Document 2qELvLOZ7yX6JYw1epVLOpY06
Region 6 - Enforcement & Compliance Assurance Division
INSPECTION REPORT
Inspection Date: Media Program: Regulatory Program:
01/14/2026 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:
Nevada Oil, LLC
Irma Nacatoch (Sand) Unit 28 Tank Battery
From Willisville, State Highway 371 North, right on Hwy 76, and then right
onto an oilfield lease road at 33.545952, -93.218989.
Willisville, AR 71730
451 North Washington
El Dorado, AR 71864
Nevada County
870-862-9950
Michael L. Burns
Person Responsible for Operation
(870-310-1501)
hrowan@ecgcpa.com
FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC:
N/A ARU002289 N/A 211111 1311
Personnel participating in inspection:
Kerri McCabe (lead)
EPA / Region 6 ECDW
Uma Lad
EPA / Region 6 ECDW
Tom McKay
EPA / Region 6 SEMD
Michael Burns
Nevada Oil, LLC
Dollar Burns
Nevada Oil, LLC
Inspector / Enforcement Officer Inspector / Enforcement Officer SEE Inspector Operations Companion
EPA Lead Inspector Signature/Date
Supervisor Signature/Date
KERRI MCCABE
Kerri McCabe
Digitally signed by KERRI MCCABE Date: 2026.03.04 07:17:00 -06'00'
Date
JEANNE ECKHART Date: 2026.03.04 10:34:38 -06'00' Digitally signed by JEANNE ECKHART
Jeanne Eckhart
Date
6ENFORM-019-R8.2 (02/12/2020)
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Nevada Oil, LLC / Irma Nacatoch (Sand) Unit 28 Tank Battery (ARU002289 / CWA) Inspection Date 01/14/2026
Section I - INTRODUCTION PURPOSE OF THE INSPECTION EPA Region 6 inspectors Kerri McCabe (lead), Uma Lad, and Tom McKay (for Spill Prevention Control and Countermeasure (SPCC) inspection) arrived at the Nevada Oil, LLC / Irma Nacatoch (Sand) Unit 28 Tank Battery ("facility") located from State Highway 371 North, right on Hwy 76, and then right onto an oilfield lease road at 33.545952, -93.218989 in Willisville, Nevada County, Arkansas; at 0845 on 01/14/2026 for an announced inspection. Mr. Michael Burns 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. This facility was last inspected by Inspector Kerri McCabe on 03/05/2025 under the Brine Program. FACILITY DESCRIPTION EPA conducted an inspection on the Nevada Oil, LLC / Irma Nacatoch (Sand) Unit 28 Tank Battery facility, which contains two (2) tanks for crude oil and saltwater storage, one (1) treater, one (1) separator, and one (1) open-top tank for oil skimming.
Map 1. Aerial imagery (Google Earth dated 08/03/2023) of the Nevada Oil, LLC / Irma Nacatoch (Sand) Unit 28 Tank Battery facility.
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Nevada Oil, LLC / Irma Nacatoch (Sand) Unit 28 Tank Battery (ARU002289 / CWA) Inspection Date 01/14/2026
Section II - OBSERVATIONS I observed the facility signage, tank battery, pipes and valves, storage tanks, and separators/treaters; see Appendix 1 (Photographs Log), see Photos No. 1 and No. 2. For additional GPS location and photo metadata, see Appendix 1. I observed the load line with a catchment bucket for secondary containment, see Photo No. 3. I observed a tank plated (i.e., with the manway removed) in preparation for permanent closure with "out of service" tagging, see Photos No. 4 and No. 5. I observed the sump channel and pit with loose oil inside secondary containment, see Photos No. 6 and No. 7. I observed active oil leaks from valves/couplings inside secondary containment, see Photos No. 8 through No. 10 and No. 13. I observed an open-top skimming tank with gapping between the tank and battery surface, see Photos No. 11 and No. 12. Section III - AREAS OF CONCERN EPA Region 6 inspectors Kerri McCabe, Uma Lad, and Tom McKay held a closing conference with Mr. Michael Burns with Nevada Oil, LLC after the inspection. Areas of concern under the SPCC rule at the time of the inspection include the following: Loose oil and saltwater inside secondary containment, 40 CFR 112.9(b)(1) (Photos No. 6 and No. 7),
and Active leaks of oil from valves/couplings inside secondary containment, 40 CFR 122.9(d)(1) (Photos
No. 8 through No. 10 and No. 13).
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. SEE Inspector Tom McKay will address SPCC rule concerns. Section V - LIST OF APPENDICES Appendix 1 - Photograph Log - 13 photos taken on 01/14/2026.
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Nevada Oil, LLC / Irma Nacatoch (Sand) Unit 28 Tank Battery (ARU002289 / CWA) Inspection Date 01/14/2026
Appendix 1 Photograph Log
13 Photos
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 1
Facility/Location:
Nevada Oil, LLC Irma Nacatoch Unit Tank Battery 28
City: Willisville
County: Nevada County
State: AR
Filename: R0011271.JPG
Photo Date: 01/14/2026
Photographer: Kerri McCabe
Witness Name:
Direction: SW
Time: 09:04:44 Tom McKay
Description: Latitude:
Looking SW, this photo shows the signage at the Irma Nacatoch Unit 28 Tank Battery
("facility").
3332'45.636" N
Longitude: 9313'8.358" W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 2
Facility/Location:
Nevada Oil, LLC Irma Nacatoch Unit Tank Battery 28
City: Willisville
County: Nevada County
State: AR
Filename: R0011272.JPG
Photo Date: 01/14/2026
Photographer: Kerri McCabe
Witness Name:
Direction: SW
Time: 09:05:13 Tom McKay
Description: Looking SW, this photo shows an overview of the facility.
Latitude: 3332'45.402" N
Longitude: 9313'8.094" W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 3
Facility/Location:
Nevada Oil, LLC Irma Nacatoch Unit Tank Battery 28
City: Willisville
County: Nevada County
State: AR
Filename: R0011273.JPG
Photo Date: 01/14/2026
Photographer: Kerri McCabe
Witness Name:
Direction: SW
Time: 09:08:08 Tom McKay
Description: Latitude:
Looking SW, this photo shows the transfer line for the tank battery with a catchment
bucket in place.
3332'45.954" N
Longitude: 9313'8.52" W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 4
Facility/Location:
Nevada Oil, LLC Irma Nacatoch Unit Tank Battery 28
City: Willisville
County: Nevada County
State: AR
Filename: R0011274.JPG
Photo Date: 01/14/2026
Photographer: Kerri McCabe
Witness Name:
Direction: SW
Time: 09:06:31 Tom McKay
Description: Latitude:
Looking SW, this photo shows a tank that has been labeled "not in service" in
preparation for permanent closure.
3332'45.396" N
Longitude: 9313'8.436" W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 5
Facility/Location:
Nevada Oil, LLC Irma Nacatoch Unit Tank Battery 28
City: Willisville
County: Nevada County
State: AR
Filename: R0011275.JPG
Photo Date: 01/14/2026
Photographer: Kerri McCabe
Witness Name:
Direction: SSW
Time: 09:13:49 Tom McKay
Description: Latitude:
Looking SSW, this photo shows the same tank from Photo No. 4 that Nevada Oil, LLC
plated (i.e., removed the manway) in preparation for permanent closure.
3332'46.206" N
Longitude: 9313'8.418" W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 6
Facility/Location:
Nevada Oil, LLC Irma Nacatoch Unit Tank Battery 28
City: Willisville
County: Nevada County
State: AR
Filename: R0011276.JPG
Photo Date: 01/14/2026
Photographer: Kerri McCabe
Witness Name:
Direction: S
Time: 09:08:40 Tom McKay
Description: Latitude:
Looking S, this photo shows the sump system for the facility and loose oil inside the tank
battery.
3332'46.062" N
Longitude: 9313'8.688" W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 7
Facility/Location:
Nevada Oil, LLC Irma Nacatoch Unit Tank Battery 28
City: Willisville
County: Nevada County
State: AR
Filename: R0011279.JPG
Photo Date: 01/14/2026
Photographer: Kerri McCabe
Witness Name:
Direction: SW
Time: 09:18:20 Tom McKay
Description: Latitude:
Looking SW, this photo shows a close-up view of the sump area with sump pump and
loose oil.
3332'45.774" N
Longitude: 9313'8.238" W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 8
Facility/Location:
Nevada Oil, LLC Irma Nacatoch Unit Tank Battery 28
City: Willisville
County: Nevada County
State: AR
Filename: R0011280.JPG
Photo Date: 01/14/2026
Photographer: Kerri McCabe
Witness Name:
Direction: SW
Time: 09:15:02 Tom McKay
Description: Looking SW, this photo shows active leaks from valves at an oil storage tank.
Latitude: 3332'46.266" N
Longitude: 9313'7.572" W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 9
Facility/Location:
Nevada Oil, LLC Irma Nacatoch Unit Tank Battery 28
City: Willisville
County: Nevada County
State: AR
Filename: R0011281.JPG
Photo Date: 01/14/2026
Photographer: Kerri McCabe
Witness Name:
Direction: SW
Time: 09:21:20 Tom McKay
Description: Latitude:
Looking SW, this photo shows an additional active leak from a valve for one of the oil
storage tanks.
3332'45.858" N
Longitude: 9313'8.304" W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 10
Facility/Location:
Nevada Oil, LLC Irma Nacatoch Unit Tank Battery 28
City: Willisville
County: Nevada County
State: AR
Filename: R0011282.JPG
Photo Date: 01/14/2026
Photographer: Kerri McCabe
Witness Name:
Direction: S
Time: 09:17:04 Tom McKay
Description: Looking S, this photo shows an active leak from a valve for one of the oil storage tanks.
Latitude: 3332'45.846" N
Longitude: 9313'8.01" W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 11
Facility/Location:
Nevada Oil, LLC Irma Nacatoch Unit Tank Battery 28
City: Willisville
County: Nevada County
State: AR
Filename: R0011283.JPG
Photo Date: 01/14/2026
Photographer: Kerri McCabe
Witness Name:
Direction: SSW
Time: 09:23:26 Tom McKay
Description: Latitude:
Looking SSW, this photo shows an open-topped skimming tank for additional oil/water
separation.
3332'45.972" N
Longitude: 9313'8.07" W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 12
Facility/Location:
Nevada Oil, LLC Irma Nacatoch Unit Tank Battery 28
City: Willisville
County: Nevada County
State: AR
Filename: R0011284.JPG
Photo Date: 01/14/2026
Photographer: Kerri McCabe
Witness Name:
Direction: SSW
Time: 09:19:14 Tom McKay
Description: Looking SSW, this photo shows a gap between a tank and the ground.
Latitude: 3332'45.846" N
Longitude: 9313'8.346" W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 13
Facility/Location:
Nevada Oil, LLC Irma Nacatoch Unit Tank Battery 28
City: Willisville
County: Nevada County
State: AR
Filename: R0011285.JPG
Photo Date: 01/14/2026
Photographer: Kerri McCabe
Witness Name:
Direction: S
Time: 09:21:28 Tom McKay
Description: Looking S, this photo shows an active leak from a valve for one of the oil storage tanks.
Latitude: 3332'45.846" N
Longitude: 9313'8.31" W