Document 3Qk9kOr4Mg3bqeaN7M1Ry8gp6
Region 6 - Enforcement & Compliance Assurance Division
INSPECTION REPORT
Inspection Date(s): Media Program: Regulatory Program(s)
12/02/2025 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:
Pharr, Billy W (dba B Pharr Operating, LLC)
Bo Gregory #2 SWD Tank Battery
In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease
road at 33.253333, -92.538889.
El Dorado, AR, 71730
P.O. Box 130
Emerson, AR, 71740
Union County
870-904-5573
Billy Pharr
Owner / Operator
bp@hydrooil.net
FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC:
N/A ARU002254 N/A 211111 1311
Personnel participating in inspection:
Kerri McCabe (lead)
EPA / Region 6 ECDW
Uma Lad
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: 2026.01.27 07:58:38 -06'00'
Date
JEANNE ECKHART Date: 2026.01.27 09:25:55 -06'00' Digitally signed by JEANNE ECKHART
Jeanne Eckhart
Date
6ENFORM-019-R8.2 (02/12/2020)
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Pharr, Billy W (dba B Pharr Operating, LLC) / Bo Gregory #2 SWD Tank Battery (ARU002254 / CWA) Inspection Date 12/02/2025
Section I - INTRODUCTION PURPOSE OF THE INSPECTION EPA Region 6 inspectors Kerri McCabe (lead) and Uma Lad arrived at the Pharr, Billy W (dba B Pharr Operating, LLC) / Bo Gregory #2 SWD Tank Battery ("facility") at 1500 on 12/02/2025 for an unannounced follow-up inspection. The facility is located from Highway 63 E, then Armer Rd, left onto an oil lease road at 33.253333, -92.538889. 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. The facility was originally inspected by Inspector Kerri McCabe on 10/08/2024. FACILITY DESCRIPTION EPA conducted a follow-up inspection on the Pharr, Billy W (dba B Pharr Operating, LLC) / Bo Gregory #2 SWD Tank Battery, which contained one (1) tank battery, four (4) storage/separation tanks for crude oil and saltwater, and two (2) Saltwater Disposal (SWD) wells.
Map 1. Aerial imagery (Google Earth dated 02/01/2025) of the Pharr, Billy W (dba B Pharr Operating, LLC) - Bo Gregory #2 SWD Tank Battery.
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Pharr, Billy W (dba B Pharr Operating, LLC) / Bo Gregory #2 SWD Tank Battery (ARU002254 / CWA) Inspection Date 12/02/2025
Section II - OBSERVATIONS I observed the Pharr, Billy W (B Pharr Operating, LLC) / Bo Gregory #2 SWD Tank Battery signage and associated secondary containment, storage tanks, separators/treaters, and saltwater disposal (SWD) well; see Appendix 1 (Photograph Log), Photo No. 1. For additional GPS location and photo metadata, see Appendix 1. I observed loose oil and oil staining inside the secondary containment, see Photo No. 2 through No. 5. I observed an active leak of saltwater from a valve from a tank inside secondary containment, see Photo No. 5. I observed disturbed soil at the drainpipe for the secondary containment berm, see Photo No. 6 through No. 10. I observed the drainpipe for the secondary containment berm, see Photo No. 11. I observed disturbed soil and stormwater flow indicators leading into a wooded area adjacent to the secondary containment berm, see Photo No. 12 through No. 14. Section III - AREAS OF CONCERN No closing conference was held due to no personnel with Pharr, Billy W (dba B Pharr Operating, LLC) being present during the inspection. In September 2025, EPA issued an Administrative Order (AO) to the operator for this site. Areas of concern at the time of the inspection include the following:
Loose, residual crude oil inside and outside secondary containment at the facility (Photos No. 25),
Crude oil and pooled saltwater inside secondary containment (Photos No. 2-5), and Open drainpipe for secondary containment berm without a valve or cap (Photo 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 - 14 photos taken 12/02/2025.
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Pharr, Billy W (dba B Pharr Operating, LLC) / Bo Gregory #2 SWD Tank Battery (ARU002254 / CWA) Inspection Date 12/02/2025
Appendix 1 Photograph Log
14 Photos
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 1
Facility/Location:
Pharr, Billy W (dba B Pharr Operating) - Bo Gregory 2 SWD Tank Battery
City: El Dorado
County: Union County
State: AR
Direction: SW
Filename: R0011018.JPG
Photo Date: 12/02/2025
Time: 15:35:55
Photographer: Kerri McCabe
Witness Name: Uma Lad
Description: Latitude:
Looking SW, this photo shows the signage identifying the company and lease names of
the B Pharr Operating - Bo Gregory 2 SWD Tank Battery (facility).
3315'12.522" N
Longitude: 9232'20.538" W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 2
Facility/Location:
Pharr, Billy W (dba B Pharr Operating) - Bo Gregory 2 SWD Tank Battery
City: El Dorado
County: Union County
State: AR
Direction: SE
Filename: R0011019.JPG
Photo Date: 12/02/2025
Time: 15:36:27
Photographer: Kerri McCabe
Witness Name: Uma Lad
Description: Latitude:
Looking SE, this photo shows an interior view of the sump area of the containment with
oil staining on the levee and oil sheen on the surface of accumulated stormwater.
3315'12.696" N
Longitude: 9232'20.946" W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 3
Facility/Location:
Pharr, Billy W (dba B Pharr Operating) - Bo Gregory 2 SWD Tank Battery
City: El Dorado
County: Union County
State: AR
Direction: NE
Filename: R0011020.JPG
Photo Date: 12/02/2025
Time: 15:36:53
Photographer: Kerri McCabe
Witness Name: Uma Lad
Description: Latitude:
Looking ENE, this photo shows an interior view of the storage tanks in front of the sump
area inside containment. The photo also shows oil staining on the containment levee,
loose oil around tanks, and oil sheening on the surface of accumulated stormwater.
3315'12.306" N
Longitude: 9232'20.988" W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 4
Facility/Location:
Pharr, Billy W (dba B Pharr Operating) - Bo Gregory 2 SWD Tank Battery
City: El Dorado
County: Union County
State: AR
Direction: NE
Filename: R0011021.JPG
Photo Date: 12/02/2025
Time: 15:36:00
Photographer: Kerri McCabe
Witness Name: Uma Lad
Description: Latitude:
Looking NE, this photo shows the interior view of the sump area inside containment with
oil staining on the containment levee and oil sheening on the surface of accumulated
stormwater.
3315'12.552" N
Longitude: 9232'20.46" W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 5
Facility/Location:
Pharr, Billy W (dba B Pharr Operating) - Bo Gregory 2 SWD Tank Battery
City: El Dorado
County: Union County
State: AR
Direction: NE
Filename: R0011022.JPG
Photo Date: 12/02/2025
Time: 15:36:37
Photographer: Kerri McCabe
Witness Name: Uma Lad
Description: Latitude:
Looking NNE, this photo shows the storage tanks used for crude oil and saltwater
storage. This photo also shows loose oil and oil sheening inside containment.
3315'12.438" N
Longitude: 9232'21.06" W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 6
Facility/Location:
Pharr, Billy W (dba B Pharr Operating) - Bo Gregory 2 SWD Tank Battery
City: El Dorado
County: Union County
State: AR
Direction: NE
Filename: R0011023.JPG
Photo Date: 12/02/2025
Time: 15:42:10
Photographer: Kerri McCabe
Witness Name: Uma Lad
Description: Latitude:
Looking NE, this photo shows both the exterior and interior of the containment levee
with disturbed soil observed around the drainpipe.
3315'12.036" N
Longitude: 9232'20.616" W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 7
Facility/Location:
Pharr, Billy W (dba B Pharr Operating) - Bo Gregory 2 SWD Tank Battery
City: El Dorado
County: Union County
State: AR
Direction: NE
Filename: R0011024.JPG
Photo Date: 12/02/2025
Time: 15:37:08
Photographer: Kerri McCabe
Witness Name: Uma Lad
Description: Latitude:
Looking NE, this photo shows an additional view from Photo #6 with disturbed soil and
the valve from the drainpipe removed.
3315'12.246" N
Longitude: 9232'20.652" W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 8
Facility/Location:
Pharr, Billy W (dba B Pharr Operating) - Bo Gregory 2 SWD Tank Battery
City: El Dorado
County: Union County
State: AR
Direction: N
Filename: R0011025.JPG
Photo Date: 12/02/2025
Time: 15:37:15
Photographer: Kerri McCabe
Witness Name: Uma Lad
Description: Latitude:
Looking N, this photo shows a closeup of the valve that had been removed from the
drainpipe from Photo #7.
3315'12.198" N
Longitude: 9232'20.598" W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 9
Facility/Location:
Pharr, Billy W (dba B Pharr Operating) - Bo Gregory 2 SWD Tank Battery
City: El Dorado
County: Union County
State: AR
Direction: W
Filename: R0011026.JPG
Photo Date: 12/02/2025
Time: 15:38:10
Photographer: Kerri McCabe
Witness Name: Uma Lad
Description: Latitude:
Looking W, this photo shows the interior view of a disturbed area within the levee of the
containment structure. This photo also shows a larger area of disturbed soil and a
saltwater disposal (SWD) in the background.
3315'12.21" N
Longitude: 9232'20.28" W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 10
Facility/Location:
Pharr, Billy W (dba B Pharr Operating) - Bo Gregory 2 SWD Tank Battery
City: El Dorado
County: Union County
State: AR
Direction: N
Filename: R0011027.JPG
Photo Date: 12/02/2025
Time: 15:38:46
Photographer: Kerri McCabe
Witness Name: Uma Lad
Description: Latitude:
Looking N, this photo shows the exterior view of the disturbed area within the
containment levee.
3315'12.558" N
Longitude: 9232'20.16" W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 11
Facility/Location:
Pharr, Billy W (dba B Pharr Operating) - Bo Gregory 2 SWD Tank Battery
City: El Dorado
County: Union County
State: AR
Direction: N
Filename: R0011028.JPG
Photo Date: 12/02/2025
Time: 15:41:24
Photographer: Kerri McCabe
Witness Name: Uma Lad
Description: Latitude:
Looking N, this photo shows the exterior view of the drainpipe for the containment
structure with the valve and cap removed.
3315'12.03" N
Longitude: 9232'20.376" W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 12
Facility/Location:
Pharr, Billy W (dba B Pharr Operating) - Bo Gregory 2 SWD Tank Battery
City: El Dorado
County: Union County
State: AR
Direction: NE
Filename: R0011029.JPG
Photo Date: 12/02/2025
Time: 15:41:41
Photographer: Kerri McCabe
Witness Name: Uma Lad
Description: Latitude:
Looking NE, this photo shows an area outside containment with disturbed soil and
stormwater (surface) flow indicators.
3315'12.042" N
Longitude: 9232'20.436" W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 13
Facility/Location:
Pharr, Billy W (dba B Pharr Operating) - Bo Gregory 2 SWD Tank Battery
City: El Dorado
County: Union County
State: AR
Direction: NE
Filename: R0011030.JPG
Photo Date: 12/02/2025
Time: 15:42:21
Photographer: Kerri McCabe
Witness Name: Uma Lad
Description: Latitude:
Looking ENE, this photo shows a continuation of the stormwater flow path and disturbed
soil from Photo #12.
3315'12.06" N
Longitude: 9232'20.472" W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 14
Facility/Location:
Pharr, Billy W (dba B Pharr Operating) - Bo Gregory 2 SWD Tank Battery
City: El Dorado
County: Union County
State: AR
Direction: NE
Filename: R0011031.JPG
Photo Date: 12/02/2025
Time: 15:42:35
Photographer: Kerri McCabe
Witness Name: Uma Lad
Description: Latitude:
Looking ENE, this photo shows a continuation of the stormwater flow path and disturbed
soil from Photo #13.
3315'12.018" N
Longitude: 9232'20.388" W