Document 2Rmad6oOMgv3pgY0kDyn537Mr

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 4/4/24 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: ArklaTx Operating Co., Inc. Elder CV Lease Tank Battery From Highway 7 North, thence Arkansas Highway 335, thence N Texas Rd, thence Hayes City Rd, thence Ouachita County Rd 68, thence Ouachita County Rd 511, off oil field lease road at 33.389652, -92.649391. Norphlet, AR 71759 706 Ouachita Road 72 Smackover, AR 71762 Ouachita County 870-725-3666 Larry L. Oswald (318-995-0502) Person Responsible for Operation Rick V. Bauman (870-314-0807) Representative rvbauman@yahoo.com (Rick V. Bauman) FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: N/A ARU002248 N/A 211111 1311 Personnel participating in inspection: Kerri McCabe (lead) EPA / Region 6 ECDW Inspector / Enforcement Officer EPA Lead Inspector Signature/Date Supervisor Signature/Date KERRI MCCABE Kerri McCabe Digitally signed by KERRI MCCABE Date: 2024.05.07 07:32:22 -05'00' Date JEANNE ECKHART Date: 2024.05.09 07:45:47 -05'00' Digitally signed by JEANNE ECKHART Jeanne Eckhart Date 6ENFORM-019-R8.2 (02/12/2020) 1 ArklaTx Operating Co., Inc. / Elder CV Lease Tank Battery (ARU002248 / CWA) Inspection Date 04/04/2024 Section I - INTRODUCTION PURPOSE OF THE INSPECTION EPA Region 6 Inspector Kerri McCabe (lead) arrived at the ArklaTx Operating Co., Inc. / Elder CV Lease Tank Battery, located from Highway 7 North, thence Arkansas Highway 335, thence N Texas Rd, thence Hayes City Rd, thence Ouachita County Rd 68, thence Ouachita County Rd 511, off oil field lease road at 33.389652, -92.649391.; at 1010 on 4/4/24 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 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 an inspection on the ArklaTx Operating Co., Inc. / Elder CV Lease Tank Battery, which contains three (3) firewalls, one (1) oil-water separator, three (3) crude oil storage tanks, two (2) saltwater storage tanks, and one (1) saltwater disposal (SWD) well. Section II - OBSERVATIONS I observed the facility sign, secondary containment, pipes and valves, and storage tanks located at the facility; see Appendix 1 (Photographs Log), Photo No. 1 through No. 2 and No. 6. For additional GPS location and photo metadata, see Appendix 1. I observed loose oil inside the secondary containment for the crude oil storage firewall, see Photo No. 3 and No. 4. I observed the sump pump used in the secondary containment for the crude oil storage firewall to route fluids back through the system, see Photo No. 5. I observed a pipe at a saltwater storage tank with a closed valve with no cap with an active saltwater leak and salt crystals coating the opening of the pipe and forming on the ground, see Photo No. 7 and No. 8. I observed the pump for the SWD well with an active leak of saltwater inside secondary containment, see Photo No. 9 and No. 10. I observed the sump pump used in the secondary containment for the saltwater storage firewall to route fluids back through the system, see Photo No. 11. I observed the transfer pipe through secondary containment for one of the saltwater storage firewalls without a catch bucket and the cap removed; residual saltwater was noted on the ground at the transfer pipe; see Photo No. 12 and No. 13. 2 ArklaTx Operating Co., Inc. / Elder CV Lease Tank Battery (ARU002248 / CWA) Inspection Date 04/04/2024 I observed the SWD well located onsite to be connected and injecting from the system, see Photo No. 14. Section III - AREAS OF CONCERN No closing conference was held due to no personnel with ArklaTx Operating Co., Inc. being present during the inspection. Areas of concern at the time of the inspection include the loose oil inside the secondary containment for crude oil storage, active leaks of saltwater at a pipe and a pump inside secondary containment for saltwater storage, a transfer pipe for saltwater without a catch bucket and a removed cap, and a residual spill of saltwater outside secondary containment. 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 - 14 photos taken 4/4/24. 3 ArklaTx Operating Co., Inc. / Elder CV Lease Tank Battery (ARU002248 / CWA) Inspection Date 04/04/2024 Appendix 1 Photograph Log 14 Photos UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: ArklaTx Operating Co., Inc. - Elder CV Lease Tank Battery from Ouachita County Rd 511 off oil field lease road at 33.389652, -92.649391. City: Smackover County/Parish: Ouachita State: Arkansas Photo File Name: P4020126 Orientation: SE Date of Photo: 04/04/2024 Time of Photo: 1027 Latitude: 33.389678 Longitude: -92.649287 Photographer: Kerri McCabe Description: Looking SE, this photo showed the signage at the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: ArklaTx Operating Co., Inc. - Elder CV Lease Tank Battery from Ouachita County Rd 511 off oil field lease road at 33.389652, -92.649391. City: Smackover County/Parish: Ouachita State: Arkansas Photo File Name: P4020127 Orientation: SE Date of Photo: 04/04/2024 Time of Photo: 1027 Latitude: 33.389721 Longitude: -92.649199 Photographer: Kerri McCabe Description: Looking SE, this photo showed an overview of the main tank battery; three (3) tank batteries onsite. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: ArklaTx Operating Co., Inc. - Elder CV Lease Tank Battery from Ouachita County Rd 511 off oil field lease road at 33.389652, -92.649391. City: Smackover County/Parish: Ouachita State: Arkansas Photo File Name: P4020128 Orientation: SE Date of Photo: 04/04/2024 Time of Photo: 1028 Latitude: 33.389644 Longitude: -92.649210 Photographer: Kerri McCabe Description: Looking SE, this photo showed loose oil inside the secondary containment (at the front) for the main tank battery. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: ArklaTx Operating Co., Inc. - Elder CV Lease Tank Battery from Ouachita County Rd 511 off oil field lease road at 33.389652, -92.649391. City: Smackover County/Parish: Ouachita State: Arkansas Photo File Name: P4020129 Orientation: SE Date of Photo: 04/04/2024 Time of Photo: 1028 Latitude: 33.389568 Longitude: -92.649195 Photographer: Kerri McCabe Description: Looking SE, this photo showed loose oil inside the secondary containment (at the back) for the main tank battery. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: ArklaTx Operating Co., Inc. - Elder CV Lease Tank Battery from Ouachita County Rd 511 off oil field lease road at 33.389652, -92.649391. City: Smackover County/Parish: Ouachita State: Arkansas Photo File Name: P4020130 Orientation: NW Date of Photo: 04/04/2024 Time of Photo: 1029 Latitude: 33.389545 Longitude: -92.649363 Photographer: Kerri McCabe Description: Looking NW, this photo showed a sump pump installed inside the secondary containment for the main tank battery to route fluids back into the system. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: ArklaTx Operating Co., Inc. - Elder CV Lease Tank Battery from Ouachita County Rd 511 off oil field lease road at 33.389652, -92.649391. City: Smackover County/Parish: Ouachita State: Arkansas Photo File Name: P4020132 Orientation: E-NE Date of Photo: 04/04/2024 Time of Photo: 1030 Latitude: 33.389545 Longitude: -92.649363 Photographer: Kerri McCabe Description: Looking E-NE, this photo showed an overview of the other two (2) tank batteries onsite. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: ArklaTx Operating Co., Inc. - Elder CV Lease Tank Battery from Ouachita County Rd 511 off oil field lease road at 33.389652, -92.649391. City: Smackover County/Parish: Ouachita State: Arkansas Photo File Name: P4020134 Orientation: E-NE Date of Photo: 04/04/2024 Time of Photo: 1032 Latitude: 33.389710 Longitude: -92.649636 Photographer: Kerri McCabe Description: Looking E-NE, this photo showed an active leak from a storage tank pipe inside the secondary containment from the middle tank battery; I noted salt crystals around pipe and on the ground. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: ArklaTx Operating Co., Inc. - Elder CV Lease Tank Battery from Ouachita County Rd 511 off oil field lease road at 33.389652, -92.649391. City: Smackover County/Parish: Ouachita State: Arkansas Photo File Name: P4020135 Orientation: N-NE Date of Photo: 04/04/2024 Time of Photo: 1032 Latitude: 33.389710 Longitude: -92.649636 Photographer: Kerri McCabe Description: Looking N-NE, this photo showed a closeup of the active leak from a storage tank pipe from Photo No. 7. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 Location: ArklaTx Operating Co., Inc. - Elder CV Lease Tank Battery from Ouachita County Rd 511 off oil field lease road at 33.389652, -92.649391. City: Smackover County/Parish: Ouachita State: Arkansas Photo File Name: P4020136 Orientation: W-SW Date of Photo: 04/04/2024 Time of Photo: 1032 Latitude: 33.389767 Longitude: -92.649609 Photographer: Kerri McCabe Description: Looking W-SW, this photo showed a pump connected to the storage tank inside secondary containment for the middle tank battery; pump line routed to the saltwater disposal (SWD) well. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 10 Location: ArklaTx Operating Co., Inc. - Elder CV Lease Tank Battery from Ouachita County Rd 511 off oil field lease road at 33.389652, -92.649391. City: Smackover County/Parish: Ouachita State: Arkansas Photo File Name: P4020138 Orientation: SE Date of Photo: 04/04/2024 Time of Photo: 1033 Latitude: 33.389767 Longitude: -92.649609 Photographer: Kerri McCabe Description: Looking SE, this photo showed an active leak at the pump in Photo No. 9. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 11 Location: ArklaTx Operating Co., Inc. - Elder CV Lease Tank Battery from Ouachita County Rd 511 off oil field lease road at 33.389652, -92.649391. City: Smackover County/Parish: Ouachita State: Arkansas Photo File Name: P4020137 Orientation: E-NE Date of Photo: 04/04/2024 Time of Photo: 1033 Latitude: 33.389801 Longitude: -92.649688 Photographer: Kerri McCabe Description: Looking E-NE, this photo showed a sump pump installed inside the secondary containment for the middle tank battery; I noted staining and salt crystals on the ground. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 12 Location: ArklaTx Operating Co., Inc. - Elder CV Lease Tank Battery from Ouachita County Rd 511 off oil field lease road at 33.389652, -92.649391. City: Smackover County/Parish: Ouachita State: Arkansas Photo File Name: P4020139 Orientation: E-SE Date of Photo: 04/04/2024 Time of Photo: 1034 Latitude: 33.389717 Longitude: -92.649438 Photographer: Kerri McCabe Description: Looking E-SE, this photo showed a transfer pipe connected to the storage tank in the middle tank battery without a cap on the pipe; I noted the valve was closed. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 13 Location: ArklaTx Operating Co., Inc. - Elder CV Lease Tank Battery from Ouachita County Rd 511 off oil field lease road at 33.389652, -92.649391. City: Smackover County/Parish: Ouachita State: Arkansas Photo File Name: P4020140 Orientation: S-SE Date of Photo: 04/04/2024 Time of Photo: 1034 Latitude: 33.389717 Longitude: -92.649438 Photographer: Kerri McCabe Description: Looking S-SE, this photo showed a recent release from the transfer pipe in Photo No. 12.; I noted flow indicators and damp sand (darker color). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 14 Location: ArklaTx Operating Co., Inc. - Elder CV Lease Tank Battery from Ouachita County Rd 511 off oil field lease road at 33.389652, -92.649391. City: Smackover County/Parish: Ouachita State: Arkansas Photo File Name: P4020142 Orientation: W-NW Date of Photo: 04/04/2024 Time of Photo: 1035 Latitude: 33.390074 Longitude: -92.649803 Photographer: Kerri McCabe Description: Looking W-NW, this photo showed the Elder #15 SWD well utilized at the facility.