Document wqVoarbbdGOk8XgQRo51bDDN6

WPX- Various Well Sites Partial Compliance Evaluation (PCE) On-Site Clean Air Act (CAA) Inspections Inspection Date: June 12 - 15, 2023 Inspection Report Date: June 27, 2023, DRAFT EPA Representatives: Alexis North, Katelyn Bergl, Youn Joo Kim Tribal Representatives: Dwight Bruce, Jr Talon Two Crow Company Representatives: None onsite during inspections. Inspection Report Prepared By: Alexis North Inspection Report Reviewed By: Katelyn Bergl, Youn Joo Kim, Scott Patefield SCOTT PATEFIELD Digitally signed by SCOTT PATEFIELD Date: 2023.07.20 10:26:32 -06'00' Applicable Rules: Fort Berthold Indian Reservation (Mandan, Hidatsa and Arikara Nation), North Dakota (Fort Berthold FIP) Compliance Assistance None 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 Enforcement History No Clean Air Act enforcement cases settled in the last five years. Areas of Concern 1. The EPA detected hydrocarbon emissions from the storage tanks at the following well pads: x WPX- Dancing Bull 16-2HC, 16-2HD, 16-21-2 x WPX- Adam Good Bear 15-22H, 15-22W, 15-22X, State of ND 10-3HA, 10-3W x WPX- MC MHA 14-11TFH, 11H, 2TFH, 2H, 3TFH 2. The EPA detected hydrocarbon emissions from the closed vent system at the following well pad: x WPX- FBIR Guy Blackhawk 24X-27D, 24X-27H, 24X-27C, 24X-27G 3. The EPA detected hydrocarbon emissions from an unlit flare at the following well pads: x WPX- Two Shields Butte 13-22-16-1H3, 13-22-33-16H, 13-22-16-1H x WPX- Tri Unit Pad 4. The EPA detected visible smoke using Method 22 at the following well pads: x Night Hawk 6-34HUL, 34HD, 34HT, 34HC, 34HY x WPX- Tri Unit Pad (Method 22) x WPX- MC MHA 14-11TFH, 11H, 2TFH, 2H, 3TFH (Method 22) Page 1 of 9 x WPX- Moccasin Creek 16-10-3-3H, 3H3 (Method 22) 5. The EPA detected unburned hydrocarbon (UBHC) emissions from operating utility flares at the following well pads: x WPX- Tri Unit Pad x WPX- MC MHA 14-11TFH, 11H, 2TFH, 2H, 3TFH x WPX- MC MHA 24-10-2TFH, 2H See Table 1 below for more details regarding inspected locations and Tables 2 & 3 for inspection details for all pads. General Source Information Unannounced well site inspections were conducted jointly by U.S. EPA and Fort Berthold Indian Reservation (FBIR) Tribal inspectors (inspectors) on June 12-15, 2023, at multiple WPX facilities located on the FBIR. The EPA evaluated each WPX 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 regulations listed below. EPA's geospatial mapping of air pollution (GMAP) van also collected data using OGI and air sampling equipment at WPX facilities from June 12-15, 2023. Data collected and observations made by GMAP EPA personnel are also included in this inspection report, where relevant and when available. Table 1 lists well pad specifics for each inspection including latitude/longitude location as well as time of entry. The well information located in the tables below is from the North Dakota Industrial Commission (NDIC) well index located online at https://www.dmr.nd.gov/oilgas/. Table 1: List of Facilities Inspected June 12-15, 2023 Pad Name Latitude Longitude Elk 16-2H, 15-21HW, 16-21HX, 17-20HE Dancing Bull 16-2HC, 16-2HD, 1621-2 Adam Good Bear 15-22H, 15-22W, 15-22X, State of ND 10-3HA, 103W State of ND 10-3H George Evans 11-2HZ, 11-2HC, 11-2HD, 14-23HZ, 14-23HC, 1423HD Two Shields Butte 14-21-16-2H3, 14-21-33-15H, 14-21-16-2HS, 14- 47.81794 47.82027 47.81716 47.82 47.82014 47.70341 -102.466 -102.458 -102.446 -102.441 -102.414 -102.461 Inspection Time In Date 6/12/2023 13:51 6/12/2023 14:00 6/12/2023 6/12/2023 14:16 14:28 6/12/2023 6/13/2023 14:34 9:29 Page 2 of 9 21-33-15H3, 14-21-4H, 14-21-3316H3 Two Shields Butte 13-22-16-1H3, 13-22-33-16H, 13-22-16-1H Meadow Lark 3-34HA, HB, QL FBIR Guy Blackhawk 24X-27D, 24X-27H, 24X-27C, 24X-27G Night Hawk 6-34HUL, 34HD, 34HT, 34HC, 34HY Two Shields Butte 14-33-25H, 6H Skunk Creek 1-12-H TRI UNIT PAD (21 wells) MC MHA 14-11TFH, 11H, 2TFH, 2H, 3TFH Moccasin Creek 16-10-3-3H, 3H3 MC MHA 24-10-2TFH, 2H Wounded Face 14-15HC, 15HX, 15HB, 15HW, 15HEL, 15HC Patricia Kelly 2-1HA, 1HS, 1HX, 1HB, 1HUL Crosby Chase 2-1HIL, 2-1HG, 21HY, 2-1HZ 47.70373 47.68943 47.69041 47.68595 47.67551 47.67551 47.59166 47.56046 47.56043 47.56036 47.63307 47.84281 47.83883 -102.449 -102.446 -102.439 -102.431 -102.462 -102.462 -102.453 -102.498 -102.504 -102.516 -102.639 -102.696 -102.696 6/13/2023 6/13/2023 6/13/2023 6/13/2023 6/13/2023 6/13/2023 6/14/2023 6/14/2023 6/14/2023 6/14/2023 6/14/2023 6/15/2023 6/15/2023 9:48 10:09 10:35 10:58 12:08 12:37 9:00 10:15 10:45 11:50 15:25 10:43 10:56 Tables 2 and 3 at the end of this report include the inspections details. Table 2 includes well head counts and storage tank details. Table 3 contains control device and AVO observations. Each well pad inspection followed the approach below: 1. Park on the well pad. 2. Make notations on the site operation including the number of each major type of site process equipment present (e.g., total number of storage tanks, number of oil tanks, number of water tanks, number of tank emission control devices). 3. Note any AVO indications of emissions from the storage tanks closed vent system and control devices. 4. Survey the site operations in infrared modes (auto, manual, and/or high-sensitivity modes), looking for emissions escaping the storage tank closed vent system, and control devices. 5. Observe control devices (enclosed combustor or utility flare) for visible emissions. Fort Berthold FIP Applicability Based on drilling information reported to the NDIC well index by WPX, the facilities listed in Table 1 were completed after the August 12, 2007, applicability date (per 40 C.F.R. 49.4161) and are producing from the Bakken Pool (per 40 C.F.R. 49.4163(a)(1)) and are thus subject to the Fort Berthold FIP. Closed Vent System Equipment Requirements [49.4165(b)] Per 49.4165(b)(1), "Each closed-vent system must route all produced natural gas and natural gas emissions from production and storage operations to the natural gas sales pipeline or the control devices...". The EPA, using an OGI camera, detected natural gas emissions from production and storage tanks at four out of 19 well pads evaluated. See Area of Concern #1 and #2 above. Page 3 of 9 Utility Flare Requirements [49.4165(c)] Per 49.4165(c)(6)(vi), "The owner or operators must ensure that each enclosed combustor and utility flare is maintained in a leak-free condition." The EPA, using an OGI camera, detected emissions at two out of the 19 well pads evaluated. See Area of Concern #3 above. Per 49.4165(c)(6)(vii), "The owner or operator must ensure that each enclosed combustor and utility flare is operated with no visible smoke emissions." Per 49.4166(g)(3) and EPA Reference Method 22, the EPA noted black smoke emissions at four out of 19 well pads evaluated. See Area of Concern #4 above. Per 49.4165(c)(1), "For each enclosed combustor or utility flare, the owner or operator must follow the manufacturer's written operating instructions, procedures and maintenance schedule to ensure good air pollution control practices for minimizing emissions." The EPA noted UBHC emissions indicating poor air pollution control practices from lit flares at three out of 19 well pads evaluated. See Area of Concern #5 above. NSPS OOOOa Applicability Based on well production information reported by WPX to the NDIC and the date of construction, reconstruction, or modification of the storage vessels, the EPA believes that storage vessels and associated emissions control equipment at four of the 19 oil and natural gas production facilities identified in Table 1 are subject to requirements for storage vessel affected facilities in NSPS OOOOa: x FBIR Guy Blackhawk 24X-27D, 24X-27H, 24X-27C, 24X-27G x Night Hawk 6-34HUL, 34HD, 34HT, 34HC, 34HY x Tri Unit Pad x Crosby Chase 2-1HIL, 2-1HG, 2-1HY, 2-1HZ Closed Vent System Equipment Requirements [60.5411a(c)] Per 60.5411a(c)(1), owners and operators must "Design the closed vent system to route all gases, vapors, and fumes emitted from the material in the storage vessel to a control device that meets the requirements specified in 60.5412(c) and (d), or to a process." The EPA observed emissions from the closed vent system at the FBIR Guy Blackhawk 24X-27D, 24X-27H, 24X-27C, 24X-27G and Tri Unit well pads. See Area of Concern #2 and #3 above. Control Device Requirements [60.5412a(d)] Per 60.5412a(d)(1)(iii), owners and operators must, "Operate the combustion control device with no visible emissions, except for periods not to exceed a total of 1 minute during any 15-minute period." The EPA observed black smoke continuously for more than a minute (per Method 22) at the Tri Unit and Night Hawk 6-34HUL, 34HD, 34HT, 34HC, 34HY well pads. See Area of Concern #4 above. Page 4 of 9 Table 2: Inspection Details: Well Head Count and Storage Tanks Well Name Elk 16-2H, 15-21HW, 16-21HX, 17-20HE # Well Heads (WH) 4 # Total Storage Tanks 13 Dancing Bull 16-2HC, 16-2HD, 16-21-2 3 18 Adam Good Bear 15-22H, 15-22W, 15-22X, State of ND 10-3HA, 10-3W 4 13 State of ND 10-3H 1 3 George Evans 11-2HZ, 11-2HC, 11-2HD, 14-23HZ, 14-23HC, 14-23HD 6 21 Two Shields Butte 14-21-16-2H3, 14-21-33- 15H, 14-21-16-2HS, 14-21-33-15H3, 14-21- 4H, 14-21-33-16H3 6 20 Two Shields Butte 13-22-16-1H3, 13-22-33- 16H, 13-22-16-1H 3 14 Meadow Lark 3-34HA, HB, QL 4 12 FBIR Guy Blackhawk 24X-27D, 24X-27H, 24X-27C, 24X-27G 8 14 Night Hawk 6-34HUL, 34HD, 34HT, 34HC, 34HY 5 15 Two Shields Butte 14-33-25H, 6H 2 10 Skunk Creek 1-12-H 1 4 TRI UNIT PAD (21 wells) 21 - Not Co- located with CTB 91 MC MHA 14-11TFH, 11H, 2TFH, 2H, 3TFH 5 26 Moccasin Creek 16-10-3-3H, 3H3 2 10 Tank Emissions Observations File ID None Emissions from bull plug/ equalizer line on HC-2 tank. This emission was reported out to Josh Jarmin (production foreman). Tank 3, intermittent leak from vent line was observed. GMAP detected the leak and recorded it. None MOV_3269 None None None 2 PRVs, small puffs of emission were observed. Unable to see via IR. None None None None Tanks were not in use and empty at time of inspection. Strong odor, described as "B.O. Smell", present facility-wide. Northernmost Produced water tank, observed small, continuous venting of emissions. None Page 5 of 9 MOV_0171 MOV_3299, MOV_3300, MOV_0200 MC MHA 24-10-2TFH, 2H 7 Wounded Face 14-15HC, 15HX, 15HB, 15HW, 15HEL, 15HC 5 Patricia Kelly 2-1HA, 1HS, 1HX, 1HB, 1HUL 5 Crosby Chase 2-1HIL, 2-1HG, 2-1HY, 2- 1HZ 6 12 None 10 None No emissions, slight "body odor" chemical 15 smell. 14 None Page 6 of 9 Table 3: Inspection Details: Control Devices and AVO Well Name Combustion Device (CD) Type Elk 16-2H, 15-21HW, 16-21HX, 17-20HE 1 air assisted Steffes Dancing Bull 16-2HC, 16-2HD, 1621-2 Adam Good Bear 15-22H, 15-22W, 15-22X, State of ND 10-3HA, 103W State of ND 10-3H George Evans 11-2HZ, 11-2HC, 11-2HD, 14-23HZ, 14-23HC, 1423HD Two Shields Butte 14-21-16-2H3, 14-21-33-15H, 14-21-16-2HS, 1421-33-15H3, 14-21-4H, 14-21-3316H3 1 air assisted Steffes 1 air assisted Steffes 1 air assisted Steffes 1 air assisted Steffes 1 air assisted Steffes, 1 HP Steffes Two Shields Butte 13-22-16-1H3, 13-22-33-16H, 13-22-16-1H Meadow Lark 3-34HA, HB, QL 1 air assisted Steffes, 1 hi/lo Steffes 1 air assisted Steffes, 1 hi/lo Steffes FBIR Guy Blackhawk 24X-27D, 24X-27H, 24X-27C, 24X-27G 1 air assisted Steffes, 1 hi/lo Steffes Visible flame CD? Yes Yes Yes Yes Yes Yes/No Yes/No Yes Yes AVO Continuous flaring and intermittent black smoke was observed Continuous flaring and intermittent black smoke was observed Continuous flaring and intermittent black smoke was observed The air assisted Steffes was lit and continuously flaring. HP Steffes was unlit, not operating and without any emissions. Air assisted Steffes was continuously flaring. Hi/Lo Steffes was unlit and with unburned hydrocarbon emissions (UBHC). As the inspectors were leaving the site, the pilot light became lit. No IR of unlit flare. Continuous flaring and intermittent black smoke was observed from both flares. Both flares were continuously flaring. Intermittent emissions were detected from the elbow union leading to the flare. File ID MOV_0167, IR_0168 MOV_0170 MOV_0174 Smoke from CD? Yes Yes Yes No No No No Yes No Page 7 of 9 Night Hawk 6-34HUL, 34HD, 34HT, 34HC, 34HY Two Shields Butte 14-33-25H, 6H Skunk Creek 1-12-H TRI UNIT PAD (23 wells) MC MHA 14-11TFH, 11H, 2TFH, 2H, 3TFH Moccasin Creek 16-10-3-3H, 3H3 MC MHA 24-10-2TFH, 2H Wounded Face 14-15HC, 15HX, 15HB, 15HW, 15HEL, 15HC 1 air assisted Steffes, 1 HP Steffes 1 hi/lo air assisted Steffes 1 hi/lo air assisted Steffes 3 hP air assisted flares 4 hi/lo flares 1 hP Steffes 2 hi/lo air assisted flares, 2 hP Steffes flares 1 hi/lo air assisted Steffes 1-hP 2-pronged flare 1-hP air assisted flare 1-hP Steffes 2-air assisted lP Flares Yes Yes Yes hi/lo 3rd from West Unlit. Others - Yes Y Y Yes Continuous flaring and continuous black smoke was observed from both flares HP (3 prong) Steffes and Lo/Hi (2 prong) Steffes. Yes Downward slope of the line DC_0183, towards the flare was DC_0184 observed. Burnt cup was (blank) documented on top of the flare. No No 1. hi/lo 3rd from west: Flare 1. unlit and venting UBHC MOV_3289, directly. MOV_3290 2. SW hP air assist: Flame 2. present, large plume of UBHC MOV_3291 trailing from flare. 3. 3. NE hP air assist: Flame MOV_3292 present, large plume of UBHC trailing from flare. VE (Black smoke) observed for >1 continuous minute per Method 22. Yes 1. hi/lo western flare (#2) - 1. DC_3298 black smoke observed > 1 2. continuous minute per Method DC_3297, 22 MOV_3303 2. hi/lo western flare (#2) - 3. UBHC Trailing plume. DC_3296 Enormous flame. 3. hi/lo eastern flare (#1) - temperature monitor read 79 degrees. Yes Black smoke observed > 1 continuous minute per Method 22 Yes Observed a trailing plume of MOV_0208 UBHC from the hP air assisted flare No Yes No Page 8 of 9 Patricia Kelly 2-1HA, 1HS, 1HX, 1HB, 1HUL Crosby Chase 2-1HIL, 2-1HG, 21HY, 2-1HZ 3 hi/lo Steffes Yes 1 hi/lo Steffes 1- 3 pronged Steffes Yes Read temps on 3 flare panels: IR_3324, 1525, 1618, 1489 DC_3325 No IR_3328, Flames present DC_3329 No Page 9 of 9