Document 85MEm99Jp4OGQmddBZKpKjXMZ

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: 11/06/2019 Water Brine - CWA Daniel Operating Company, Inc. Hadley Lease 33.157693, -92.396515 El Dorado, Arkansas 71730 322 Morgan Rd. El Dorado, Arkansas 71730 Union County 870-814-7883 David Daniel FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: N/A ARU001254 N/A 21111 1311 Personnel participating in inspection: Kent W. Sanborn EPA 6 ECDWE Environmental Engineer EPA Lead Inspector Signature/Date Supervisor Signature/Date Kent W. Sanborn Digitally signed by Kent W. Sanborn DN: cn=Kent W. Sanborn, o, ou=6EN-WR, email=sanborn.kent@epa.gov, c=US Date: 2019.12.11 11:32:41 -06'00' Kent W. Sanborn Date GUY TIDMORE Digitally signed by GUY TIDMORE Agency, cn=GUY TIDMORE, DN: c=US, o=U.S. Government, ou=Environmental Protection 12 DEC 2019 0.9.2342.19200300.100.1.1=68001003655426 Date: 2019.12.12 10:47:41 -06'00' Guy Tidmore Date 6ENFORM-019-8 (10/31/2019) 1 Section I - INTRODUCTION Daniel Operating Company, Inc. / Hadley Lease Inspection Date: 11/06/2019 PURPOSE OF THE INSPECTION EPA Region 6 inspector K.W. Sanborn visited the Daniel Operating Company, Inc. oil and gas facility located at latitude 33.157693 and longitude -92.396515 near El Dorado, Arkansas on 11/06/2019 for an unannounced inspection. There were no representatives of Daniel Operating Company, Inc. present for the inspection. The inspection was conducted by authority of the Clean Water Act and the Safe Drinking Water Act to determine compliance with the Environmental Protection Agency (EPA) regulations. FACILITY DESCRIPTION The tank battery facility is located on the Hadley Lease. Section II - OBSERVATIONS During the inspection, the secondary containment pit was approximately 1/2 full of fluids, including rainwater and saltwater. With a calibrated YSI Pro 30 conductivity meter, I took a Total Dissolved Solids (TDS) reading of 2,000 milligrams per liter (mg/L) in the road ditch near the tank battery. The separator was inadequate and did not appear to function properly. The secondary containment berms were inadequate and the containment berms seep from the facility towards the road ditch. Section III - AREAS OF CONCERN The secondary containment was inadequate due to seepage and it was 1/2 full of fluids. I measured elevated TDS in a road ditch outside of the facility. I observed an inadequate separator during the inspection. Section IV - FOLLOW UP EPA water enforcement will refer this facility to the EPA SPCC program and will conduct a follow up inspection in approximately 6 months. Section V - LIST OF APPENDICES N/A 2 6ENFORM-019-8 (10/31/2019)