Document 2j9NO3OaEjVaQMad08XY3Dnz6

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 10/07/2024 Water Clean Water Act Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: Corley Trust, LLC Wilson #7 SWD Tank Battery Latitude: 33.35372, Longitude: -92.69236 Smackover, AR, 71762 410 W. 6th Smackover, AR 71762 Union County 870-725-3928 Jeff Corley corleytrust@att.net FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: NA ARU002260 NA 211111 1311 Personnel participating in inspection: Uma Lad (lead) EPA/Region 6 ECDW Kerri McCabe EPA/Region 6 ECDW Michael Blaha EPA/Region 6 ECDW Enforcement Officer/Inspector Enforcement Officer/Inspector Enforcement Officer/Inspector EPA Lead Inspector Signature/Date Supervisor Signature/Date UMA LAD Uma Lad Digitally signed by UMA LAD Date: 2024.11.19 11:24:50 -06'00' Date JEANNE ECKHART Date: 2024.11.25 09:16:05 -06'00' Digitally signed by JEANNE ECKHART Jeanne Eckhart Date 6ENFORM-019-R8.2 (02/12/2020) 1 Section I - INTRODUCTION Corley Trust, LLC - Wilson #7 SWD Tank Battery / ARU002260 (CWA) Inspection Date 10/07/2024 PURPOSE OF THE INSPECTION EPA Region 6 inspectors Michael Blaha, Kerri McCabe, and I, Uma Lad, arrived at Corley Trust, LLC - Wilson #7 SWD Tank Battery, located off a lease road near Gas Plant Road (33.353727, -92.69236) at 5:55 PM on October 7, 2024, 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 Corley Trust, LLC - Wilson #7 SWD Tank Battery, which consists of two (2) saltwater storage tanks, two (2) crude oil storage tanks, two (2) separators, and one (1) saltwater disposal (SWD) well. Section II - OBSERVATIONS I observed the facility sign, secondary containment, pipes, valves, and storage tanks located at the facility; see Appendix 1 (photo log), photo No. 1 and No. 2. For additional GPS location and photo metadata, see Appendix 1. I observed loose oil and brine in a workover pit that was outside of secondary containment, see photo No. 3-4. The pit was constructed around the secondary containment discharge valve. I observed loose oil inside secondary containment, see photo No. 5. I observed an overhead pipe from a tank that was not properly supported, see photo No. 6. I observed discharge valves with loose oil and no catchment, see photo No. 7. I also observed a leaking connector pipe for the SWD well, see photo No. 8. I observed tanks without "out of service" labels, see photo No. 9. Section III - AREAS OF CONCERN No closing conference was held due to no Corley Trust, LLC staff being present during the inspection. Areas of concern at the time of the inspection include the loose oil and brine in the workover pit outside of secondary containment, loose oil within secondary containment, a tank pipe without proper support, discharge valves with loose oil and no catchment, a leak at a connector pipe for the SWD well, and tanks without the "out of service" markings. 2 Section IV - FOLLOW UP Corley Trust, LLC - Wilson #7 SWD Tank Battery / ARU002260 (CWA) Inspection Date 10/07/2024 Inspector will conduct follow-up phone calls with the company representatives over the coming weeks and months to ensure areas of concern are properly addressed. Section V - LIST OF APPENDICES Appendix 1 - Photo Log - 9 photos taken on 10/07/2024 3 Corley Trust, LLC - Wilson #7 SWD Tank Battery / ARU002260 (CWA) Inspection Date 10/07/2024 Appendix 1 Photograph Log 9 Photos UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.35372, - 92.69236 City: Smackover Photo No. 1 County/Parish: Union State: Arkansas Photo File Name: PA070019 Orientation: N Date of Photo: 10/07/2024 Time of Photo: 5:55 PM Latitude: 33.35372 Longitude: - 92.69236 Photographer: Uma Lad Description: This photo was taken looking north and shows the facility sign. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.35372, - 92.69236 City: Smackover Photo No. 2 County/Parish: Union State: Arkansas Photo File Name: PA070020 Orientation: N Date of Photo: 10/07/2024 Time of Photo: 5:56 PM Latitude: 33.35371 Longitude: -92.69253 Photographer: Uma Lad Description: This photo was taken looking north and shows an overview of the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.35372, - 92.69236 City: Smackover Photo No. 3 County/Parish: Union State: Arkansas Photo File Name: PA070021 Orientation: N Date of Photo: 10/07/2024 Time of Photo: 5:57 PM Latitude: 33.35394 Longitude: -92.69245 Photographer: Uma Lad Description: This photo was taken looking north and shows a workover pit with loose oil and brine outside of secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.35372, - 92.69236 City: Smackover Photo No. 4 County/Parish: Union State: Arkansas Photo File Name: PA070022 Orientation: N Date of Photo: 10/07/2024 Time of Photo: 5:58 PM Latitude: 33.35395 Longitude: - 92.69248 Photographer: Uma Lad Description: T This photo was taken looking north and shows a workover pit with loose oil and brine outside of secondary containment. The berm is built around the secondary containment discharge valve. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.35372, - 92.69236 City: Smackover Photo No. 5 County/Parish: Union State: Arkansas Photo File Name: PA070023 Orientation: SW Date of Photo: 10/07/2024 Time of Photo: 5:58 PM Latitude: 33.35395 Longitude: -92.69248 Photographer: Uma Lad Description: This photo was taken looking southwest and shows loose oil inside secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.35372, - 92.69236 City: Smackover Photo No. 6 County/Parish: Union State: Arkansas Photo File Name: PA070024 Orientation: SW Date of Photo: 10/07/2024 Time of Photo: 5:58 PM Latitude: 33.35396 Longitude: -92.69246 Photographer: Uma Lad Description: This photo was taken looking southwest and shows an overhead pipe without support extending from a tank. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.35372, - 92.69236 City: Smackover Photo No. 7 County/Parish: Union State: Arkansas Photo File Name: PA070025 Orientation: SW Date of Photo: 10/07/2024 Time of Photo: 6:00 PM Latitude: 33.35394 Longitude: -92.69237 Photographer: Uma Lad Description: This photo was taken looking southwest and shows discharge valves with loose oil and no catchment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.35372, - 92.69236 City: Smackover Photo No. 8 County/Parish: Union State: Arkansas Photo File Name: PA070026 Orientation: SW Date of Photo: 10/07/2024 Time of Photo: 6:00 PM Latitude: 33.35392 Longitude: -92.69226 Photographer: Uma Lad Description: This photo was taken looking southwest and shows a leak from a connection pipe to the SWD well , where crystal formation was present. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.35372, - 92.69236 City: Smackover Photo No. 9 County/Parish: Union State: Arkansas Photo File Name: PA070028 Orientation: SW Date of Photo: 10/07/2024 Time of Photo: 6:01 PM Latitude: 33.35411 Longitude: -92.69265 Photographer: Uma Lad Description: This photo was taken looking southwest and shows two (2) tanks without "out of service" labels or markings.