Document 6w5e2r3e25qmB9kLnqN1mE3jd

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 4/2/24 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: RCP Production, LLC TD Murphy B-3 SWD Tank Battery From Highway 7 Business, thence Gas Plant Road, thence All Gulf Road, off oil field lease road in Smackover (Sandy Land) at 33.341155, -92.690976 Smackover, AR 71762 134 Daniel Road Smackover, AR 71762 Union County 870-814-9942 Rod Phillips Person Responsible for Operation rod_phillips2000@yahoo.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: N/A ARU002227 N/A 211111 1311 Personnel participating in inspection: Kerri McCabe (lead) EPA / Region 6 ECDW Rod Phillips RCP Production, LLC Inspector / Enforcement Officer Owner / Operator EPA Lead Inspector Signature/Date Supervisor Signature/Date KERRI MCCABE Kerri McCabe Digitally signed by KERRI MCCABE Date: 2024.05.07 07:40:57 -05'00' Date JEANNE ECKHART Date: 2024.05.09 10:47:28 -05'00' Digitally signed by JEANNE ECKHART Jeanne Eckhart Date 6ENFORM-019-R8.2 (02/12/2020) 1 Section I - INTRODUCTION RCP Production, LLC / TD Murphy B-3 SWD Follow-up (ARU002227 / CWA) Inspection Date 04/02/2024 PURPOSE OF THE INSPECTION EPA Region 6 Inspector Kerri McCabe (lead) arrived at the RCP Production, LLC / TD Murphy B-3 SWD Tank Battery release, located off an oil lease road off All Gulf Road in Smackover at 33.341485, 92.686930; at 1630 on 4/2/24 for an announced inspection. Mr. Rod Phillips, RCP Production, LLC; 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. FACILITY DESCRIPTION EPA conducted an inspection on the RCP Production, LLC / TD Murphy B-3 SWD Tank Battery as a followup to a release from the tank battery that had occurred on 3/12/24. EPA collected Total Dissolved Solids (TDS) readings from areas sampled during the 3/12/24 and 3/13/24 inspections. Section II - OBSERVATIONS A Total Dissolved Solids (TDS) reading of 832 mg/L was taken in a pool at a wetland upstream of a culvert in an oil field lease road and downstream of the TD Murphy B-3 SWD tank battery release, see Appendix 1 (Photographs Log), Photo No. 1 through No. 3. For additional GPS location and photo metadata, see Appendix 1. Another TDS reading of 807 mg/L was taken directly downstream of the pool and the culvert in the same conveyance as the first TDS reading, see Photo No. 4 through No. 6. A TDS reading of 562 mg/L, for background comparison, was taken upstream of the pool, see Photo No. 7 through No. 9. A TDS reading of 1,439 mg/L was taken downstream of the wetland area in the receiving stream, see Photo No. 10 through No. 12. A final TDS reading of 1,449 mg/L was taken downstream of the reading from Photo No. 10, see Photo No. 13 through No. 15. A comparison between the facility-owned meter and the Brine Program meter was conducted on samples collected by the operator throughout March 2024, see Photo No. 16. I observed the meter purchased and utilized by the operator, see Photo No. 17. The sample used for analysis comparison was collected on 3/19/24 by the operator, see Photo No. 18. 2 RCP Production, LLC / TD Murphy B-3 SWD Follow-up (ARU002227 / CWA) Inspection Date 04/02/2024 The TDS reading for the 3/19/24 sample reported from the facility-owned meter was 4,500 ppm, see Photo No. 19. The TDS reading for the 3/19/24 sample reported from the Brine Program meter was 4,730 mg/L, see Photo No. 20. All TDS field readings observed throughout the inspection were taken with a properly calibrated, EPAissued, YSI Pro30 Conductivity/TDS/Salinity/Temperature Meter (#Y60530). Section III - AREAS OF CONCERN A closing conference was held with Mr. Rod Phillips, RCP Production, LLC; to discuss the findings of the inspection. Areas of concern at the time of the inspection include the elevated TDS readings from the surface water along the discharge conveyance. 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. A follow-up inspection will be conducted on 5/9/24. Section V - LIST OF APPENDICES Appendix 1 - Photograph Log - 20 photos taken 4/2/24. 3 RCP Production, LLC / TD Murphy B-3 SWD Follow-up (ARU002227 / CWA) Inspection Date 04/02/2024 Appendix 1 Photograph Log 20 Photos UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: RCP Production, LLC - TD Murphy B-3 SWD off Union County Rd 713 from oil field lease road at 33.341155, -92.690976. City: Smackover County/Parish: Union State: Arkansas Photo File Name: P4020034 Orientation: W Date of Photo: 04/02/2024 Time of Photo: 1701 Latitude: 33.341550 Longitude: -92.687078 Photographer: Kerri McCabe Description: Looking W, this photo showed the Total Dissolved Solids (TDS) reading at the pond off All Gulf Rd that is downstream from the TD Murphy B-3 SWD tank battery release. Meter Date / Time TSD / Temperature Sampler / Analyzer YSI Pro30 Conductivity/TDS/Salinity/Temperature Meter #Y60530 April 02, 2024 / 1701 832 mg/L at 24.0 degC Kerri McCabe UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: RCP Production, LLC - TD Murphy B-3 SWD off Union County Rd 713 from oil field lease road at 33.341155, -92.690976. City: Smackover County/Parish: Union State: Arkansas Photo File Name: P4020035 Orientation: SE Date of Photo: 04/02/2024 Time of Photo: 1701 Latitude: 33.341550 Longitude: -92.687078 Photographer: Kerri McCabe Description: Looking SE, this photo showed the upstream view at the TDS reading location in Photo No. 1. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: RCP Production, LLC - TD Murphy B-3 SWD off Union County Rd 713 from oil field lease road at 33.341155, -92.690976. City: Smackover County/Parish: Union State: Arkansas Photo File Name: P4020036 Orientation: SW Date of Photo: 04/02/2024 Time of Photo: 1702 Latitude: 33.341550 Longitude: -92.687078 Photographer: Kerri McCabe Description: Looking SW, this photo showed the downstream view at the TDS reading location in Photo No. 1. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: RCP Production, LLC - TD Murphy B-3 SWD off Union County Rd 713 from oil field lease road at 33.341155, -92.690976. City: Smackover County/Parish: Union State: Arkansas Photo File Name: P4020038 Orientation: W Date of Photo: 04/02/2024 Time of Photo: 1704 Latitude: 33.341412 Longitude: -92.686812 Photographer: Kerri McCabe Description: Looking W, this photo showed the TDS reading directly downstream of the pond off All Gulf Rd that is downstream from the TD Murphy B-3 SWD tank battery release. Meter Date / Time TSD / Temperature Sampler / Analyzer YSI Pro30 Conductivity/TDS/Salinity/Temperature Meter #Y60530 April 02, 2024 / 1704 807 mg/L at 24.4 degC Kerri McCabe UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: RCP Production, LLC - TD Murphy B-3 SWD off Union County Rd 713 from oil field lease road at 33.341155, -92.690976. City: Smackover County/Parish: Union State: Arkansas Photo File Name: P4020039 Orientation: SE Date of Photo: 04/02/2024 Time of Photo: 1704 Latitude: 33.341412 Longitude: -92.686812 Photographer: Kerri McCabe Description: Looking SE, this photo showed the upstream view at the TDS reading location in Photo No. 4. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: RCP Production, LLC - TD Murphy B-3 SWD off Union County Rd 713 from oil field lease road at 33.341155, -92.690976. City: Smackover County/Parish: Union State: Arkansas Photo File Name: P4020040 Orientation: SW Date of Photo: 04/02/2024 Time of Photo: 1704 Latitude: 33.341412 Longitude: -92.686812 Photographer: Kerri McCabe Description: Looking SW, this photo showed the downstream view at the TDS reading location in Photo No. 4. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: RCP Production, LLC - TD Murphy B-3 SWD off Union County Rd 713 from oil field lease road at 33.341155, -92.690976. City: Smackover County/Parish: Union State: Arkansas Photo File Name: P4020041 Orientation: E Date of Photo: 04/02/2024 Time of Photo: 1719 Latitude: 33.341109 Longitude: -92.689790 Photographer: Kerri McCabe Description: Looking E, this photo showed the TDS reading upstream of the pond off All Gulf Rd that is downstream from the TD Murphy B-3 SWD tank battery release. Meter Date / Time TSD / Temperature Sampler / Analyzer YSI Pro30 Conductivity/TDS/Salinity/Temperature Meter #Y60530 April 02, 2024 / 1719 562 mg/L at 20.2 degC Kerri McCabe UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: RCP Production, LLC - TD Murphy B-3 SWD off Union County Rd 713 from oil field lease road at 33.341155, -92.690976. City: Smackover County/Parish: Union State: Arkansas Photo File Name: P4020042 Orientation: E-SE Date of Photo: 04/02/2024 Time of Photo: 1720 Latitude: 33.341109 Longitude: -92.689790 Photographer: Kerri McCabe Description: Looking E-SE, this photo showed the upstream view at the TDS reading location in Photo No. 7. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 Location: RCP Production, LLC - TD Murphy B-3 SWD off Union County Rd 713 from oil field lease road at 33.341155, -92.690976. City: Smackover County/Parish: Union State: Arkansas Photo File Name: P4020043 Orientation: W Date of Photo: 04/02/2024 Time of Photo: 1720 Latitude: 33.341109 Longitude: -92.689790 Photographer: Kerri McCabe Description: Looking W, this photo showed the downstream view at the TDS reading location in Photo No. 7. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 10 Location: RCP Production, LLC - TD Murphy B-3 SWD off Union County Rd 713 from oil field lease road at 33.341155, -92.690976. City: Smackover County/Parish: Union State: Arkansas Photo File Name: P4020044 Orientation: N-NE Date of Photo: 04/02/2024 Time of Photo: 1738 Latitude: 33.344938 Longitude: -92.683762 Photographer: Kerri McCabe Description: Looking N-NE, this photo showed the TDS reading in the receiving stream downstream of the pond off All Gulf Rd that is downstream from the TD Murphy B-3 SWD tank battery release. Meter Date / Time TSD / Temperature Sampler / Analyzer YSI Pro30 Conductivity/TDS/Salinity/Temperature Meter #Y60530 April 02, 2024 / 1738 1,439 mg/L at 21.1 degC Kerri McCabe UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 11 Location: RCP Production, LLC - TD Murphy B-3 SWD off Union County Rd 713 from oil field lease road at 33.341155, -92.690976. City: Smackover County/Parish: Union State: Arkansas Photo File Name: P4020045 Orientation: S-SW Date of Photo: 04/02/2024 Time of Photo: 1739 Latitude: 33.344938 Longitude: -92.683762 Photographer: Kerri McCabe Description: Looking E-SE, this photo showed the upstream view at the TDS reading location in Photo No. 10. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 12 Location: RCP Production, LLC - TD Murphy B-3 SWD off Union County Rd 713 from oil field lease road at 33.341155, -92.690976. City: Smackover County/Parish: Union State: Arkansas Photo File Name: P4020046 Orientation: NW Date of Photo: 04/02/2024 Time of Photo: 1739 Latitude: 33.344938 Longitude: -92.683762 Photographer: Kerri McCabe Description: Looking NW, this photo showed the downstream view at the TDS reading location in Photo No. 10. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 13 Location: RCP Production, LLC - TD Murphy B-3 SWD off Union County Rd 713 from oil field lease road at 33.341155, -92.690976. City: Smackover County/Parish: Union State: Arkansas Photo File Name: P4020047 Orientation: SE Date of Photo: 04/02/2024 Time of Photo: 1748 Latitude: 33.346081 Longitude: -92.682973 Photographer: Kerri McCabe Description: Looking SE, this photo showed the TDS reading in the receiving stream at the bridge crossing downstream of the pond off All Gulf Rd. Meter Date / Time TSD / Temperature Sampler / Analyzer YSI Pro30 Conductivity/TDS/Salinity/Temperature Meter #Y60530 April 02, 2024 / 1748 1,449 mg/L at 21.2 degC Kerri McCabe UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 14 Location: RCP Production, LLC - TD Murphy B-3 SWD off Union County Rd 713 from oil field lease road at 33.341155, -92.690976. City: Smackover County/Parish: Union State: Arkansas Photo File Name: P4020048 Orientation: S-SE Date of Photo: 04/02/2024 Time of Photo: 1748 Latitude: 33.346081 Longitude: -92.682973 Photographer: Kerri McCabe Description: Looking S-SE, this photo showed the upstream view at the TDS reading location in Photo No. 13. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 15 Location: RCP Production, LLC - TD Murphy B-3 SWD off Union County Rd 713 from oil field lease road at 33.341155, -92.690976. City: Smackover County/Parish: Union State: Arkansas Photo File Name: P4020049 Orientation: S-SW Date of Photo: 04/02/2024 Time of Photo: 1748 Latitude: 33.346081 Longitude: -92.682973 Photographer: Kerri McCabe Description: Looking S-SW, this photo showed the downstream view at the TDS reading location in Photo No. 13. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 16 Location: RCP Production, LLC - TD Murphy B-3 SWD off Union County Rd 713 from oil field lease road at 33.341155, -92.690976. City: Smackover County/Parish: Union State: Arkansas Photo File Name: P4020050 Orientation: N-NW Date of Photo: 04/02/2024 Time of Photo: 1751 Latitude: 33.346481 Longitude: -92.683323 Photographer: Kerri McCabe Description: Looking N-NW, this photo showed the water samples collected by Mr. Rod Phillips of RCP Production, LLC. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 17 Location: RCP Production, LLC - TD Murphy B-3 SWD off Union County Rd 713 from oil field lease road at 33.341155, -92.690976. City: Smackover County/Parish: Union State: Arkansas Photo File Name: P4020051 Orientation: N Date of Photo: 04/02/2024 Time of Photo: 1751 Latitude: 33.346481 Longitude: -92.683323 Photographer: Kerri McCabe Description: Looking N, this photo showed the meter (Walfront Model No. EZ-9909SP) used by Mr. Rod Phillips of RCP Production, LLC. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 18 Location: RCP Production, LLC - TD Murphy B-3 SWD off Union County Rd 713 from oil field lease road at 33.341155, -92.690976. City: Smackover County/Parish: Union State: Arkansas Photo File Name: P4020052 Orientation: N Date of Photo: 04/02/2024 Time of Photo: 1752 Latitude: 33.346481 Longitude: -92.683323 Photographer: Kerri McCabe Description: Looking N, this photo showed the March 19, 2024 sample (TDS reading is reported as 3,387 ppm) collected by Mr. Rod Phillips of RCP Production, LLC; this sample was used for meter comparison. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 19 Location: RCP Production, LLC - TD Murphy B-3 SWD off Union County Rd 713 from oil field lease road at 33.341155, -92.690976. City: Smackover County/Parish: Union State: Arkansas Photo File Name: P4020053 Orientation: NW Date of Photo: 04/02/2024 Time of Photo: 1753 Latitude: 33.346481 Longitude: -92.683323 Photographer: Kerri McCabe Description: Looking NW, this photo showed the TDS reading of the March 19, 2024 sample from the meter utilized by Mr. Rod Phillips of RCP Production, LLC.; TDS reading was 4,500 ppm. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 20 Location: RCP Production, LLC - TD Murphy B-3 SWD off Union County Rd 713 from oil field lease road at 33.341155, -92.690976. City: Smackover County/Parish: Union State: Arkansas Photo File Name: P4020054 Orientation: NW Date of Photo: 04/02/2024 Time of Photo: 1755 Latitude: 33.346481 Longitude: -92.683323 Photographer: Kerri McCabe Description: Looking NW, this photo showed the TDS reading of the March 19, 2024 sample from the meter utilized by USEPA Region 6; TDS reading was 4,730 mg/L.