Despite Republic having seen no more than 6 exceedances in the recent SEM reports supplied ahead of the inspection that included penetration monitoring, including reports with 0 exceedances, he identified 61 points in exceedance of 500 ppm, including 21 points above 10,000 ppm, with 26 exceedances at gas collection wells that Republic should have specifically been monitoring on a quarterly basis since the Oregon State Plan became effective in November 2020.