Document 5DMxzw8jyJxR0wDY0DO3Me0de

Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date(s): Media: Regulatory Program(s) April 26, 2018 Water (CWA) NPDES - Brine Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: Diamond 3S, LLC Kennedy 36.586969N, -96.498093W (NE Sect. 1, T 24N, R 7E) Pawhuska, Oklahoma 74056 20102 West Coyote Trail Sand Springs, Oklahoma 74063 Osage Joel Summers (918) 638-9306 FRS Number: Identification/Permit Number: Media Number: NAICS: SIC: N/A OKU000867 N/A 21111 1311 Personnel participating in inspection: Kent W. Sanborn EPA Region 6, 6EN-WR Environmental Engineer 918-557-1615 EPA Lead Inspector Signature/Date Supervisor Signature/Date Sanborn, Kent Digitally signed by Sanborn, Kent DN: cn=Sanborn, Kent, email=Sanborn.Kent@epa.gov Date: 2018.06.18 15:50:39 -05'00' Kent W. Sanborn GUY TIDMORE Digitally signed by GUY TIDMORE DN: c=US, o=U.S. Government, ou=USEPA, ou=Staff, cn=GUY TIDMORE, dnQualifier=0000012807 Date: 2018.06.19 11:26:49 -05'00' Guy Tidmore Date 19 JUN 2018 Date 6ENFORM-019-R7 (2/15/2017) 1 Section I - INTRODUCTION Diamond 3S, LLC/ Kennedy Inspection Date: April 26, 2018 PURPOSE OF THE INSPECTION EPA Region 6 inspector Kent W. Sanborn arrived at the Diamond 3S, LLC lease on the Kennedy property near Pawhuska, Osage County, Oklahoma at about 1:00 PM on April 26, 2018 for an inspection. The inspection was initiated by a reported discharge of fluids into a nearby tributary of Daniel's Run Creek by Diamond 3S LLC, Kennedy #3 injection well. The inspection was a follow-up to inspections conducted March 16, 20, and April 12, 2018. The Bureau of Indian Affairs (BIA) in Pawhuska requested our assistance in addressing the discharge. There were no company representatives at the site during the inspection. I confirmed the discharge from contaminated soil from a previous spill was continuing to enter the tributary of Daniel's Run Creek. I observed no cleanup activity on the site during the inspection. The inspection was conducted under the authority of Section 308 of the CWA. The scope of the inspection was to determine if the facility was in compliance with Clean Water Act, including Section 301, and to identify and document discharges of produced wastewater (brine) to waters of the United States. FACILITY DESCRIPTION The origination point of discharge was a leaking injection well supply line connecting to the well known as the Kennedy Number 3 injection well. This well is also known as EPA inventory ID OS 4349. The line was buried up to the well, and the well was closed in. The flow line was leaking fluids and was connected to the main tank battery. The entire pasture area between the well and the creek was saturated with brine and continued to seep to the tributary of Daniel's Run Creek. Section II - OBSERVATIONS I arrived at the Diamond 3S, LLC, Kennedy lease at about 1:00 pm on April 26, 2018. Photo 1 indicated that the injection line that leaked brine and some oil into the tributary of Daniel's Run Creek had not been moved. Photo 2 shows the ongoing damage to the hillside where the flow path of brine occurred on the surface and subsurface from a previous leak that occurred in March 2018. The ground was still saturated with brine near the tributary (Photo 3). The brine was seeping into the creek (Photo 4). A Specific Conductance field reading was taken with a calibrated YSI 30 Conductivity Meter at the point of entry and was 67.4 milliSiemens (mS), which was converted to 43,810 milligrams/Liter (mg/L) Total Dissolved Solids (TDS) as shown in Appendix 2 (Photo 5 in Appendix 1). The tributary was full after a recent rainfall event (Photo 6). Dam 1 had water and brine running through a pipe and downstream along the tributary of Daniel's Run Creek during the inspection. There was some foam observed on the surface of the tributary. (Photo 7). A Specific Conductance field reading taken at Dam 1 was 65.9 mS, which was converted to 42,835 mg/L TDS as shown in Appendix 2 (Photo 8 in Appendix 1). Dam 2 was full and running over and flowing downstream during the inspection (Photo 9). A dead crayfish was present at the Dam 2 location (Photo 10). A Specific Conductance field reading taken at Dam 2 was 26.55 mS, which was converted to 17,257 mg/L TDS as shown in Appendix 2 (Photo 11 in Appendix 1). I observed that water and brine were also running through Dam 3 during the inspection and flowing south, downstream, as shown in Photos 12 and 13. A Specific Conductance field reading taken at Dam 3 2 Diamond 3S, LLC/ Kennedy Inspection Date: April 26, 2018 was 41.95 mS, which was converted to 27,267 mg/L TDS as shown in Appendix 2 (Photo 14 in Appendix 1). I observed livestock tracks, including cattle tracks, that indicate cattle were at the tributary between Dam 2 and Dam 3 (Photo 15). Photo 16 shows a 4th dam that was built downstream of Dam 3. Water and brine were also running over the dam and flowing south in Daniel's Run Creek. A Specific Conductance field reading taken at Dam 4 was 6.44 mS, which was converted to 4,186 mg/L TDS as shown in Appendix 2 (Photo 17 in Appendix 1). Photo 18 shows the unaffected portion of the tributary of Daniel's Run Creek upstream of the discharge point of entry. A Specific Conductance field reading taken upstream in the tributary and was 749 microSiemens (uS), which was converted to 486 mg/L TDS as shown in Appendix 2 (Photo 19 in Appendix 1). Section III - AREAS OF CONCERN During the inspection, elevated levels of TDS continue to be present in the tributary of Daniel's Run Creek and Daniel's Run Creek due to a previous spill that occurred and contaminated soil continuing to seep brine into the tributary. The brine continues to flow further downstream from the previously documented furthest downstream location indicating new downstream impacts to the tributary and creek. There was minimal remedial activity to prevent further pollution in the tributary and downstream water bodies observed. Additionally, the contaminated flow path and large area of soil saturated with brine was still seeping into the tributary at the point of entry. Section IV - FOLLOW UP A follow up inspection will be conducted as needed. Section V - LIST OF APPENDICES Appendix 1 - Photo Log - 19 photos taken April 26, 2018. Appendix 2 - Table 1 - Conversion from Specific Conductance to Total Dissolved Solids (TDS). 3 Diamond 3S, LLC / Kennedy Inspection Date: 4/26/2018 Appendix 1 Photographic Log (19 photos) UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 36.586969N, -96.498093W (NE Sect. 1, T 24N, R 7E) City: Pawhuska County: Osage State: Oklahoma Photo File Name: Photo 1 (DSC_0001) Orientation: South Date of Photo: 04/26/2018 Time of Photo: 1:37 pm Latitude: 36.586969N Longitude: -96.498093W Photographer: K.W. Sanborn Description: This photo shows where a previous discharge originated from an injection well line located, which was a few yards from Kennedy #3 injection well. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 36.586969N, -96.498093W (NE Sect. 1, T 24N, R 7E) City: Pawhuska County: Osage State: Oklahoma Photo File Name: Photo 2 (DSC_0002) Orientation: Southwest Date of Photo: 04/26/2018 Time of Photo: 1:38 pm Latitude: 36.586969N Longitude: -96.498093W Photographer: K.W. Sanborn Description: The hillside southwest of the point of discharge was dead and saturated with brine during the inspection. The brine was seeping from the contaminated hillside into the tributary of Daniel's Run Creek. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 36.586969N, -96.498093W (NE Sect. 1, T 24N, R 7E) City: Pawhuska County: Osage State: Oklahoma Photo File Name: Photo 3 (DSC_0007) Orientation: Southwest Date of Photo: 04/26/2018 Time of Photo: 1:39 pm Latitude: 36.586514N Longitude: -96.499076W Photographer: K.W. Sanborn Description: The ground next to the tributary was saturated with brine and flowed to the point of entry to the tributary of Daniel's Run Creek. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 36.586969N, -96.498093W (NE Sect. 1, T 24N, R 7E) City: Pawhuska County: Osage State: Oklahoma Photo File Name: Photo 4 (DSC_0009) Orientation: South Date of Photo: 04/26/2018 Time of Photo: 1:40 pm Latitude: 36.586514N Longitude: -96.499076W Photographer: K.W. Sanborn Description: The brine enters the tributary of Daniel's Run Creek here from the large saturated area uphill from the point of entry. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 36.586969N, -96.498093W (NE Sect. 1, T 24N, R 7E) City: Pawhuska County: Osage State: Oklahoma Photo File Name: Photo 5 (DSC_0012) Orientation: Southwest Date of Photo: 04/26/2018 Time of Photo: 1:41 pm Latitude: 36.586514N Longitude: -96.499076W Photographer: K.W. Sanborn Description: A Specific Conductance field reading was taken with a calibrated YSI 30 Conductivity Meter at the point of entry was 67.4 milliSiemens (mS), which was converted to 43,810 milligrams/Liter (mg/L) Total Dissolved Solids (TDS) as shown in Appendix 2. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 36.586969N, -96.498093W (NE Sect. 1, T 24N, R 7E) City: Pawhuska County: Osage State: Oklahoma Photo File Name: Photo 6 (DSC_0013) Orientation: Southwest Date of Photo: 04/26/2018 Time of Photo: 1:41 pm Latitude: 36.586313N Longitude: -96.499364W Photographer: K.W. Sanborn Description: The tributary was shown here backed up behind the first temporary dam, or Dam 1. I observed some bed, bank and riparian vegetation. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 36.586969N, -96.498093W (NE Sect. 1, T 24N, R 7E) City: Pawhuska County: Osage State: Oklahoma Photo File Name: Photo 7 (DSC_0015) Orientation: South Date of Photo: 04/26/2018 Time of Photo: 1:42 pm Latitude: 36.586313N Longitude: -96.499364W Photographer: K.W. Sanborn Description: Dam 1 is shown here and water and brine were running through the pipe and downstream along the tributary of Daniel's Run Creek during the inspection. There was some foam observed on the surface of the tributary. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 36.586969N, -96.498093W (NE Sect. 1, T 24N, R 7E) City: Pawhuska County: Osage State: Oklahoma Photo File Name: Photo 8 (DSC_0017) Orientation: Southwest Date of Photo: 04/26/2018 Time of Photo: 1:43 pm Latitude: 36.586313N Longitude: -96.499364W Photographer: K.W. Sanborn Description: A Specific Conductance field reading taken at Dam 1 was 65.9 mS, which was converted to 42,835 mg/L TDS as shown in Appendix 2. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 36.586969N, -96.498093W (NE Sect. 1, T 24N, R 7E) City: Pawhuska County: Osage State: Oklahoma Photo File Name: Photo 9 (DSC_0019) Orientation: South Date of Photo: 04/26/2018 Time of Photo: 1:48 pm Latitude: 36.585146N Longitude: -96.500020W Photographer: K.W. Sanborn Description: This photo shows the second temporary dam, or Dam 2. Water and brine were also flowing over the dam and flowing downstream in the tributary of Daniel's Run Creek. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 10 36.586969N, -96.498093W (NE Sect. 1, T 24N, R 7E) City: Pawhuska County: Osage State: Oklahoma Photo File Name: Photo 10 (DSC_0018) Orientation: East Date of Photo: 04/26/2018 Time of Photo: 1:45 pm Latitude: 36.585146N Longitude: -96.500020W Photographer: K.W. Sanborn Description: I observed a dead crayfish in the tributary at Dam 2. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 11 36.586969N, -96.498093W (NE Sect. 1, T 24N, R 7E) City: Pawhuska County: Osage State: Oklahoma Photo File Name: Photo 11 (DSC_0020) Orientation: South Date of Photo: 4/26/2018 Time of Photo: 1:49 pm Latitude: 36.585146N Longitude: -96.500020W Photographer: K.W. Sanborn Description: A Specific Conductance field reading taken at Dam 2 was 26.55 mS, which was converted to 17,257 mg/L TDS as shown in Appendix 2. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 12 36.586969N, -96.498093W (NE Sect. 1, T 24N, R 7E) City: Pawhuska County: Osage State: Oklahoma Photo File Name: Photo 12 (DSC_0022) Orientation: South Date of Photo: 4/26/2018 Time of Photo: 1:56 pm Latitude: 36.583809N Longitude: -96.502419W Photographer: K.W. Sanborn Description: This photo shows a third temporary dam, or Dam 3. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 13 36.586969N, -96.498093W (NE Sect. 1, T 24N, R 7E) City: Pawhuska County: Osage State: Oklahoma Photo File Name: Photo 13 (DSC_0021) Orientation: North Date of Photo: 4/26/2018 Time of Photo: 1:49 pm Latitude: 36.583809N Longitude: -96.502419W Photographer: K.W. Sanborn Description: I observed that water and brine were also running through the Dam 3 during the inspection and flowing south, downstream. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 14 36.586969N, -96.498093W (NE Sect. 1, T 24N, R 7E) City: Pawhuska County: Osage State: Oklahoma Photo File Name: Photo 14 (DSC_0023) Orientation: Southwest Date of Photo: 4/26/2018 Time of Photo: 1:56 pm Latitude: 36.583809N Longitude: -96.502419W Photographer: K.W. Sanborn Description: A Specific Conductance field reading taken at Dam 3 was 41.95 mS, which was converted to 27,267 mg/L TDS as shown in Appendix 2. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 15 36.586969N, -96.498093W (NE Sect. 1, T 24N, R 7E) City: Pawhuska County: Osage State: Oklahoma Photo File Name: Photo 15 (DSC_0026) Orientation: Southeast Date of Photo: 4/26/2018 Time of Photo: 1:59 pm Latitude: 36.584833N Longitude: -96.500620W Photographer: K.W. Sanborn Description: I observed livestock tracks, including cattle tracks, that indicate cattle were at the tributary at this location here, between Dam 2 and Dam 3. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 16 36.586969N, -96.498093W (NE Sect. 1, T 24N, R 7E) City: Pawhuska County: Osage State: Oklahoma Photo File Name: Photo 16 (DSC_0027) Orientation: South Date of Photo: 4/26/2018 Time of Photo: 2:03 pm Latitude: 36.582435N Longitude: -96.502429W Photographer: K.W. Sanborn Description: A fourth Dam has been built as shown here, or Dam 4. through the dam at the time of the inspection. Water and brine were flowing UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 17 36.586969N, -96.498093W (NE Sect. 1, T 24N, R 7E) City: Pawhuska County: Osage State: Oklahoma Photo File Name: Photo 17 (DSC_0028) Orientation: South Date of Photo: 4/26/2018 Time of Photo: 2:03 pm Latitude: 36.582035N Longitude: -96.502429W Photographer: K.W. Sanborn Description: A Specific Conductance field reading taken at Dam 4 was 6.44 mS, which was converted to 4,186 mg/L TDS as shown in Appendix 2. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 18 36.586969N, -96.498093W (NE Sect. 1, T 24N, R 7E) City: Pawhuska County: Osage State: Oklahoma Photo File Name: Photo 18 (DSC_0032) Orientation: North Date of Photo: 4/26/2018 Time of Photo: 2:20 pm Latitude: 36.587812N Longitude: -96.498510W Photographer: K.W. Sanborn Description: I observed the tributary of Daniel's Run Creek upstream of the discharge point of entry at this location. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 19 36.586969N, -96.498093W (NE Sect. 1, T 24N, R 7E) City: Pawhuska County: Osage State: Oklahoma Photo file Name: Photo 19 (DSC_0031) Orientation: North Date of Photo: 4/26/2018 Time of Photo: 2:20 pm Latitude: 36.587812N Longitude: -96.498510W Photographer: K.W. Sanborn Description: A Specific Conductance field reading taken upstream in the tributary and was 749 microSiemens (uS), which was converted to 486 mg/L TDS as shown in Appendix 2. Diamond 3S, LLC / Kennedy Inspection Date: 4/26/2018 Appendix 2 Table 1: Conversion of Specific Conductance Readings to Total Dissolved Solids Diamond 3S, LLC / Kennedy Inspection Date: 4/26/2018 Table 1 Conversion from Specific Conductance (milliSiemens) Field Readings to Total Dissolved Solids (milligrams/Liter) Measurements taken with a calibrated YSI 30 Conductivity Meter Inspection Report Photo No. Photo No. 5 Specific Conductance Reading (mS) 67.4 mS Specific Conductance (uS) 67,400 uS Converted Total Dissolved Solids (mg/L)* 43,810 mg/L Photo No. 8 65.9 mS 65,900 uS 42,835 mg/L Photo No. 11 26.55 mS 26,550 uS 17,257.5 mg/L Photo No. 14 41.95 mS 41,950 uS 27,267.5 mg/L Photo No. 17 6.44 mS 6,440 uS 4,186 mg/L Photo No. 19 N/A 749 uS 486.8 mg/L *The default conversion value to convert specific conductance (uS) to Total Dissolved Solids (TDS) used in this inspection report was 0.65. For example, 67,400 uS multiplied by 0.65 equates to 43,810 mg/L TDS.