Document 6bg7Y3aRXOJ9MBvxG1nxw7Dzo
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:
C12: Arkansas Oil, LLC
Midway Smackover Unit Tract #17 Tank Battery
From Lewisville (Baker Community), at State Hwy 82 East, left on State Hwy
29, right on Lafayette CR 25, and then right onto an oilfield lease road at
33.459617, -93.582800.
Lewisville, AR 71845
Hwy 25 1124
Lowerville, AR 71545
Lafayette County
501-772-3456
Paul Appel (832-628-3016)
Person Responsible for Operation
Robert Thomasson, Representative / robert@standardgas.org
FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC:
N/A ARU002304 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
Paul Appel
C12: Arkansas Oil, LLC
Robert Thomasson
C12: Arkansas Oil, LLC
Jeff Buehler
C12: Arkansas Oil, LLC
Michael Pearson
C12: Arkansas Oil, LLC
Inspector / Enforcement Officer Inspector / Enforcement Officer SEE Inspector Spill Coordinator Regulator Compliance Coordinator Emergency Contact Pumper
EPA Lead Inspector Signature/Date
Supervisor Signature/Date
KERRI MCCABE
Kerri McCabe
Digitally signed by KERRI MCCABE Date: 2026.03.04 07:24:31 -06'00'
Date
JEANNE ECKHART Date: 2026.03.04 11:28:44 -06'00' Digitally signed by JEANNE ECKHART
Jeanne Eckhart
Date
6ENFORM-019-R8.2 (02/12/2020)
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C12: Arkansas Oil, LLC / MSU Tract #17 Tank Battery (ARU002304 / 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 C12: Arkansas Oil, LLC / Midway Smackover Unit Tract #17 Tank Battery ("facility") located from State Highway 82 East, left on State Highway 29, right on Lafayette County Road 25, and then right onto an oilfield lease road at 33.459617, -93.582800 in Lewisville (Baker Community), Lafayette County, Arkansas; at 1300 on 01/14/2026 for an announced inspection. Mr. Paul Appel 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 04/17/2025 under the Brine Program. FACILITY DESCRIPTION EPA conducted an inspection on the C12: Arkansas Oil, LLC / Midway Smackover Unit Tract #17 Tank Battery facility, which contains four (4) tank batteries with a total of ten (10) tanks that include storage, separation, and free water knock out (FWKO) for crude oil and saltwater processing and storage.
Map 1. Aerial imagery (Google Earth dated 10/30/2023) of the C12: Arkansas Oil, LLC / Midway Smackover Unit Tract #17 Tank Battery facility.
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C12: Arkansas Oil, LLC / MSU Tract #17 Tank Battery (ARU002304 / CWA) Inspection Date 01/14/2026
Section II - OBSERVATIONS I observed the facility signage, tank batteries, pipes and valves, storage tanks, and separators/treaters; see Appendix 1 (Photographs Log), Photos No. 1 and No. 2. For additional GPS location and photo metadata, see Appendix 1. I observed a tank battery with a "test" tank and the associated load line, see Photos No. 3 and No. 4. I observed loose oil inside the oil storage tank battery (Area 1), see Photo No. 5. I observed the saltwater disposal (SWD) tank battery (Area 2) and drainpipe, see Photos No. 6 and No. 7. I observed the separator tank battery (Area 3) and berm that C12: Arkansas Oil, LLC personnel repaired since the 04/17/2025 inspection, see Photos No. 8 and No. 9. I observed C12: Arkansas Oil, LLC personnel remediate the loose oil in the oil storage tank battery (Area 1), see Photos No. 10 and No. 11. Section III - AREAS OF CONCERN EPA Region 6 inspectors held a closing conference with Mr. Paul Appel of C12: Arkansas Oil, LLC after the inspection. Areas of concern under the SPCC rule at the time of the inspection include the following: Load line for "test" tank outside secondary containment, 40 CFR 112.7(c) (Photos No. 2 through
No. 4), and Loose oil inside the oil storage tank battery (Area 1), 40 CFR 112.9(b)(1) (Photo No. 5); C12:
Arkansas Oil, LLC personnel remediated the loose oil during the inspection (Photos No. 10 and 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. SEE Inspector Tom McKay will address SPCC rule concerns. Section V - LIST OF APPENDICES Appendix 1 - Photograph Log - 11 photos taken on 01/14/2026.
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C12: Arkansas Oil, LLC / MSU Tract #17 Tank Battery (ARU002304 / CWA) Inspection Date 01/14/2026
Appendix 1 Photograph Log
11 Photos
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 1
Facility/Location:
C12: Arkansas Oil, LLC Midway Smackover Unit Tract 17
City: Lewisville
County: Lafayette County
State: AR
Filename: R0011291.JPG
Photo Date: 01/14/2026
Photographer: Kerri McCabe
Witness Name:
Direction: SW
Time: 13:16:02 Tom McKay
Description: Latitude:
Looking SSW, this photo shows the signage for the Midway Smackover Unit Tract 17 Tank
Battery ("facility").
3327'34.782" N
Longitude: 9334'58.344" W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 2
Facility/Location:
C12: Arkansas Oil, LLC Midway Smackover Unit Tract 17
City: Lewisville
County: Lafayette County
State: AR
Filename: R0011292.JPG
Photo Date: 01/14/2026
Photographer: Kerri McCabe
Witness Name:
Direction: SW
Time: 13:17:08 Tom McKay
Description: Looking SSW, this photo shows an overview of the facility.
Latitude: 3327'33.786" N
Longitude: 9334'58.374" W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 3
Facility/Location:
C12: Arkansas Oil, LLC Midway Smackover Unit Tract 17
City: Lewisville
County: Lafayette County
State: AR
Filename: R0011293.JPG
Photo Date: 01/14/2026
Photographer: Kerri McCabe
Witness Name:
Direction: S
Time: 13:16:49 Tom McKay
Description: Looking S, this photo shows the tank battery for a "test" tank.
Latitude: 3327'33.78" N
Longitude: 9334'58.242" W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 4
Facility/Location:
C12: Arkansas Oil, LLC Midway Smackover Unit Tract 17
City: Lewisville
County: Lafayette County
State: AR
Filename: R0011294.JPG
Photo Date: 01/14/2026
Photographer: Kerri McCabe
Witness Name:
Direction: S
Time: 13:24:04 Tom McKay
Description: Latitude:
Looking S, this photo shows the load line for the "test" tank battery without a secondary
containment.
3327'34.716" N
Longitude: 9334'57.546" W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 5
Facility/Location:
C12: Arkansas Oil, LLC Midway Smackover Unit Tract 17
City: Lewisville
County: Lafayette County
State: AR
Filename: R0011295.JPG
Photo Date: 01/14/2026
Photographer: Kerri McCabe
Witness Name:
Direction: SW
Time: 13:18:11 Tom McKay
Description: Looking WSW, this photo shows loose oil inside the FWKO tank battery.
Latitude: 3327'34.08" N
Longitude: 9334'58.098" W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 6
Facility/Location:
C12: Arkansas Oil, LLC Midway Smackover Unit Tract 17
City: Lewisville
County: Lafayette County
State: AR
Filename: R0011296.JPG
Photo Date: 01/14/2026
Photographer: Kerri McCabe
Witness Name:
Direction: SW
Time: 13:26:28 Tom McKay
Description: Latitude:
Looking SW, this photo shows an overview of the saltwater disposal (SWD) injection well
tank battery with a repaired containment berm.
3327'35.4" N
Longitude: 9334'57.93" W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 7
Facility/Location:
C12: Arkansas Oil, LLC Midway Smackover Unit Tract 17
City: Lewisville
County: Lafayette County
State: AR
Filename: R0011297.JPG
Photo Date: 01/14/2026
Photographer: Kerri McCabe
Witness Name:
Direction: SW
Time: 13:29:25 Tom McKay
Description: Latitude:
Looking WSW, this photo shows the drainpipe for the SWD tank battery with closed
valve and cap.
3327'36.036" N
Longitude: 9334'56.898" W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 8
Facility/Location:
C12: Arkansas Oil, LLC Midway Smackover Unit Tract 17
City: Lewisville
County: Lafayette County
State: AR
Filename: R0011298.JPG
Photo Date: 01/14/2026
Photographer: Kerri McCabe
Witness Name:
Direction: S
Time: 13:26:42 Tom McKay
Description: Latitude:
Looking S, this photo shows the tank battery for the separators with a repaired
containment berm.
3327'35.562" N
Longitude: 9334'57.852" W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 9
Facility/Location:
C12: Arkansas Oil, LLC Midway Smackover Unit Tract 17
City: Lewisville
County: Lafayette County
State: AR
Filename: R0011299.JPG
Photo Date: 01/14/2026
Photographer: Kerri McCabe
Witness Name:
Direction: SW
Time: 13:31:28 Tom McKay
Description: Latitude:
Looking SW, this photo shows a closeup of the containment berm repairs for Photo No.
8.
3327'36.096" N
Longitude: 9334'55.884" W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 10
Facility/Location:
C12: Arkansas Oil, LLC Midway Smackover Unit Tract 17
City: Lewisville
County: Lafayette County
State: AR
Filename: R0011300.JPG
Photo Date: 01/14/2026
Photographer: Kerri McCabe
Witness Name:
Direction: SW
Time: 13:41:15 Tom McKay
Description: Latitude:
Looking WSW, this photo shows the loose oil from Photo No. 5 removed by C12:
Arkansas Oil, LLC personnel during the inspection.
3327'34.698" N
Longitude: 9334'57.714" W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 11
Facility/Location:
C12: Arkansas Oil, LLC Midway Smackover Unit Tract 17
City: Lewisville
County: Lafayette County
State: AR
Filename: R0011301.JPG
Photo Date: 01/14/2026
Photographer: Kerri McCabe
Witness Name:
Direction: SW
Time: 13:41:42 Tom McKay
Description: Latitude:
Looking WSW, this photo shows the loose oil from Photo No. 5 placed in a drum for
proper disposal.
33 27'34.62" N
Longitude: 9334'57.804" W