Document 0XQd8zrDR32vjBwkbm8eNwyk

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 05/21/2024 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: RCP Production, LLC TD Murphy B-3 SWD Tank Battery From Highway 7 Business, thence Gas Plant Road, thence All Gulf Road, off an oil field lease road in Smackover (Sandy Land) at 33.341155, -92.690976 Smackover, AR 71762 134 Daniel Road Smackover, AR 71762 Union County 870-814-9942 Rod Phillips Person Responsible for Operation rod_phillips2000@yahoo.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: N/A ARU002227 N/A 211111 1311 Personnel participating in inspection: Kerri McCabe (lead) EPA / Region 6 ECDW Rod Phillips RCP Production, LLC Inspector / Enforcement Officer Owner / Operator EPA Lead Inspector Signature/Date Supervisor Signature/Date KERRI MCCABE Kerri McCabe Digitally signed by KERRI MCCABE Date: 2024.06.18 06:54:40 -05'00' Date JEANNE ECKHART Date: 2024.06.18 14:20:37 -05'00' Digitally signed by JEANNE ECKHART Jeanne Eckhart Date 6ENFORM-019-R8.2 (02/12/2020) 1 Section I - INTRODUCTION RCP Production, LLC / TD Murphy B-3 SWD (ARU002227 / CWA) Inspection Date 05/21/2024 PURPOSE OF THE INSPECTION EPA Region 6 Inspector Kerri McCabe (lead) arrived at the RCP Production, LLC / TD Murphy B-3 SWD Tank Battery release site, located from All Gulf Rd, off an oil lease road in Smackover at 33.341485, 92.686930; at 1422 on 05/21/2024 for an announced inspection. Mr. Rod Phillips, RCP Production, LLC; represented the facility at the time of the inspection. The inspection was conducted by the authority of the Clean Water Act (CWA) to determine compliance with Environmental Protection Agency (EPA) regulations. There were no other federal, state, or local agency representatives present at the time of the inspection. FACILITY DESCRIPTION EPA conducted a follow-up inspection on the RCP Production, LLC / TD Murphy B-3 SWD Tank Battery for a release from the tank battery that had occurred on 03/12/2024. EPA collected Total Dissolved Solids (TDS) readings from areas sampled during the 03/12/2024 and 04/02/2024 inspections. Aerial Image 1. Overview of the area of the release and the associated RCP Production - TD Murphy B-3 SWD well and downstream TDS readings for the impacted wetland and unnamed tributary (UT) of Smackover Creek. Google Earth image date 09/26/2023. 2 Section II - OBSERVATIONS RCP Production, LLC / TD Murphy B-3 SWD (ARU002227 / CWA) Inspection Date 05/21/2024 I observed the pool in the impacted wetland downstream of the TD Murphy B-3 SWD tank battery. New booms were noted at the influent-side of the road culvert, see Appendix 1 (Photograph Log), Photo No. 1. For additional GPS location and photo metadata, see Appendix 1. I observed a pump at the pool in the impacted wetland downstream of the TD Murphy B-3 SWD tank battery. The operator, Rod Phillips, stated the pump was used to transfer water from the pool to a pumper truck, which is routed back to the SWD well. See Photo No. 2. I collected a TDS reading of 1,024 mg/L at the pool in the impacted wetland downstream of the TD Murphy B-3 SWD tank battery. See Photo No. 3. I observed the area upstream of the pool in the impacted wetland, where the TDS sample was collected. See Photo No. 4. I observed the area downstream of the pool in the impacted wetland, where the TDS sample was collected. See Photo No. 5 and No. 6. I collected a TDS reading of 1,158 mg/L from a sample from a bucket filled with water pumped from the pool in the impacted wetland for comparison with the operator's meter and the EPA-issued meter. See Photo No. 7. I collected a Total Dissolved Solids (TDS) reading of 2,116 mg/L at the All Gulf Rd bridge, which is downstream of the impacted wetland, at an unnamed tributary (UT) of Smackover Creek. See Photo No. 8. I observed upstream at the UT of Smackover Creek, where the TDS reading was collected. See Photo No. 9. I observed downstream at the UT of Smackover Creek, where the TDS reading was collected. See Photo No. 10. I collected a TDS reading of 2,196 mg/L from an area used by Jerry Langley Oil Co., LLC personnel for the collection of flush water from the impacted wetland. See Photo No. 11. I observed upstream at the collection site, where the TDS reading was collected. See Photo No. 12. I observed downstream at the collection site, where the TDS reading was collected. See Photo No. 13. 3 RCP Production, LLC / TD Murphy B-3 SWD (ARU002227 / CWA) Inspection Date 05/21/2024 Section III - AREAS OF CONCERN A closing conference was held with Mr. Rod Phillips, RCP Production, LLC; to discuss the findings of the inspection. Areas of concern at the time of the inspection include the elevated TDS readings from the surface water locations along the length of the discharge conveyance, UT of Smackover Creek. Section IV - FOLLOW UP Inspector will conduct follow-up phone calls with the company representative(s) over the coming weeks and months to ensure areas of concern are properly addressed. Section V - LIST OF APPENDICES Appendix 1 - Photograph Log - 13 photos taken 05/21/2024. 4 RCP Production, LLC / TD Murphy B-3 SWD (ARU002227 / CWA) Inspection Date 05/21/2024 Appendix 1 Photograph Log 13 Photos UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: RCP Production, LLC - TD Murphy B-3 SWD release site from All Gulf Road, off an oil field lease road at 33.341155, -92.690976. City: Smackover County/Parish: Union State: Arkansas Photo File Name: R0010121 Orientation: W-NW Date of Photo: 05/21/2024 Time of Photo: 1503 Latitude: 33.341583 Longitude: -92.687000 Photographer: Kerri McCabe Description: Looking W-NW, this photo showed new booms placed downstream of the RCP Production, LLC - TD Murphy B-3 SWD crude oil and saltwater release into a wetland documented in the 03/12/2024 and 04/02/2024 inspections. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: RCP Production, LLC - TD Murphy B-3 SWD release site from All Gulf Road, off an oil field lease road at 33.341155, -92.690976. City: Smackover County/Parish: Union State: Arkansas Photo File Name: R0010122 Orientation: NW Date of Photo: 05/21/2024 Time of Photo: 1504 Latitude: 33.341595 Longitude: -92.686978 Photographer: Kerri McCabe Description: Looking NW, this photo showed a pump setup at the pool in the wetland downstream of the TD Murphy B-3 SWD release. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: RCP Production, LLC - TD Murphy B-3 SWD release site from All Gulf Road, off an oil field lease road at 33.341155, -92.690976. City: Smackover County/Parish: Union State: Arkansas Photo File Name: R0010126 Orientation: SW Date of Photo: 05/21/2024 Time of Photo: 1557 Latitude: 33.341250 Longitude: -92.686950 Photographer: Kerri McCabe Description: Looking SW, this photo showed the TDS reading of 1,024 mg/L at the pool in the wetland downstream of the TD Murphy B-3 SWD release. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: RCP Production, LLC - TD Murphy B-3 SWD release site from All Gulf Road, off an oil field lease road at 33.341155, -92.690976. City: Smackover County/Parish: Union State: Arkansas Photo File Name: R0010123 Orientation: NW Date of Photo: 05/21/2024 Time of Photo: 1504 Latitude: 33.341600 Longitude: -92.687033 Photographer: Kerri McCabe Description: Looking NW, this photo showed the view upstream of the TDS reading in Photo No. 3. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: RCP Production, LLC - TD Murphy B-3 SWD release site from All Gulf Road, off an oil field lease road at 33.341155, -92.690976. City: Smackover County/Parish: Union State: Arkansas Photo File Name: R0010124 Orientation: E-NE Date of Photo: 05/21/2024 Time of Photo: 1504 Latitude: 33.341463 Longitude: -92.686957 Photographer: Kerri McCabe Description: Looking E-NE, this photo showed the view downstream of the TDS reading in Photo No. 3. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: RCP Production, LLC - TD Murphy B-3 SWD release site from All Gulf Road, off an oil field lease road at 33.341155, -92.690976. City: Smackover County/Parish: Union State: Arkansas Photo File Name: R0010125 Orientation: N-NE Date of Photo: 05/21/2024 Time of Photo: 1505 Latitude: 33.341467 Longitude: -92.686850 Photographer: Kerri McCabe Description: Looking N-NE, this photo showed an additional view of the downstream location in Photo No. 5. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: RCP Production, LLC - TD Murphy B-3 SWD release site from All Gulf Road, off an oil field lease road at 33.341155, -92.690976. City: Smackover County/Parish: Union State: Arkansas Photo File Name: R0010130 Orientation: NE Date of Photo: 05/21/2024 Time of Photo: 1606 Latitude: 33.341467 Longitude: -92.686850 Photographer: Kerri McCabe Description: Looking NE, this photo showed the TDS reading of 1,158 mg/L from a sample collected by the pump in Photo No. 2. The sample was used to compare the operator's meter with the EPA-issued meter. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: RCP Production, LLC - TD Murphy B-3 SWD release site from All Gulf Road, off an oil field lease road at 33.341155, -92.690976. City: Smackover County/Parish: Union State: Arkansas Photo File Name: R0010134 Orientation: NE Date of Photo: 05/21/2024 Time of Photo: 1705 Latitude: 33.346167 Longitude: -92.682900 Photographer: Kerri McCabe Description: Looking NE, this photo showed the TDS reading of 2,116 mg/L at the All Gulf Rd bridge, which is the downstream location for the wetlands in Photo No. 1 and No. 2 and No. 4 through No. 6. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 Location: RCP Production, LLC - TD Murphy B-3 SWD release site from All Gulf Road, off an oil field lease road at 33.341155, -92.690976. City: Smackover County/Parish: Union State: Arkansas Photo File Name: R0010136 Orientation: W-SW Date of Photo: 05/21/2024 Time of Photo: 1705 Latitude: 33.346167 Longitude: -92.682900 Photographer: Kerri McCabe Description: Looking W-SW, this photo showed the upstream view of the receiving stream, unnamed tributary (UT) of Smackover Creek, for the TDS reading in Photo No. 8. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 10 Location: RCP Production, LLC - TD Murphy B-3 SWD release site from All Gulf Road, off an oil field lease road at 33.341155, -92.690976. City: Smackover County/Parish: Union State: Arkansas Photo File Name: R0010135 Orientation: NE Date of Photo: 05/21/2024 Time of Photo: 1705 Latitude: 33.346167 Longitude: -92.682900 Photographer: Kerri McCabe Description: Looking NE, this photo showed the downstream view of the receiving stream, UT of Smackover Creek, for the TDS reading in Photo No. 8. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 11 Location: RCP Production, LLC - TD Murphy B-3 SWD release site from All Gulf Road, off an oil field lease road at 33.341155, -92.690976. City: Smackover County/Parish: Union State: Arkansas Photo File Name: R0010139 Orientation: NW Date of Photo: 05/21/2024 Time of Photo: 1723 Latitude: 33.343233 Longitude: -92.684133 Photographer: Kerri McCabe Description: Looking NW, this photo showed the TDS reading of 2,196 mg/L for a location upstream of the All Gulf Rd bridge site in Photo No. 8 through No. 10. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 12 Location: RCP Production, LLC - TD Murphy B-3 SWD release site from All Gulf Road, off an oil field lease road at 33.341155, -92.690976. City: Smackover County/Parish: Union State: Arkansas Photo File Name: R0010140 Orientation: W-SW Date of Photo: 05/21/2024 Time of Photo: 1723 Latitude: 33.343233 Longitude: -92.684133 Photographer: Kerri McCabe Description: Looking W-SW, this photo showed the upstream view of the receiving stream, UT of Smackover Creek, for the TDS reading in Photo No. 11. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 13 Location: RCP Production, LLC - TD Murphy B-3 SWD release site from All Gulf Road, off an oil field lease road at 33.341155, -92.690976. City: Smackover County/Parish: Union State: Arkansas Photo File Name: R0010141 Orientation: N Date of Photo: 05/21/2024 Time of Photo: 1724 Latitude: 33.343233 Longitude: -92.684133 Photographer: Kerri McCabe Description: Looking N, this photo showed the downstream view of the receiving stream, UT of Smackover Creek, for the TDS reading in Photo No. 11.