Document 10K21j3Q9znwLdj8ak1MgKGxj

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 11/06/2019 Water, Clean Water Act, National Pollution Discharge Elimination System Oil and Gas, Produced Water Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: Jamie Oil, Inc. Gulf Lease 33.170610N, -92.501498W El Dorado, Arkansas 71730 117 Foxwood Hot Springs, Arkansas 71913 Union 870-814-5299 Main Office N/A Main Office N/A FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: N/A ARU001272 N/A 211111 1311 Personnel participating in inspection: Kent W. Sanborn U.S. EPA, Region 6, ECDWE 918-557-1615 EPA Lead Inspector Signature/Date Supervisor Signature/Date Kent W. Sanborn Digitally signed by Kent W. Sanborn DN: cn=Kent W. Sanborn, o, ou=6EN-WR, email=sanborn.kent@epa.gov, c=US Date: 2019.12.05 08:55:43 -06'00' Kent W. Sanborn GUY TIDMORE Digitally signed by GUY TIDMORE DN: c=US, o=U.S. Government, ou=Environmental Protection Agency, cn=GUY TIDMORE, 0.9.2342.19200300.100.1.1=68001003655426 Date: 2019.12.06 11:21:58 -06'00' Guy Tidmore Date 6 DEC 2019 Date 6ENFORM-019-8 (10/31/2019) 1 Section I - INTRODUCTION Jamie Oil, Inc. / Gulf Lease Inspection Date: 11/06/2019 PURPOSE OF THE INSPECTION EPA Region 6 inspector Kent W. Sanborn arrived at the Jamie Oil, Inc. Gulf Lease located Northeast of El Dorado, Arkansas at about 9:00 AM on November 6, 2019 for an unannounced inspection. There were no company representatives at the site. The inspection was conducted to determine the facility's compliance with the Clean Water Act (CWA). The scope of the inspection was to determine if the facility was in compliance with the CWA, and to identify and document unauthorized discharges of produced wastewater (brine) to a water of the United States. The inspection was a follow-up to previous inspections that documented unauthorized discharges of produced water at the facility. FACILITY DESCRIPTION The discharge of produced water originated from the facility located on the Gulf Lease, where brine was stored and a flow line running at the lease connecting one or two producing wells in the vicinity to the tank battery. The discharge of produced water had reached North Creek, which I observed during the inspection. I observed some minor cleanup activity that included absorbant spread on the oil at the discharge site. I observed that the discharge had recently occurred and could be several months old. Section II - OBSERVATIONS I initially arrived at the Jamie Oil, Inc., Gulf Lease at about 9:00 am November 6, 2019. Photos 1 and 2 show the location of the source of the discharge of produced water, or brine. Photo 3 showed dead and dying trees at the discharge site. The brine and some oil were pooled up in a ditch downstream from the discharge site (Photo 4). With a calibrated YSI Pro 30 Conductivity Meter, a Total Dissolve Solids (TDS) reading was measured in the pool and was 34,775 milligrams per liter (mg/L) (Photo 5). Photo 6 showed the discharge flow path north toward North Creek. A sign at a producing oil well near the point of entry to the creek was shown in Photo 7. Photos 8 and 9 indicated the location of the point of entry of the where the brine flowed into North creek. The TDS of the flowing creek measured 13,971 mg/L (Photo 10). Photo 11 showed the typical surface water drainage in the area near the point of entry to North Creek. The TDS upstream measured 47.8 mg/L (Photo 12). I observed that North Creek several miles downstream from the point of entry was a much larger and faster flowing water body (Photo 13). I observed several fish at this downstream location. A slight oil sheen (Photo 14) was also present during the inspection at this location. Section III - AREAS OF CONCERN There was surface damage and a flow path of produced water from the facility, including a flow line. There were elevated levels of TDS identified along the flow path and in North Creek. There was oil and oil sheen observed as well along the flow path and in North Creek. 2 6ENFORM-019-8 (10/31/2019) Section IV - FOLLOW UP Jamie Oil, Inc. / Gulf Lease Inspection Date: 11/06/2019 A follow up inspection will be conducted as needed. This facility will be referred to EPA water enforcement. Section V - LIST OF APPENDICES Appendix 1 - Photo Log - 14 photos taken 11/6/2019. 3 6ENFORM-019-8 (10/31/2019) Jamie Oil, Inc./Gulf Lease Inspection Date: 11/6/2019 Appendix 1 Photographic Log (14 photos) UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 33.170610N, -92.501498W City: El Dorado Photo No. 1 County: Union State: Arkansas Photo File Name: Photo 1 (DSC_0015) Orientation: South Date of Photo: 11/6/2019 Time of Photo: 10:21am Latitude: 33.170610N Longitude: -92.501498W Photographer: K.W. Sanborn Description: I observed a discharge of produced water, or brine, had occurred in this drainage ditch in the woods south of North Creek. A potential flow line failure was the evident source of the point of discharge of brine. I observed oil and brine fluids here and along the flow path downstream, towards North Creek from this location. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 33.170610N, -92.501498W City: El Dorado Photo No. 2 County: Union State: Arkansas Photo File Name: Photo 2 (DSC_0019) Orientation: South Date of Photo: 11/6/2019 Time of Photo: 10:21am Latitude: 33.170610N Longitude: -92.501498W Photographer: K.W. Sanborn Description: I observed brine and oil fluids pooled up here, along the flow path towards North Creek. There was dead vegetation observed at this location as well. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 33.170610N, -92.501498W City: El Dorado Photo No. 3 County: Union State: Arkansas Photo File Name: Photo 3 (DSC_0018) Orientation: South Date of Photo: 11/6/2019 Time of Photo: 10:21am Latitude: 33.170610N Longitude: -92.501498W Photographer: K.W. Sanborn Description: There were dead and dying trees after exposure to brine along the flow path, where elevated brine levels were measured. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 33.170610N, -92.501498W City: El Dorado Photo No. 4 County: Union State: Arkansas Photo File Name: Photo 4 (DSC_0016) Orientation: North Date of Photo: 11/6/2019 Time of Photo: 10:21am Latitude: 33.170610N Longitude: -92.501498W Photographer: K.W. Sanborn Description: I observed fluids, including brine pooled up downstream of the discharge point and lease road crossing. This location was on the flow path toward North Creek. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 33.170610N, -92.501498W City: El Dorado Photo No. 5 County: Union State: Arkansas Photo File Name: Photo 5 (DSC_0020) Orientation: North Date of Photo: 11/6/2019 Time of Photo: 10:22am Latitude: 33.170610N Longitude: -92.501498W Photographer: K.W. Sanborn Description: With a calibrated YSI Pro 30 Conductivity Meter, I took a Total Dissolved Solids (TDS) reading of the pool shown in Photo 4 and it measured 34,775 milligrams per liter (mg/L). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 33.170610N, -92.501498W City: El Dorado Photo No. 6 County: Union State: Arkansas Photo File Name: Photo 6 (DSC_0017) Orientation: Northwest Date of Photo: 11/6/2019 Time of Photo: 10:21am Latitude: 33.170610N Longitude: -92.501498W Photographer: K.W. Sanborn Description: The trail of the brine discharge flowed north toward the point of entry to North Creek. I observed intermittent holes of brine along the flow path between here and North Creek. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 33.170610N, -92.501498W City: El Dorado Photo No. 7 County: Union State: Arkansas Photo File Name: Photo 7 (DSC_0021) Orientation: North Date of Photo: 11/6/2019 Time of Photo: 10:31am Latitude: 33.172381N Longitude: -92.500635W Photographer: K.W. Sanborn Description: This was a producing well located near the point of entry to North Creek. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 33.170610N, -92.501498W City: El Dorado Photo No. 8 County: Union State: Arkansas Photo File Name: Photo 8 (DSC_0022) Orientation: North Date of Photo: 11/6/2019 Time of Photo: 10:32am Latitude: 33.1741N Longitude: -92.4993W Photographer: K.W. Sanborn Description: A bridge crossing near the point of entry to North Creek was observed here. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 33.170610N, -92.501498W City: El Dorado Photo No. 9 County: Union State: Arkansas Photo File Name: Photo 9 (DSC_0023) Orientation: West Date of Photo: 11/6/2019 Time of Photo: 10:32am Latitude: 33.1741N Longitude: -92.4993W Photographer: K.W. Sanborn Description: I observed the point of entry to North Creek here. The creek was flowing north during the inspection. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 33.170610N, -92.501498W City: El Dorado Photo No. 10 County: Union State: Arkansas Photo File Name: Photo 10 (DSC_0025) Orientation: West Date of Photo: 11/6/2019 Time of Photo: 10:33am Latitude: 33.1741N Longitude: -92.4993W Photographer: K.W. Sanborn Description: The TDS at the point of entry measured 13,971 mg/L. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 33.170610N, -92.501498W City: El Dorado Photo No. 11 County: Union State: Arkansas Photo File Name: Photo 11 (DSC_0027) Orientation: South Date of Photo: 11/6/2019 Time of Photo: 10:34am Latitude: 33.1720N Longitude: -92.4995W Photographer: K.W. Sanborn Description: This was a view of another small drainage, or tributary, coming from the east, and entered North Creek near the main point of entry of the brine. It was not affected by the spill. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 33.170610N, -92.501498W City: El Dorado Photo No. 12 County: Union State: Arkansas Photo File Name: Photo 12 (DSC_0026) Orientation: East Date of Photo: 11/6/2019 Time of Photo: 10:34am Latitude: 33.1720N Longitude: -92.4995W Photographer: K.W. Sanborn Description: The TDS of background water, or the unaffected tributary entering the upstream from the point of entry of brine on North Creek measured 47.8 mg/L. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 33.170610N, -92.501498W City: El Dorado Photo No. 13 County: Union State: Arkansas Photo File Name: Photo 13 (DSC_0029) Orientation: West Date of Photo: 11/6/2019 Time of Photo: 11:13am Latitude: 33.1852N Longitude: -92.4761W Photographer: K.W. Sanborn Description: This was North Creek several miles downstream from the point of entry of brine into North Creek. I observed that the creek at this location was large and the TDS at this location indicated the water did not have elevated TDS levels in it. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 33.170610N, -92.501498W City: El Dorado Photo No. 14 County: Union State: Arkansas Photo File Name: Photo 14 (DSC_0030) Orientation: West Date of Photo: 11/6/2019 Time of Photo: 11:13am Latitude: 33.1852N Longitude: -92.4995W Photographer: K.W. Sanborn Description: This photo was the same location on North Creek as shown in Photo 13. oil sheen on North Creek at this location. I observed a slight