Document zxGL406GdwLmRoeQyy69x2Dg

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 SUBJECT: FROM: THRU: TO: CLEAN AIR ACT INSPECTION REPORT Infinity Natural Resources (INR) Jenkins Well Pad Victoria Nelson, Environmental Engineer AECAB (MI/WI) Sarah Marshall, Section Supervisor AECAB (MI/WI) File BASIC INFORMATION Facility Name: Infinity Natural Resources (INR) Jenkins Well Pad Facility Location: 2070 Kensington Rd Carrollton, Ohio 44615 (40.608147, -81.061941) Date of Inspection: August 29, 2022 EPA Inspectors: 1. Victoria Nelson, Environmental Engineer 2. Jacob Herbers, Environmental Engineer 3. Sasha Letuchy, Environmental Engineer 4. Manoj Patel, Environmental Engineer 5. Laura Neudorf, Environmental Engineer Other Attendees: 1. Bill Veigel, Production Manager, INR 2. Larry Barr, Supervisor, INR Contact Email Address: BVeigel@infinitynr.com Purpose of Inspection: To assess compliance with the facility's Permit-to-Install and Operate, and the Clean Air Act Facility Type: Oil and gas well pad Regulations Central to Inspection: NSPS Subpart OOOO/OOOOa - Standards of Performance for Crude Oil and Natural Gas Facilities Arrival Time: 15:30 EDT Departure Time: 15:45 EDT Inspection Type: Unannounced Inspection Announced Inspection OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Small Business Resource Information Sheet not provided. Reason: Not a small business Provided CBI warning to facility The following information was obtained verbally from Bill Veigel and Larry Barr, unless otherwise noted. Process Description: At the well pad, an oil/gas/water emulsion is extracted from the formation through two sets of three wells each, totaling 6 well heads on-site. Each well flows into a sand trap, a gas processing unit (GPU), and a three-phase separator. From there, the oil/condensate is sent through a heater treater and then into two tanks, and the produced water is sent into one tank. The tanks feed into two vapor recovery units (VRUs), and excess vapors are sent to the combustor, which is the primary emission control device. The gas is sent to pipeline for further processing. There were approximately 12 temporary brine/frack tanks on site. Staff Interview: Facility staff said that one of the sets of well heads is newer than the other. TOUR INFORMATION EPA Tour of the Facility: Yes Data Collected and Observations: EPA observed a combustor flaring and emitting on the East end on the site. EPA observed rusty drip marks on the produced water tank's pressure relief device (PRD). With the FLIR camera, EPA inspectors observed emissions from the two conservation vents on the tank battery, and from the produced water tank's thief hatch. Photos and/or Videos: were taken during the inspection. Page 2 of 4 Field Measurements: were not taken during this inspection. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Concerns: EPA had concerns about design and operation of the vapor capture and control systems at the facilities, which we discussed with INR representatives. EPA's concerns stemmed from observed emissions from components atop the tank battery. DIGITAL SIGNATURES VICTORIA Digitally signed by VICTORIA NELSON Date: 2022.10.25 Report Author: _N_E_L__S_O__N_____1_6:_30_:0_1 -_05_'0_0'_____________ SARAH Digitally signed by SARAH MARSHALL Date: 2022.10.26 Section Supervisor: _M_A__R_S__H_A__L_L__1_0:_03_:1_5_-0_5'0_0_' _____________ Page 3 of 4 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: Jacob Herbers 2. Archival Record Location: Region 5 Electronic Records Center Image # 1 2 File Name IMG_0212.JPG IMG_0213.JPG Date and Time 2022:08:29 15:30:50 EDT 2022:08:29 15:30:57 EDT 3 IMG_0214.JPG 2022:08:29 15:31:02 EDT 4 IMG_0215.JPG 2022:08:29 15:31:26 EDT 5 IMG_0216.JPG 2022:08:29 15:32:34 EDT 6 IMG_0217.JPG 2022:08:29 15:36:51 EDT 7 IMG_0218.JPG 2022:08:29 15:39:04 EDT 8 IMG_0219.JPG 2022:08:29 15:42:32 EDT Description of Image Tank battery and GPU/sand trap GPU/sand trap on the other side of the tank battery Temporary brine/frack tank batteries New drilling area PRD on produced water tank with rusty drip marks Tank battery nameplate New drilling area New drilling area and combustor APPENDIX B: DIGITAL VIDEO LOG 1. Inspector Name: Victoria Nelson, Jacob Herbers, Sasha Letuchy 2. Archival Record Location: Region 5 Electronic Records Center Video # 1 2 3 4 5 File Name MOV_2640.mp4 MOV_2815.mp4 MOV_2816.mp4 MOV_2817.mp4 MVI_0220.mp4 Date and Time 8/29/22 15:29 EDT 8/29/22 15:29 EDT 8/29/22 15:30 EDT 8/29/22 15:32 EDT 8/29/22 15:44 EDT Description of Video FLIR video of combustor FLIR video of emissions from the conservation vent between the two condensate tanks FLIR video of emissions from the conservation vent between the produced water tank and a condensate tank FLIR video of emissions from the thief hatch on the produced water tank Visible spectrum video of intermittent smoke from the combustor stack Page 4 of 4