Document 0LwEJ77gYmLMR4y4y8O6OXgaO

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 04/18/2025 Water (CWA) Water (CWA) Brine Program (Oil & Gas Inspection) Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: T2 Operating Corporation Buckner #D-5 SWD Off U.S. Highway 82 at 33.36356, -93.415611 Buckner, AR 71827 1800 Wazee Street, Suite 318 Denver, CO 80202 Lafayette County 303-579-1129 Gilbert Thompson t.farel@tmdh-energy.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: N/A ARU002313 N/A 211111 1311 Personnel participating in inspection: Uma Lad EPA / Region 6 ECDW Kerri McCabe EPA / Region 6 ECDW Michael Blaha EPA / Region 6 ECDW Inspector / Enforcement Officer Inspector / Enforcement Officer Inspector / Enforcement Officer EPA Lead Inspector Signature/Date UMA LAD Uma Lad Digitally signed by UMA LAD Date: 2025.06.09 14:19:12 -05'00' Date Supervisor Signature/Date JEANNE ECKHART Date: 2025.06.10 14:52:11 -05'00' Digitally signed by JEANNE ECKHART Jeanne Eckhart Date 6ENFORM-019-R8.2 (02/12/2020) 1 Section I - INTRODUCTION T2 Operating Corporation / Buckner #D-5 SWD (ARU002313 / CWA) Inspection Date 04/18/2025 PURPOSE OF THE INSPECTION Environmental Protection Agency (EPA) Region 6 inspectors Uma Lad, Kerri McCabe, and Michael Blaha arrived at the T2 Operating Corporation / Buckner #D-5 SWD ("facility"), located off U.S. Highway 82 at 33.36356, -93.415611, at 8:17 AM on 04/18/2025 for an unannounced inspection. No facility representatives were present at the time of the inspection. The inspection was conducted by the authority of the Clean Water Act (CWA) to determine compliance with EPA regulations. There were no other federal, state, or local agency representatives present at the time of the inspection. FACILITY DESCRIPTION EPA conducted an inspection on the T2 Operating Corporation / Buckner #D-5 SWD facility, which consists of one (3) storage tanks, two (2) separators, and one (1) pump. Section II - OBSERVATIONS I observed the facility and associated signage and secondary containment with storage tanks, separators, and pump; see Appendix 1 (Photograph Log), Photo No. 1 through No. 3. For additional GPS location and photo metadata, see Appendix 1. I observed loose oil inside secondary containment for the separators, see Photo No. 4. I also observed loose oil inside secondary containment for the storage tanks and pump, see Photo No. 5 through No. 7. I observed two (2) leaking pipes or valves connected to the storage tank battery, see Photo No. 6 and No. 7. Section III - AREAS OF CONCERN No closing conference was held due to no personnel from T2 Operating Corporation present during the inspection. The areas of concern observed during the inspection include the loose oil inside secondary containment and the multiple leaking pipes and/or valves connected to the storage tanks. Section IV - FOLLOW UP Inspector will provide the completed inspection report to company representative(s). Section V - LIST OF APPENDICES Appendix 1 - Photograph Log* - 7 photos taken 04/18/2025. *The photos were captured in HEIC format and converted to JPG format for the purpose of drafting the Photograph Log. The original photos are retained with their metadata. 2 T2 Operating Corporation / Buckner #D-5 SWD (ARU002313 / CWA) Inspection Date 04/18/2025 Appendix 1 Photograph Log 7 Photos UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: Off U.S. Highway 82 at 33.36356, -93.415611 City: Buckner County/Parish: Lafayette State: AR Photo File Name: 20250418_132345306_iOS Orientation: North Date of Photo: 04/18/2025 Time of Photo: 8:23 AM Latitude: 33.363544 Longitude: -93.415611 Photographer: Uma Lad Description: Looking north, this photo shows the sign at the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: Off U.S. Highway 82 at 33.36356, -93.415611 City: Buckner County/Parish: Lafayette State: AR Photo File Name: 20250418_132448072_iOS Orientation: East Date of Photo: 04/18/2025 Time of Photo: 8:24 AM Latitude: 33.363441 Longitude: -93.415930 Photographer: Uma Lad Description: Looking east, this photo shows an overview of the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: Off U.S. Highway 82 at 33.36356, -93.415611 City: Buckner County/Parish: Lafayette State: AR Photo File Name: 20250418_132450257_iOS Orientation: Northeast Date of Photo: 04/18/2025 Time of Photo: 8:24 AM Latitude: 33.363444 Longitude: -93.415944 Photographer: Uma Lad Description: Looking northeast, this photo shows an overview of the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: Off U.S. Highway 82 at 33.36356, -93.415611 City: Buckner County/Parish: Lafayette State: AR Photo File Name: 20250418_132537509_iOS Orientation: North Date of Photo: 04/18/2025 Time of Photo: 8:25 AM Latitude: 33.363619 Longitude: -93.415808 Photographer: Uma Lad Description: Looking north, this photo shows loose oil inside secondary containment for the separator. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: Off U.S. Highway 82 at 33.36356, -93.415611 City: Buckner County/Parish: Lafayette State: AR Photo File Name: 20250418_132635415_iOS Orientation: Northeast Date of Photo: 04/18/2025 Time of Photo: 8:26 AM Latitude: 33.363605 Longitude: -93.415650 Photographer: Uma Lad Description: Looking northeast, this photo shows loose oil inside secondary containment for the tanks. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: Off U.S. Highway 82 at 33.36356, -93.415611 City: Buckner County/Parish: Lafayette State: AR Photo File Name: 20250418_132714273_iOS Orientation: East Date of Photo: 04/18/2025 Time of Photo: 8:27 AM Latitude: 33.363586 Longitude: -93.415658 Photographer: Uma Lad Description: Looking east, this photo shows loose oil inside secondary containment for the tanks and a leaking pipe. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: Off U.S. Highway 82 at 33.36356, -93.415611 City: Buckner County/Parish: Lafayette State: AR Photo File Name: 20250418_132751378_iOS Orientation: North Date of Photo: 04/18/2025 Time of Photo: 8:27 AM Latitude: 33.363547 Longitude: -93.415572 Photographer: Uma Lad Description: Looking north, this photo shows loose oil inside secondary containment for the tanks and a leaking pipe.