Document 3Q5NkJjq0oDpdqb6keMVQ0Q23

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 03/05/2025 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: W M Operating, Inc. HGC Lewis-Denman Tank Battery From Willisville, State Highway 371 North, right on Hwy 76, right on Nevada Rd 161, and then right onto an oilfield lease road at 33.535379, -93.270251. Willisville, AR 71730 151 Curry Field Rd Stephens, AR 71764 Nevada County 870-947-0415 Kelly Lamkin (870-947-0415) Person Responsible for Operation kellylamkin@gmail.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: N/A ARU002291 N/A 211111 1311 Personnel participating in inspection: Kerri McCabe (lead) EPA / Region 6 ECDW Michael Blaha EPA / Region 6 ECDW Inspector / Enforcement Officer Inspector / Enforcement Officer EPA Lead Inspector Signature/Date Supervisor Signature/Date KERRI MCCABE Kerri McCabe Digitally signed by KERRI MCCABE Date: 2025.04.10 15:56:44 -05'00' Date JEANNE ECKHART Date: 2025.04.14 07:40:20 -05'00' Digitally signed by JEANNE ECKHART Jeanne Eckhart Date 6ENFORM-019-R8.2 (02/12/2020) 1 Section I - INTRODUCTION W M Operating, Inc. / HGC Lewis-Denman Tank Battery (ARU002291 / CWA) Inspection Date 03/05/2025 PURPOSE OF THE INSPECTION EPA Region 6 inspectors Kerri McCabe (lead) and Michael Blaha arrived at the W M Operating, Inc. / HGC Lewis-Denman Tank Battery ("facility") located from State Highway 371 North, right on Hwy 76, right on Nevada Rd 161, and then right onto an oilfield lease road at 33.535379, -93.270251 in Willisville, Nevada County, Arkansas; at 1345 on 03/05/2025 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 W M Operating, Inc. / HGC Lewis-Denman Tank Battery facility, which contains four (4) tanks for crude oil and saltwater storage, two (2) separators/treaters, and one (1) opentop tank for crude oil separation/skimming. Map 1. Aerial imagery (Google Earth dated 08/03/2023) of the W M Operating, Inc. / HGC LewisDenman Tank Battery facility. 2 Section II - OBSERVATIONS W M Operating, Inc. / HGC Lewis-Denman Tank Battery (ARU002291 / CWA) Inspection Date 03/05/2025 I observed the facility signage, secondary containment, pipes and valves, storage tanks, and separators/treaters; see Appendix 1 (Photographs Log), Photos No. 1 through No. 3. For additional GPS location and photo metadata, see Appendix 1. I observed product transfer lines outside secondary containment without catchment buckets, see Photos No. 2 and No. 3. I observed a bucket containing crude oil on the berm of the secondary containment, see Photos No. 2 through No. 4. I observed a pipe with a replaced cap and a new motor/pump inside secondary containment, see Photos No. 5 and No. 6. I observed an open-top tank in the sump area of the secondary containment, see Photos No. 7 and No. 9. I observed the drainpipe for the secondary containment, see Photo No. 8. I observed loose crude oil and saltwater inside secondary containment, see Photos No. 5 through No. 7 and Photos No. 9 through No. 11. Section III - AREAS OF CONCERN No closing conference was held due to no personnel with W M Operating, Inc. being present during the inspection. Areas of concern at the time of the inspection include the following: Product transfer lines outside secondary containment without catchment buckets (Photos No. 2 and No. 3), A bucket containing crude oil on the berm of the secondary containment (Photos No. 2 and No. 4), Loose crude oil and saltwater inside secondary containment (Photos No. 5 through No. 7 and Photos No. 9 through No. 11). 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 - 11 photos taken 03/05/2025. 3 W M Operating, Inc. / HGC Lewis-Denman Tank Battery (ARU002291 / CWA) Inspection Date 03/05/2025 Appendix 1 Photograph Log 11 Photos UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: From Willisville (Irma Community), State Hwy 371, right on Hwy 76, then right on Nevada Rd 162, right onto an oilfield lease road at 33.535379, -93.270251. City: Willisville (Irma) County/Parish: Nevada State: Arkansas Photo File Name: 100-0748 Orientation: 61 ENE Date of Photo: 03/05/2025 Time of Photo: 1349 Latitude: 33.535567 Longitude: -93.270217 Photographer: Kerri McCabe Description: Looking ENE, this photo shows the signage at the HGC Lewis-Denman Tank Battery ("facility"). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: From Willisville (Irma Community), State Hwy 371, right on Hwy 76, then right on Nevada Rd 162, right onto an oilfield lease road at 33.535379, -93.270251. City: Willisville (Irma) County/Parish: Nevada State: Arkansas Photo File Name: 100-0749 Orientation: 69 ENE Date of Photo: 03/05/2025 Time of Photo: 1349 Latitude: 33.535483 Longitude: -93.270250 Photographer: Kerri McCabe Description: Looking ENE, this photo shows an overview of the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: From Willisville (Irma Community), State Hwy 371, right on Hwy 76, then right on Nevada Rd 162, right onto an oilfield lease road at 33.535379, -93.270251. City: Willisville (Irma) County/Parish: Nevada State: Arkansas Photo File Name: 100-0750 Orientation: 107 ESE Date of Photo: 03/05/2025 Time of Photo: 1350 Latitude: 33.535567 Longitude: -93.270217 Photographer: Kerri McCabe Description: Looking ESE, this photo shows the front view of the inside and outside of the secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: From Willisville (Irma Community), State Hwy 371, right on Hwy 76, then right on Nevada Rd 162, right onto an oilfield lease road at 33.535379, -93.270251. City: Willisville (Irma) County/Parish: Nevada State: Arkansas Photo File Name: 100-0752 Orientation: 71 ENE Date of Photo: 03/05/2025 Time of Photo: 1350 Latitude: 33.535550 Longitude: -93.270183 Photographer: Kerri McCabe Description: Looking ENE, this photo shows a bucket full of crude oil on the berm of the secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: From Willisville (Irma Community), State Hwy 371, right on Hwy 76, then right on Nevada Rd 162, right onto an oilfield lease road at 33.535379, -93.270251. City: Willisville (Irma) County/Parish: Nevada State: Arkansas Photo File Name: 100-0753 Orientation: 50 NE Date of Photo: 03/05/2025 Time of Photo: 1350 Latitude: 33.535483 Longitude: -93.270100 Photographer: Kerri McCabe Description: Looking NE, this photo shows a cap that has been replaced inside the secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: From Willisville (Irma Community), State Hwy 371, right on Hwy 76, then right on Nevada Rd 162, right onto an oilfield lease road at 33.535379, -93.270251. City: Willisville (Irma) County/Parish: Nevada State: Arkansas Photo File Name: 100-0754 Orientation: 356 N Date of Photo: 03/05/2025 Time of Photo: 1351 Latitude: 33.535417 Longitude: -93.270017 Photographer: Kerri McCabe Description: Looking N, this photo shows a motor inside secondary containment that has been replaced. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: From Willisville (Irma Community), State Hwy 371, right on Hwy 76, then right on Nevada Rd 162, right onto an oilfield lease road at 33.535379, -93.270251. City: Willisville (Irma) County/Parish: Nevada State: Arkansas Photo File Name: 100-0755 Orientation: 71 ENE Date of Photo: 03/05/2025 Time of Photo: 1351 Latitude: 33.535417 Longitude: -93.269983 Photographer: Kerri McCabe Description: Looking ENE, this photo shows the sump area of the secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: From Willisville (Irma Community), State Hwy 371, right on Hwy 76, then right on Nevada Rd 162, right onto an oilfield lease road at 33.535379, -93.270251. City: Willisville (Irma) County/Parish: Nevada State: Arkansas Photo File Name: 100-0756 Orientation: 278 W Date of Photo: 03/05/2025 Time of Photo: 1352 Latitude: 33.535633 Longitude: -93.269717 Photographer: Kerri McCabe Description: Looking W, this photo shows the drainpipe for the secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 Location: From Willisville (Irma Community), State Hwy 371, right on Hwy 76, then right on Nevada Rd 162, right onto an oilfield lease road at 33.535379, -93.270251. City: Willisville (Irma) County/Parish: Nevada State: Arkansas Photo File Name: 100-0757 Orientation: 250 WSW Date of Photo: 03/05/2025 Time of Photo: 1352 Latitude: 33.535583 Longitude: -93.269867 Photographer: Kerri McCabe Description: Looking WSW, this photo shows an open-top tank used as a skimmer for the sump area of the secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 10 Location: From Willisville (Irma Community), State Hwy 371, right on Hwy 76, then right on Nevada Rd 162, right onto an oilfield lease road at 33.535379, -93.270251. City: Willisville (Irma) County/Parish: Nevada State: Arkansas Photo File Name: 100-0758 Orientation: 322 NW Date of Photo: 03/05/2025 Time of Photo: 1352 Latitude: 33.535600 Longitude: -93.270017 Photographer: Kerri McCabe Description: Looking NW, this photo shows loose crude oil and saltwater inside secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 11 Location: From Willisville (Irma Community), State Hwy 371, right on Hwy 76, then right on Nevada Rd 162, right onto an oilfield lease road at 33.535379, -93.270251. City: Willisville (Irma) County/Parish: Nevada State: Arkansas Photo File Name: 100-0759 Orientation: 131 SE Date of Photo: 03/05/2025 Time of Photo: 1353 Latitude: 33.535683 Longitude: -93.270117 Photographer: Kerri McCabe Description: Looking SE, this photo shows an additional view of the loose crude oil and saltwater inside secondary containment.