Document Ddd0RObMo1vnkXj5ZGyEwkrjN
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 #3 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
33.443267, -93.533467.
Lewisville, AR 71845
Hwy 25 1124
Lewisville, 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 ARU002303 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 Regulatory Compliance Coordinator Emergency Contact Pumper
EPA Lead Inspector Signature/Date
KERRI MCCABE
Kerri McCabe
Digitally signed by KERRI MCCABE Date: 2026.03.04 07:21:53 -06'00'
Date
Supervisor Signature/Date
JEANNE ECKHART Date: 2026.03.04 11:25:15 -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 #3 Tank Battery (ARU002303 / CWA) Inspection Date 01/14/2026
Section I - INTRODUCTION PURPOSE OF THE INSPECTION EPA Region 6 inspectors Kerri McCabe (lead), Uma Lad, Tom McKay (for Spill Prevention Control and Countermeasure (SPCC) inspection)) arrived at the C12: Arkansas Oil, LLC / Midway Smackover Unit Tract #3 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 33.443267, -93.533467 in Lewisville (Baker Community), Lafayette County, Arkansas; at 1400 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 #3 Tank Battery facility, which contains four (4) tank batteries for a total of ten (10) tanks that include storage, separation, and free water knock out (FWKO) for crude oil and saltwater processing and storage; and three (3) Class II saltwater disposal (SWD) injection wells. There are four (4) additional storage tanks for refined product.
Map 1. Aerial imagery (Google Earth dated 09/08/2023) of the C12: Arkansas Oil, LLC / Midway Smackover Unit Tract #3 Tank Battery facility.
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C12: Arkansas Oil, LLC / MSU Tract #3 Tank Battery (ARU002303 / 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 the SWD injection well tank battery (Area 2) and drainpipe, see Photos No. 3 and No. 4.
I observed the oil storage tank battery (Area 1) and drainpipe, see Photos No. 5 and No. 6.
I observed loose oil inside the oil storage tank battery, see Photo No. 7.
I observed the Free-water Knockout (FWKO) tank battery (Area 3) and a load line without secondary containment, see Photo No. 8.
I observed loose oil from a section of piping at the FWKO tank battery, see Photo No. 9.
I observed an additional oil storage tank battery with four (4) bolted tanks, see Photo No. 10.
I observed one (1) bolted tank undergoing permanent closure (i.e., cleaned, plated/manway removed, and tagged, etc.), see Photos No. 11 through No. 14.
I observed a tote with crude oil outside secondary containment near the FWKO tank battery, see Photos No. 8 and No. 15.
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:
Loose oil inside the oil storage tank battery (Area 1), 40 CFR 112.9(b)(1) (Photo No. 7), Load line for FWKO tank battery (Area 3) without secondary containment, 40 CFR 112.7(c) (Photo
No. 8), Loose oil from piping at the FWKO tank battery, 40 CFR 112.9(b)(1) (Photo No. 9), A tote (near the FWKO tank battery) used to store crude oil located outside secondary containment,
40 CFR 112.7(c) (Photos No. 8 and No. 15), and Loose oil inside oil storage tank battery (bolted tanks), 40 CFR 112.9(b)(1) (Photos No. 12 and No.
14)
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 - 15 photos taken on 01/14/2026.
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C12: Arkansas Oil, LLC / MSU Tract #3 Tank Battery (ARU002303 / CWA) Inspection Date 01/14/2026
Appendix 1 Photograph Log
15 Photos
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 1
Facility/Location:
C12: Arkansas Oil, LLC Midway Smackover Unit Tract 3 Tank Battery
City: Lewisville
County: Lafayette County
State: AR
Direction: SSW
Filename: R0011303.JPG
Photo Date: 01/14/2026
Time: 14:12:53
Photographer: Kerri McCabe
Witness Name: Tom McKay
Description: Latitude:
Looking SSW, this photo shows the signage for the Midway Smackover Unit Tract 3 Tank
Battery ("facility").
3326'35.766" N
Longitude: 9332'0.276" W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 2
Facility/Location:
C12: Arkansas Oil, LLC Midway Smackover Unit Tract 3 Tank Battery
City: Lewisville
County: Lafayette County
State: AR
Direction: SW
Filename: R0011304.JPG
Photo Date: 01/14/2026
Time: 14:13:27
Photographer: Kerri McCabe
Witness Name: Tom McKay
Description: Looking SW, this photo shows an overview of the facility.
Latitude: 3326'36.024" N
Longitude: 9332'1.146" W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 3
Facility/Location:
C12: Arkansas Oil, LLC Midway Smackover Unit Tract 3 Tank Battery
City: Lewisville
County: Lafayette County
State: AR
Direction: SW
Filename: R0011305.JPG
Photo Date: 01/14/2026
Time: 14:14:28
Photographer: Kerri McCabe
Witness Name: Tom McKay
Description: Latitude:
Looking SW, this photo shows an overview of the saltwater disposal (SWD) injection well
tank battery.
3326'36.432" N
Longitude: 9332'1.302" W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 4
Facility/Location:
C12: Arkansas Oil, LLC Midway Smackover Unit Tract 3 Tank Battery
City: Lewisville
County: Lafayette County
State: AR
Direction: S
Filename: R0011306.JPG
Photo Date: 01/14/2026
Time: 14:15:41
Photographer: Kerri McCabe
Witness Name: Tom McKay
Description: Looking S, this photo shows the drainpipe for the SWD injection well tank battery.
Latitude: 3326'37.385" N
Longitude: 9332'2.472" W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 5
Facility/Location:
C12: Arkansas Oil, LLC Midway Smackover Unit Tract 3 Tank Battery
City: Lewisville
County: Lafayette County
State: AR
Direction: SW
Filename: R0011307.JPG
Photo Date: 01/14/2026
Time: 14:18:03
Photographer: Kerri McCabe
Witness Name: Tom McKay
Description: Looking SW, this photo shows an overview of the oil storage tank battery (Area 1).
Latitude: 3326'37.134" N
Longitude: 9332'1.469" W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 6
Facility/Location:
C12: Arkansas Oil, LLC Midway Smackover Unit Tract 3 Tank Battery
City: Lewisville
County: Lafayette County
State: AR
Direction: SW
Filename: R0011308.JPG
Photo Date: 01/14/2026
Time: 14:18:44
Photographer: Kerri McCabe
Witness Name: Tom McKay
Description: Looking SW, this photo shows the drainpipes for the oil storage tank battery.
Latitude: 3326'37.164" N
Longitude: 9332'0.840" W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 7
Facility/Location:
C12: Arkansas Oil, LLC Midway Smackover Unit Tract 3 Tank Battery
City: Lewisville
County: Lafayette County
State: AR
Direction: SW
Filename: R0011309.JPG
Photo Date: 01/14/2026
Time: 14:20:14
Photographer: Kerri McCabe
Witness Name: Tom McKay
Description: Looking SW, this photo shows loose oil inside the oil storage tank battery.
Latitude: 3326'37.979" N
Longitude: 9332'1.530" W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 8
Facility/Location:
C12: Arkansas Oil, LLC Midway Smackover Unit Tract 3 Tank Battery
City: Lewisville
County: Lafayette County
State: AR
Direction: S
Filename: R0011311.JPG
Photo Date: 01/14/2026
Time: 14:24:41
Photographer: Kerri McCabe
Witness Name: Tom McKay
Description: Latitude:
Looking S, this photo shows the loading line for the FWKO tank battery without
secondary containment.
3326'37.999" N
Longitude: 9332'1.374" W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 9
Facility/Location:
C12: Arkansas Oil, LLC Midway Smackover Unit Tract 3 Tank Battery
City: Lewisville
County: Lafayette County
State: AR
Direction: WSW
Filename: R0011312.JPG
Photo Date: 01/14/2026
Time: 14:25:58
Photographer: Kerri McCabe
Witness Name: Tom McKay
Description: Looking WSW, this photo shows an active leak from a pipe inside the FWKO tank battery.
Latitude: 3326'39.191" N
Longitude: 9332'1.038" W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 10
Facility/Location:
C12: Arkansas Oil, LLC Midway Smackover Unit Tract 3 Tank Battery
City: Lewisville
County: Lafayette County
State: AR
Direction: S
Filename: R0011313.JPG
Photo Date: 01/14/2026
Time: 14:30:23
Photographer: Kerri McCabe
Witness Name: Tom McKay
Description: Looking S, this photo shows a tank battery with older, bolted tanks.
Latitude: 3326'39.797" N
Longitude: 9332'1.692" W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 11
Facility/Location:
C12: Arkansas Oil, LLC Midway Smackover Unit Tract 3 Tank Battery
City: Lewisville
County: Lafayette County
State: AR
Direction: S
Filename: R0011314.JPG
Photo Date: 01/14/2026
Time: 14:31:20
Photographer: Kerri McCabe
Witness Name: Tom McKay
Description: Latitude:
Looking S, this photo shows the interior of the bolted tank battery with a pipe partially
disconnected.
3326'40.157" N
Longitude: 9332'1.242" W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 12
Facility/Location:
C12: Arkansas Oil, LLC Midway Smackover Unit Tract 3 Tank Battery
City: Lewisville
County: Lafayette County
State: AR
Direction: S
Filename: R0011315.JPG
Photo Date: 01/14/2026
Time: 14:33:02
Photographer: Kerri McCabe
Witness Name: Tom McKay
Description: Latitude:
Looking S, this photo shows a tank that C12: Arkansas Oil, LLC plated (i.e., removed the
manway) in preparation for permanent closure.
3326'40.139" N
Longitude: 9332'1.134" W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 13
Facility/Location:
C12: Arkansas Oil, LLC Midway Smackover Unit Tract 3 Tank Battery
City: Lewisville
County: Lafayette County
State: AR
Direction: SSW
Filename: R0011316.JPG
Photo Date: 01/14/2026
Time: 14:33:10
Photographer: Kerri McCabe
Witness Name: Tom McKay
Description: Latitude:
Looking SSW, this photo shows sedimentation inside the plated tank that still needs to
be removed prior to permanent closure.
3326'40.110" N
Longitude: 9332'1.074" W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 14
Facility/Location:
C12: Arkansas Oil, LLC Midway Smackover Unit Tract 3 Tank Battery
City: Lewisville
County: Lafayette County
State: AR
Direction: S
Filename: R0011318.JPG
Photo Date: 01/14/2026
Time: 14:35:31
Photographer: Kerri McCabe
Witness Name: Tom McKay
Description: Latitude:
Looking S, this photo shows an additional view of the removed section of pipe from
Photo No. 11.
3326'40.043" N
Longitude: 9332'1.032" W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 15
Facility/Location:
C12: Arkansas Oil, LLC Midway Smackover Unit Tract 3 Tank Battery
City: Lewisville
County: Lafayette County
State: AR
Direction: SW
Filename: R0011319.JPG
Photo Date: 01/14/2026
Time: 14:41:47
Photographer: Kerri McCabe
Witness Name: Tom McKay
Description: Latitude:
Looking SW, this photo shows a closeup of the tote containing oil that was outside
secondary containment from Photo No. 8.
3326'38.585" N
Longitude: 9332'0.479" W