staff stated that all the tanks were uncontrolled. We departed the facility at 1:15 pm.
4. Goodman 22 Battery (AIRS No. 350152126)
We arrived at the facility at 2:17 pm (Photo No. 12). The facility was comprised of two (2) heater treaters that operated interchangeably; two (2) two-phase scrubbers that scrub gas from heater treater and separators; one (1) dual pressure flare; four (4) 3-phase separators; two (2) operating oil storage tanks; four (4) produced water storage tanks; and two (2) OOS slop storage tanks. We observed hydrocarbon emissions from the thief hatch on oil storage tank 71962 using the OGI camera (Photo No. 14) Video No. 7)[AOC 5]. We heard a hissing sound from the PRV on the produced water storage tank directly next to oil storage tank 71963 and observed hydrocarbon emissions from the PRV using the OGI camera (Photo No. 15 and Video No. 8 [AOC 6]. We observed un-combusted hydrocarbon emissions from the dual pressure flare and a heat signature using the OGI camera (Photo No. 13 and Video No. 9)[AOC 7]. I observed an illuminating green light indicating a lit pilot and a temperature reading of 864.88o F at the dual pressure
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Spur Energy Partners, LLC / New Mexico Permian Basin Inspection Date 09/09/2025
flare control box (Photo No. 16 and Photo No. 17). I observed oil residue on the dual pressure flare and the soil around the dual pressure flare (Photo No. 18, Photo No. 19, and Photo No. 20)[AOC 8]. Spur staff stated that there was an upset a few months prior to the inspection, and liquids made their way through the dual pressure flare and spilled onto the ground. I asked if there was a liner under the dual pressure flare and the Spur staff stated there was no liner. We departed the facility at 2:50 pm.
5. Morris Boyd State Com #5H (AIRS No. 350152123)
We arrived at the facility at 2:56 pm (Photo No. 21 and Photo No. 22). The facility was comprised of one (1) operating heater treater and two (2) OOS heater treaters; two (2) VRUs; one (1) VRT; six (6) OOS separators and three (3) new operating separators; one (1) OOS two-phase scrubber and one (1) operating scrubber for the flare and sales line; one (1) dual pressure flare; eight (8) operating oil storage tanks and two (2) OOS oil storage tanks; eight (8) produced water storage tanks; one (1) gunbarrel storage tank; and three (3) slop storage tanks. We observed hydrocarbon emissions from a vent on the VRU for the oil tanks with the OGI camera (Photo No. 23 and Video No. 10)[AOC 9]. Spur stated that the VRUs were rented from Richard Energy, who was responsible for conducting all maintenance activities on the VRUs. We observed hydrocarbon emissions from the top of the oil storage tanks (Photo No. 24 and Video No. 11)[AOC 10]. We departed the facility at 4:18 pm.
6. Live Oak Tank Battery (AIRS No. 350152544)
We arrived at the facility at 4:26 pm (Photo No. 25) and observed third-party contractors onsite installing pipes for the addition of new wells to the site. The facility was comprised of one (1) heater treater; one (1) two-phase flare scrubber; one (1) dual pressure flare; five (5) 3-phase separators; two (2) VRUs; one (1) VRT; three (3) oil storage tanks; three (3) produced water storage tanks; and two (2) half-round storage tanks that were used to separate sand and water for the new wells. We observed un-combusted hydrocarbon emissions from the unlit dual pressure flare (Photo No. 26 and Video No. 12)[AOC 11]. Spur confirmed the observation using their equipment. I observed a temperature reading that displayed a sensor error on the dual pressure flare control box (Photo No. 27). Spur reset the sensor by restarting blower/sensor. The thermocouple temperature increased to 848.7o F (Photo No. 29). The green light on the side of the thermocouple box was illuminated to indicate the pilot was lit on the dual pressure flare after it was reset (Photo No. 28). We observed un-combusted hydrocarbon emissions from the dual pressure flare with a heat signature after it was relit with the OGI camera (Photo No. 30 and Video No. 14). We observed hydrocarbon emissions from the thief hatch on oil storage tank 73875 with the OGI camera (Photos No. 31, Photo No. 32, Photo No. 33, and Video No.13)[AOC 12]. Spur staff confirmed emissions from the oil storage tank 73875 thief hatch using their own equipment. We departed the facility at 5:08 pm.
7. Lakewood Federal Com 4H, 8H, 10H, 20H and 21H Facility (Lakewood) (AIRS No. 350152453)
We arrived at the facility at 5:15 pm (Photo No. 34 and Photo No. 35). The facility was comprised of one (1) heater treater; one (1) two-phase flare scrubber; one (1) dual pressure flare; five (5) 3-phase
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Spur Energy Partners, LLC / New Mexico Permian Basin Inspection Date 09/09/2025
separators; one (1) VRU; one (1) VRT; two (2) oil storage tanks; and two (2) produced water storage tanks. We observed un-combusted hydrocarbon emissions from the unlit dual pressure flare with the OGI camera (Photo No. 37 and Video No. 15)[AOC 13]. I observed a temperature reading of 92.609o F (Photo No. 36). Spur staff turned off main power at the control box to reset the blower and sensor. The thermocouple temperature increased to above the minimum set point of 300 o F. We continued to observe un-combusted hydrocarbon emissions with the OGI camera from the dual pressure flare with a heat signature after Spur reset the blower and sensor (Video No. 16). We departed the facility at 5:33 pm.
Section III AREAS OF CONCERN
The following areas of concern ("AOC") were based on our observations during the inspections ofthe Spur facilities.
1. Hydrocarbon emissions from PRV on produced water storage tank 72238 at Arkansas 23 Fee 3. 2. Un-combusted hydrocarbon emissions from the dual pressure flare at Alto Amms 21 Tank. 3. Hydrocarbon emissions from the manifold PRV above oil storage tank 74538 at Alto Amms 21 Tank. 4. Hydrocarbon emissions from the PRV on produced water storage tank at B&B/Ross Ranch Yeso
Battery. 5. Hydrocarbon emissions from the thief hatch on oil storage tank 71962 at Goodman 22 Battery. 6. Hydrocarbon emissions from the PRV on the produced water storage tank next to oil storage tank
71963 at Goodman 22 Battery. 7. Un-combusted hydrocarbon emissions from a lit dual pressure flare at Goodman 22 Battery. 8. Oil residue was observed on the dual pressure flare and the soil around the flare at Goodman 22
Battery. 9. Hydrocarbon emissions from the VRU for oil storage tanks while it was operating at Morris Boyd State
Com #5. 10. Hydrocarbon emissions from the top of the oil storage tanks at Morris Boyd State Com #5. 11. Un-combusted hydrocarbon emissions from an unlit dual pressure flare at Live Oak Tank Battery. 12. Hydrocarbon emissions from the thief hatch on oil storage tank 73875/OT-1 at Live Oak Tank Battery. 13. Un-combusted hydrocarbon emissions from an unlit dual pressure flare at Lakewood Federal Com 4H,
8H, 10H, 20H and 21H Facility.
EPA Region 6 inspectors Bailey Brown, Cale Chapman, and I conducted a closing conference with Spur representatives John Hermes, Superintendent for Spur; Paolo Bahena, ESG Senior Foreman for Spur; and John Connolly, Consultant for Spur (Appendix 1) at Spur's Lakewood facility at 6:05 pm on September 9, 2025. NMED inspector Mitchell Schatz was in attendance. During the closing conference, I reviewed the thirteen (13) AOCs noted during the inspection, fielded questions from company staff, and provided information about the next steps in the inspection process. We thanked them for their time and completed the closing conference at 6:18 pm.
Section IV FOLLOW UP
On September 16, 2025, I requested the following information via email from Spur: current permits or NOIs; pending permit applications or NOIs; maintenance records; inspection records; control device manufacturing specifications, schematics, and manufacturer recommended maintenance; monitoring
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Spur Energy Partners, LLC / New Mexico Permian Basin Inspection Date 09/09/2025
data; tanks potential to emit 12-month rolling average; total well counts for each facility; and any other relevant documentation for the seven (7) facilities. I also provided Spur electronic copies of the digital photographs and videos that were taken during the inspection. Spur provided the requested records on October 1, 2025. Section V LIST OF APPENDICES Appendix 1 Opening/Pre-Inspection Meeting and Closing Conference/Post Inspection Meeting Lists Appendix 2 - Photograph Log 37 digital photographs taken 09/09/2025 Appendix 3 Video Log 16 OGI camera videos taken 09/09/2025
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Spur Energy Partners, LLC / New Mexico Permian Basin Inspection date 09/09/2025
Appendix 1 Opening / Pre-Inspection Meeting and Closing Conference/Post Inspection Meeting Lists
EPA Inspection Report - Page 9 of 53
Attachment 4
2025 CAA NM PCE Inspections
Spur Energy Partners, LLC
Opening/Pre-Inspection Meeting
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EPA Inspection Report - Page 10 of 53
Closing Confcr<nrc/Po,t-ln, pcction Meeting
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Page 2 of 2
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Spur Energy Partners, LLC / New Mexico Permian Basin Inspection Date 09/09/2025
Appendix 2 Photograph Log
EPA Inspection Report - Page 12 of 53
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 2
Photo No.1
Facility/Location:
I Spur Energy Partners, LLC - Arkansas 23 Fee 3
City: Lakewood
County: I Eddy County I State: I NM
Filename: R0010623.JPG Photographer: Cassandra Lowder
Photo Date: 09/09/2025 I
Witness Name:
I Direction: I N/A Time: I 10:59:09 I Bailey Brown
Description: Facility Sign - The date/time stamp in the image is incorrect
Latitude: 32 .64708
Longitude: -104.45659
Page 1 of 37
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 2
Photo No. 2
Facility/Location:
I Spur Energy Partners, LLC - Arkansas 23 Fee 3
City: Lakewood
County: I Eddy County I State: I NM
Filename: R0010626.JPG Photographer: Cassandra Lowder
Photo Date: 09/09/2025 I
Witness Name:
I Direction: I N/A Time: I 11:02:32 I Bailey Brown
Description: Produced Water Storage Tank 72238 - The date/time stamp on the photo is incorrect.
Latitude: 32 .64708
Longitude: -104.45659
Page 2 of 37
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 2
Photo No. 3
Facility/Location :
I Spur Energy Partners, LLC - Arkansas 23 Fee 3
City: Lakewood
County: I Eddy County I State: I NM
I Direction: I N/A
Filename: R0010629.JPG Photographer: Cassandra Lowder
Photo Date:
09/09/2025 I
Time: I 11:29:47
Witness Name: I Bailey Brown
SEP 07 2025 11:29
Description : Facility-The date stamp on the photo is incorrect.
Latitude: 32 .64708
Longitude: -104.45659
Page 3 of 37
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 2
Photo No . 4
Facility/Location :
I Spur Energy Partners, LLC - Alto Amm 21 Tank
City: Lakewood
County: I Eddy County I State: I NM
I Direction: I N/A
Filename: R0010631.JPG Photographer: Cassandra Lowder
Photo Date:
09/09/2025 I
Time: I 11:59:04
Witness Name: I Bailey Brown
LTO AMM 21 TANK BATTERY E-22-19S-25E 32.647440, -104.480788
Description: Facility Sign - The date/time stamp on the photo is incorrect.
Latitude: 32 .647473
Longitude: -104.480757
Page 4 of 37
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 2
Photo No. 5
Facility/Location :
I Spur Energy Partners, LLC - Alto Amm 21 Tank
City: Lakewood
County: I Eddy County I State: I NM
I Direction: I N/A
Filename: R0010633.JPG Photographer: Cassandra Lowder
Photo Date:
09/09/2025 I
Time: I 12:15:52
Witness Name: I Bailey Brown
Description : Latitude :
Thermocouple temperature at Flare Control Box - The date/time stamp on the photo is
incorrect. 32 .647473
I
Longitude: I -104.480757
Page 5 of 37
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 2
Photo No. 6
Facility/Location :
I Spur Energy Partners, LLC - Alto Amm 21 Tank
City: Lakewood
County: I Eddy County I State: I NM
I Direction: I N/A
Filename: R0010634.JPG Photographer: Cassandra Lowder
Photo Date:
09/09/2025 I
Time: I 12:16:18
Witness Name: I Bailey Brown
Description : Latitude :
Flare Control Box with green light illuminated indicating a lit flare pilot - The date/time
stamp on the photo is incorrect.
32 .647473
I
Longitude: I -104.480757
Page 6 of 37
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 2
Photo No. 7
Facility/Location :
I Spur Energy Partners, LLC - Alto Amm 21 Tank
City: Lakewood
County: I Eddy County I State: I NM
I Direction: I N/A
Filename: R0010635.JPG Photographer: Cassandra Lowder
Photo Date:
09/09/2025 I
Time: I 12:22:45
Witness Name: I Bailey Brown
Description: Facility - The date/time stamp on the photo is incorrect.
Latitude: 32 .647473
Longitude: -104.480757
Page 7 of 37
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 2
Photo No. 8
Facility/Location:
I Spur Energy Partners, LLC - Alto Amm 21 Tank
City: Lakewood
County: I Eddy County I State: I NM
Filename: R0010636.JPG Photographer: Cassandra Lowder
Photo Date: 09/09/2025 I
Witness Name:
I Direction: I N/A Time: I 12:23:42 I Bailey Brown
Description: Oil and Produced Water Storage Tanks - The date/time stamp on the photo is incorrect.
Latitude: 32 .647473
Longitude: -104.480757
Page 8 of 37
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 2
Photo No. 9
Facility/Location:
I Spur Energy Partners, LLC - Alto Amm 21 Tank
City: Lakewood
County: I Eddy County I State: I NM
Filename: R0010638.JPG Photographer: Cassandra Lowder
Photo Date: 09/09/2025 I
Witness Name:
I Direction: I N/A Time: I 12:30:52 I Bailey Brown
Description: Dual Pressure Flare - The date/time stamp on the photo is incorrect.
Latitude: 32 .647473
Longitude: -104.480757
Page 9 of 37
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 2
Photo No. 10
Facility/Location :
I Spur Energy Partners, LLC - B&B / Ross Ranch Yeso Battery
City: Lakewood
County: I Eddy County I State: I NM
I Direction: I N/A
Filename: DSCN1595.JPG Photographer: Cassandra Lowder
Photo Date:
09/09/2025 I
Time: I 12:57:20
Witness Name: I Bailey Brown
sEc. 22P --,9s. 25E
D CO NTY. EW
Description : Facility Sign Latitude: 32.648341
Longitude: -104.479356
Page 10 of 37
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 2
Photo No. 11
Facility/Location:
I Spur Energy Partners, LLC - B&B / Ross Ranch Yeso Battery
City: Lakewood
County: I Eddy County I State: I NM
I Direction: I N/A
Filename: DSCN1601.JPG Photographer: Cassandra Lowder
Photo Date:
09/09/2025 I
Time: I 13:11:49
Witness Name: I Bailey Brown
Description: Produced Water Storage Tank with hydrocarbon emissions from PRV
Latitude: 32 .648341
Longitude: -104.479356
Page 11 of 37
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 2
Photo No. 12
Facility/Location:
I Spur Energy Partners, LLC - Goodman 22 Battery
City: Lakewood
County: I Eddy County I State: I NM
Filename: DSCN1602.JPG Photographer: Cassandra Lowder
Photo Date: 09/09/2025 I
Witness Name:
I Direction: I N/A Time: I 14:20:32 I Bailey Brown
. ENERGY
Description: Facility Sign Latitude: 32 .64524
Longitude: -104.47354
Page 12 of 37
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 2
Photo No. 13
Facility/Location :
I Spur Energy Partners, LLC - Goodman 22 Battery
City: Lakewood
County: I Eddy County I State: I NM
I Direction: I N/A
Filename: DSCN1605.JPG Photographer: Cassandra Lowder
Photo Date:
09/09/2025 I
Time: I 14:30:26
Witness Name: I Bailey Brown
Description : Dual Pressure Flare Latitude: 32 .64524
Longitude: -104.47354
Page 13 of 37
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 2
Photo No. 14
Facility/Location:
I Spur Energy Partners, LLC - Goodman 22 Battery
City: Lakewood
County: I Eddy County I State: I NM
Filename: DSCN1606.JPG Photographer: Cassandra Lowder
Photo Date: 09/09/2025 I
Witness Name:
I Direction: I N/A Time: I 14:37:47 I Bailey Brown
Description: Oil Storage Tank 71962 Latitude: 32 .64524
Longitude: -104.47354
Page 14 of 37
EPA Inspection Report - Page 26 of 53
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 2
Photo No. 15
Facility/Location:
I Spur Energy Partners, LLC - Goodman 22 Battery
City: Lakewood
County: I Eddy County I State: I NM
Filename: DSCN1607.JPG Photographer: Cassandra Lowder
Photo Date: 09/09/2025 I
Witness Name:
I Direction: I N/W Time: I 14:38:51 I Bailey Brown
Description: Produced Water Storage Tank to the right of Oil Storage Tank 71963
Latitude: 32 .64524
Longitude: -104.47354
Page 15 of 37
EPA Inspection Report - Page 27 of 53
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 2
Photo No. 16
Facility/Location:
I Spur Energy Partners, LLC - Goodman 22 Battery
City: Lakewood
County: I Eddy County I State: I NM
Filename: DSCN1608.JPG Photographer: Cassandra Lowder
Photo Date: 09/09/2025 I
Witness Name:
I Direction: I N/A Time: I 14:44:04 I Bailey Brown
Description: Thermocouple Temperature Latitude: 32 .64524
Longitude: -104.47354
Page 16 of 37
EPA Inspection Report - Page 28 of 53
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 2
Photo No. 17
Facility/Location:
I Spur Energy Partners, LLC - Goodman 22 Battery
City: Lakewood
County: I Eddy County I State: I NM
Filename: DSCN1609.JPG Photographer: Cassandra Lowder
Photo Date: 09/09/2025 I
Witness Name:
I Direction: I N/A Time: I 14:44:48 I Bailey Brown
Description: Flare Control Box with green light illuminated indicating a lit flare pilot
Latitude: 32 .64524
Longitude: -104.47354
Page 17 of 37
EPA Inspection Report - Page 29 of 53
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 2
Photo No. 18
Facility/Location:
I Spur Energy Partners, LLC - Goodman 22 Battery
City: Lakewood
County: I Eddy County I State: I NM
Filename: DSCN 1610.J PG Photographer: Cassandra Lowder
Photo Date: 09/09/2025 I
Witness Name:
I Direction: I N/A Time: I 14:46:18 I Bailey Brown
Description: Latitude:
Oil overflow spillage from Dual Pressure Flare 32 .64524
Longitude:
-104.47354
Page 18 of 37
EPA Inspection Report - Page 30 of 53
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 2
Photo No. 19
Facility/Location:
I Spur Energy Partners, LLC - Goodman 22 Battery
City: Lakewood
County: I Eddy County I State: I NM
Filename: Photographer:
DSCN 1611.J PG Cassandra Lowder
Photo Date: 09/09/2025 I
Witness Name:
I Direction: I N/A Time: I 14:46:25 I Bailey Brown
Description: Fluid residue on Dual Pressure Flare stack Latitude: 32 .64524
Longitude: -104.47354
Page 19 of 37
EPA Inspection Report - Page 31 of 53
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 2
Photo No. 20
Facility/Location:
I Spur Energy Partners, LLC - Goodman 22 Battery
City: Lakewood
County: I Eddy County I State: I NM
Filename: DSCN1612.JPG Photographer: Cassandra Lowder
Photo Date: 09/09/2025 I
Witness Name:
I Direction: I N/A Time: I 14:46:41 I Bailey Brown
I
I
I I
I
Description: Fluid residue from Dual Pressure Flare stack, pad, and on ground
Latitude: 32 .64524
Longitude: -104.47354
Page 20 of 37
EPA Inspection Report - Page 32 of 53
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 2
Photo No. 21
Facility/Location:
I Spur Energy Partners, LLC - Morris Boyd State COM #SH
City: Filename: Photographer:
Lakewood DSCN1613.JPG Cassandra Lowder
County:
I Eddy County I State: I NM
I Direction: I N/A
Photo Date: 09/09/2025 I
Time: I 15:02:58
Witness Name: I Bailey Brown
Description: Well Sign used as a Facility Sign Latitude: 32 .64057
Longitude: -104.45889
Page 21 of 37
EPA Inspection Report - Page 33 of 53
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 2
Photo No. 22
Facility/Location:
I Spur Energy Partners, LLC - Morris Boyd State COM #SH
City: Lakewood
County: I Eddy County I State: I NM
I Direction: I N/A
Filename: Photographer:
DSCN1614.JPG Cassandra Lowder
Photo Date:
09/09/2025 I
Time: I 15:33:37
Witness Name: I Bailey Brown
Description: Facility Front Latitude: 32 .64057
Longitude: -104.45889
Page 22 of 37
EPA Inspection Report - Page 34 of 53
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 2
Photo No. 23
Facility/Location:
I Spur Energy Partners, LLC - Morris Boyd State COM #SH
City: Lakewood
County: I Eddy County I State: I NM
I Direction: I N/A
Filename: Photographer:
DSCN1619.JPG Cassandra Lowder
Photo Date:
09/09/2025 I
Time: I 16:06:15
Witness Name: I Bailey Brown
Description: Vapor Recovery Unit for Oil Storage Tanks Latitude: 32 .64057
Longitude: -104.45889
Page 23 of 37
EPA Inspection Report - Page 35 of 53
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 2
Photo No. 24
Facility/Location:
I Spur Energy Partners, LLC - Morris Boyd State COM #SH
City: Lakewood
County: I Eddy County I State: I NM
I Direction: I N/A
Filename: Photographer:
DSCN1621.JPG Cassandra Lowder
Photo Date:
09/09/2025 I
Time: I 16:12:59
Witness Name: I Bailey Brown
Description: Oil Storage Tank Pad Latitude: 32 .64057
Longitude: -104.45889
Page 24 of 37
EPA Inspection Report - Page 36 of 53
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 2
Photo No. 25
Facility/Location:
I Spur Energy Partners, LLC - Live Oak Central Tank Battery
City: Filename: Photographer:
Lakewood DSCN1622.JPG Cassandra Lowder
County:
I Eddy County I State: I NM
I Direction: I N/A
Photo Date: 09/09/2025 I
Time: I 16:39:23
Witness Name: I Bailey Brown
Description: Facility Latitude: 32 .635811
Longitude: -104.469561
Page 25 of 37
EPA Inspection Report - Page 37 of 53
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 2
Photo No. 26
Facility/Location:
I Spur Energy Partners, LLC - Live Oak Central Tank Battery
City: Lakewood
County: I Eddy County I State: I NM
I Direction: I N/A
Filename: DSCN1623.JPG Photographer: Cassandra Lowder
Photo Date:
09/09/2025 I
Time: I 16:40:03
Witness Name: I Bailey Brown
Description: Dual Pressure Flare Latitude: 32 .635811
Longitude: -104.469561
Page 26 of 37
EPA Inspection Report - Page 38 of 53
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 2
Photo No. 27
Facility/Location:
I Spur Energy Partners, LLC - Live Oak Central Tank Battery
City: Lakewood
County: I Eddy County I State: I NM
I Direction: I N/A
Filename: DSCN1624.JPG Photographer: Cassandra Lowder
Photo Date:
09/09/2025 I
Time: I 16:41:55
Witness Name: I Bailey Brown
Description: Thermocouple temperature at Flare Control Box
Latitude: 32 .635811
Longitude: -104.469561
Page 27 of 37
EPA Inspection Report - Page 39 of 53
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 2
Photo No. 28
Facility/Location:
I Spur Energy Partners, LLC - Live Oak Central Tank Battery
City: Lakewood
County: I Eddy County I State: I NM
I Direction: I N/A
Filename: DSCN1625.JPG Photographer: Cassandra Lowder
Photo Date:
09/09/2025 I
Time: I 16:43:16
Witness Name: I Bailey Brown
Description: Flare Control Box with green light illuminated indicating a lit flare pilot
Latitude: 32 .635811
Longitude: -104.469561
Page 28 of 37
EPA Inspection Report - Page 40 of 53
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 2
Photo No. 29
Facility/Location:
I Spur Energy Partners, LLC - Live Oak Central Tank Battery
City: Lakewood
County: I Eddy County I State: I NM
I Direction: I N/A
Filename: DSCN1626.JPG Photographer: Cassandra Lowder
Photo Date:
09/09/2025 I
Time: I 16:44:36
Witness Name: I Bailey Brown
Description: Thermocouple temperature at Flare Control Box
Latitude: 32 .635811
Longitude: -104.469561
Page 29 of 37
EPA Inspection Report - Page 41 of 53
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 2
Photo No. 30
Facility/Location:
I Spur Energy Partners, LLC - Live Oak Central Tank Battery
City: Lakewood
County: I Eddy County I State: I NM
I Direction: I N/A
Filename: DSCN1630.JPG Photographer: Cassandra Lowder
Photo Date:
09/09/2025 I
Time: I 16:58:45
Witness Name: I Bailey Brown
Description: Combustion on Dual Pressure Flare Latitude: 32 .635811
Longitude: -104.469561
Page 30 of 37
EPA Inspection Report - Page 42 of 53
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 2
Photo No. 31
Facility/Location :
I Spur Energy Partners, LLC - Live Oak Central Tank Battery
City: Lakewood
County: I Eddy County I State: I NM
I Direction: I N/A
Filename: DSCN1631.JPG Photographer: Cassandra Lowder
Photo Date:
09/09/2025 I
Time: I 16:59:37
Witness Name: I Bailey Brown
Description: Oil Storage Tank with hydrocarbon emissions.
Latitude: 32 .635811
Longitude: -104.469561
Page 31 of 37
EPA Inspection Report - Page 43 of 53
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 2
Photo No. 32
Facility/Location :
I Spur Energy Partners, LLC - Live Oak Central Tank Battery
City: Lakewood
County: I Eddy County I State: I NM
I Direction: I N/A
Filename: DSCN1632.JPG Photographer: Cassandra Lowder
Photo Date:
09/09/2025 I
Time: I 16:59:52
Witness Name: I Bailey Brown
Description : Oil Storage Tank 73875 Latitude: 32 .635811
Longitude: -104.469561
Page 32 of 37
EPA Inspection Report - Page 44 of 53
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 2
Photo No. 33
Facility/Location:
I Spur Energy Partners, LLC - Live Oak Central Tank Battery
City: Lakewood
County: I Eddy County I State: I NM
I Direction: I N/A
Filename: Photographer:
DSCN1633.JPG Cassandra Lowder
Photo Date:
09/09/2025 I
Time: I 17:01:27
Witness Name: I Bailey Brown
Description: Top of Oil Storage Tank 73875 Latitude: 32 .635811
Longitude: -104.469561
Page 33 of 37
EPA Inspection Report - Page 45 of 53
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 2
Photo No. 34
Facility/Location :
I Spur Energy Partners, LLC - Lakewood Federal Com
City: Lakewood
County: I Eddy County I State: I NM
I Direction: I N/A
Filename: DSCN1635.JPG Photographer: Cassandra Lowder
Photo Date:
09/09/2025 I
Time: I 17:20:43
Witness Name: I Bailey Brown
LAKEIOOD FEDERAL COM 4R BR lOR 20H AND 21H FACILITY
500' FSL .1710' FEL O-27-19S-25E
NMNM0 .5 0 4 3 6 4 8
D.Y COUNTY. NM
ONTACT #: 1-888-778-7034
Description : Facility Sign Latitude: 32 .625808
Longitude: -104.469155
Page 34 of 37
EPA Inspection Report - Page 46 of 53
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 2
Photo No. 35
Facility/Location:
I Spur Energy Partners, LLC - Lakewood Federal Com
City: Lakewood
County: I Eddy County I State: I NM
Filename: Photographer:
DSCN1636.JPG Cassandra Lowder
Photo Date: 09/09/2025 I
Witness Name:
I Direction: I N/A Time: I 17:24:02 I Bailey Brown
Description: Facility Latitude: 32 .625808
Longitude: -104.469155
Page 35 of 37
EPA Inspection Report - Page 47 of 53
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 2
Photo No. 36
Facility/Location:
I Spur Energy Partners, LLC - Lakewood Federal Com
City: Lakewood
County: I Eddy County I State: I NM
Filename: DSCN1638.JPG Photographer: Cassandra Lowder
Photo Date: 09/09/2025 I
Witness Name:
I Direction: I N/A Time: I 17:25:44 I Bailey Brown
Description: Thermocouple temperature at Flare Control Box
Latitude: 32 .625808
Longitude: -104.469155
Page 36 of 37
EPA Inspection Report - Page 48 of 53
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 2
Photo No. 37
Facility/Location:
I Spur Energy Partners, LLC - Lakewood Federal Com
City: Lakewood
County: I Eddy County I State: I NM
Filename: Photographer:
DSCN1639.JPG Cassandra Lowder
Photo Date: 09/09/2025 I
Witness Name:
I Direction: I N/A Time: I 17:27:15 I Bailey Brown
Description: Unlit Dual Pressure Flare Latitude: 32 .625808
Longitude: -104.469155
Page 37 of 37
EPA Inspection Report - Page 49 of 53
Spur Energy Partners, LLC - New Mexico Permian Basin Inspection Date 09/09/2025
Appendix 3 Video Log
EPA Inspection Report - Page 50 of 53
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Video Log
Appendix 3
Location : Spur Energy Partners, LLC- Multiple New Mexico Permian Basin Facilities
City: near Lakewood
I County: Eddy County
I State: New Mexico
Video No.: Facility Name: Video File Name: Date of Video: Time of Video: Videographer:
Description:
1 Arkansas 23 Fee 3 FLIR0064.mp4 09/09/2025 11:10 am Bailey Brown Hydrocarbon emissions from pressure relief valve on produced water storage tank 72238
Video No.: Facility Name: Video File Name: Date of Video: Time of Video: Videographer:
Description:
2 Arkansas 23 Fee 3 FLIR0065.mp4 09/09/2025 11:15 am Bailey Brown Emissions from pressure relief valve on produced water tank
Video No. : Facility Name: Video File Name: Date of Video: Time of Video: Videographer:
Description:
3 Alto Amm 21 Tank Battery FLIR0066.mp4 09/09/2025 12:03 pm Cale Chapman Emissions from Dual Pressure Flare
Video No. : Facility Name: Video File Name: Date of Video: Time of Video: Videographer:
Description:
4 Alto Amm 21 Tank Battery FLIR0067.mp4 09/09/2025 12:07 pm Cale Chapman Emissions from Dual Pressure Flare
Page 1 of 4
EPA Inspection Report - Page 51 of 53
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Video Log
Appendix 3
Location : Spur Energy Partners, LLC- Multiple New Mexico Permian Basin Facilities
City: near Lakewood
I County: Eddy County
I State: New Mexico
Video No.: Facility Name: Video File Name: Date of Video: Time of Video: Videographer:
Description :
5 Alto Amm 21 Tank Battery FLIR0068.mp4 09/09/2025 12:14 pm Cale Chapman Hydrocarbon emissions from manifold pressue relief valve above oil storage tank 74538
Video No.: Facility Name: Video File Name: Date of Video: Time of Video: Videographer:
Description :
6 B&B / Ross Ranch Yeso Battery FLIR0070.mp4 09/09/2025 1:10 pm Cale Chapman Hydrocarbon emissions from pressure relief valve on produced water storage tank
Video No.: Facility Name: Video File Name: Date of Video: Time of Video: Videographer:
Description :
7 Goodman 22 Tank Battery FLIR0071 .mp4 09/09/2025 3:03 pm Cale Chapman Emissions from the thief hatch on oil tank
Video No.: Facility Name: Video File Name: Date of Video: Time of Video: Videographer:
Description :
8 Goodman 22 Tank Battery FLIR0072 .mp4 09/09/2025 2:36 pm Cale Chapman Emissions from pressure relief valve on produced water tank
Page 2 of 4
EPA Inspection Report - Page 52 of 53
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Video Log
Appendix 3
Location : Spur Energy Partners, LLC- Multiple New Mexico Permian Basin Facilities
City: near Lakewood
I County: Eddy County
I State: New Mexico
Video No.: Facility Name: Video File Name: Date of Video: Time of Video: Videographer:
Description :
9 Goodman 22 Tank Battery FLIR0073.mp4 09/09/2025 2:44 pm Cale Chapman Emissions from Dual Pressure Flare (heat signature in video)
Video No.: Facility Name: Video File Name: Date of Video: Time of Video: Videographer:
Description :
10 Morris Boyd State Com #SH FLIR0075.mp4 09/09/2025 4:08 pm Cale Chapman Emissions from Vapor Recovery Unit (VRU for oil tank battery; VRU operating prior to video)
Video No.: Facility Name: Video File Name: Date of Video: Time of Video: Videographer:
Description :
11 Morris Boyd State Com #SH FLIR0076.mp4 09/09/2025 4:10 pm Cale Chapman Hydrocarbon emissions from the top of an oil storage tank
Video No.: Facility Name: Video File Name: Date of Video: Time of Video: Videographer:
Description :
12 Live Oak Central Tank Battery FLIR0077.mp4 09/09/2025 4:33 pm Cale Chapman Un-combusted hydrocarbons emissions from an unlit Dual Pressure Flare
Page 3 of 4
EPA Inspection Report - Page 53 of 53
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Video Log
Appendix 3
Location : Spur Energy Partners, LLC- Multiple New Mexico Permian Basin Facilities
City: near Lakewood
I County: Eddy County
I State: New Mexico
Video No.: Facility Name: Video File Name: Date of Video: Time of Video: Videographer:
Description :
13 Live Oak Central Tank Battery FLIR0078.mp4 09/09/2025 4:55 pm Bailey Brown Hydrocarbon emissions from thief hatch on oil storage tank 73875
Video No.: Facility Name: Video File Name: Date of Video: Time of Video: Videographer:
Description :
14 Live Oak Central Tank Battery FLIR0079.mp4 09/09/2025 5:00 pm Cale Chapman Hydrocarbon emissions from Dual Pressure Flare
Video No. : Facility Name:
Video File Name: Date of Video: Time of Video: Videographer: Description :
15 Lakewood Federal Com 4H, 8H, 10H, 20H and 21H Facility FLIR0080.mp4 09/09/2025 5:22 pm Cale Chapman Un-combusted hydrocarbon emissions from an unlit Dual Pressure Flare
Video No.: Facility Name:
Video File Name: Date of Video: Time of Video: Videographer: Description :
16 Lakewood Federal Com 4H, 8H, 10H, 20H and 21H Facility FLIR0081 .mp4 09/09/2025 5:28 pm Cale Chapman Un-combusted hydrocarbon emissions from High Pressure/Low Pressure Flare after flare pilot was lit
Page 4 of 4