Document rBv2wmBm6bOnrZqnMpqze5ELa

EPA Inspection Report - Page 1 of 53 f t E A ~ UnitedStates .._..,~ Environm ental Protectio n ,,.. 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 ...,,!:1'"'11y -"'!:I' 1,;;;u uy JrUYIII..... ........ 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 2 EPA Inspection Report - Page 3 of 53 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 EPA Inspection Report - Page 4 of 53 Spur Energy Partners, LLC / New Mexico Permian Basin Inspection Date 09/09/2025 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 4 EPA Inspection Report - Page 5 of 53 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 5 EPA Inspection Report - Page 6 of 53 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 6 EPA Inspection Report - Page 7 of 53 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 7 EPA Inspection Report - Page 8 of 53 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 Commence opcning/~inspection meeting. .. -------------Time: b"240 Page 3 of82 Name r. {A1\ (bWVl /vi ,1-c),e./1 Sc/,c.,,h :TUhn> er M e.S -:rf' Jl)hri c.~..,,,.,_!S Title Representing Telephone No. Email erp- 12<.Q N/Yl0 5 P~r s~Pu- ,.J.,,}~.,;,- S~v- !:.RDI .PA P-t ~ <; '\JVG'.PA P.l. y - - - + -:;-_, r,,;,-1,,-I f' J "---,.,.,,,..,, t fl'vr,.~;,t'-",',,.._-c,G9h- 1.-Z~-.S13-1'33 Joh_.,.~ erJ, /i,( ""' Initials / Date: ffi Page 1 of 2 EPA Inspection Report - Page 10 of 53 Closing Confcr<nrc/Po,t-ln, pcction Meeting Commence closing conference/post-inspection meetin11.....................................Time: lp u< y,V'\ Name (2-,_1~ . rouJV'\ t-ALE <-HAPMAN Title 11'1. ' \u'(" I-f?r<I~ - n& ~ r Representing 'Gf C\ - .~~ EPA R.~ Telephone No. Attachment 4 Email Jmtials / Date: .Lf?-'tJ'--~' q fq { Page 2 of 2 EPA Inspection Report - Page 11 of 53 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 EPA Inspection Report - Page 13 of 53 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 EPA Inspection Report - Page 14 of 53 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 EPA Inspection Report - Page 15 of 53 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 EPA Inspection Report - Page 16 of 53 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 EPA Inspection Report - Page 17 of 53 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 EPA Inspection Report - Page 18 of 53 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 EPA Inspection Report - Page 19 of 53 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 EPA Inspection Report - Page 20 of 53 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 EPA Inspection Report - Page 21 of 53 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 EPA Inspection Report - Page 22 of 53 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 EPA Inspection Report - Page 23 of 53 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 EPA Inspection Report - Page 24 of 53 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 EPA Inspection Report - Page 25 of 53 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