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Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 4/3/24 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: Nevada Oil, LLC Sandy Bend Tank Battery From Highway 82 East, thence Sandy Bend Rd, off an oil field lease road at 33.157587, -92.396525. Urbana, AR 71730 451 North Washington El Dorado, AR 71730 Union County 870-862-9950 Michael L. Burns (870-310- Person Responsible for Operation 1501) hrowan@ecgcpa.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: N/A ARU002244 N/A 211111 1311 Personnel participating in inspection: Kerri McCabe (lead) EPA / Region 6 ECDW Inspector / Enforcement Officer EPA Lead Inspector Signature/Date Supervisor Signature/Date KERRI MCCABE Kerri McCabe Digitally signed by KERRI MCCABE Date: 2024.05.06 06:41:29 -05'00' Date JEANNE ECKHART Date: 2024.05.06 12:46:29 -05'00' Digitally signed by JEANNE ECKHART Jeanne Eckhart Date 6ENFORM-019-R8.2 (02/12/2020) 1 Section I - INTRODUCTION Nevada Oil, LLC / Sandy Bend Tank Battery (ARU002244 / CWA) Inspection Date 04/03/2024 PURPOSE OF THE INSPECTION EPA Region 6 Inspector Kerri McCabe (lead) arrived at the Nevada Oil, LLC / Sandy Bend Tank Battery, located from Highway 82 East, thence Sandy Bend Rd, off an oil field lease road at 33.157587, 92.396525; at 0958 on 4/3/24 for an unannounced inspection. No facility representatives were present 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 Nevada Oil, LLC / Sandy Bend Tank Battery, which contains one (1) oil-water separator, two (2) storage tanks, and one (1) oil-water separator and one (1) storage tank across from the tank battery that are out of service. Section II - OBSERVATIONS I observed the facility sign, secondary containment, oil-water separators, pipes and valves, and storage tanks located at the facility; see Appendix 1 (Photograph Log), Photo No. 1 and No. 2. For additional GPS location and photo metadata, see Appendix 1. I observed loose oil on the ground outside secondary containment; see Photo No. 3. I observed loose oil inside secondary containment, see Photo No. 4, No. 6 through No. 8. I observed a gap at the bottom on one of the storage tanks inside secondary containment, see Photo No. 5. I observed one of the storage tanks inside secondary containment with a hole in the sidewall, see Photo No. 9 and No. 10. I observed a storage tank and an oil-water separator outside secondary containment with loose oil around the equipment, see Photo No. 11 and No. 12. Section III - AREAS OF CONCERN No closing conference was held due to no personnel with Nevada Oil, LLC being present during the inspection. Areas of concern at the time of the inspection include the loose oil outside secondary containment, excessive loose oil inside secondary containment, eroded foundations, holes in storage tanks inside the tank battery, and inoperable equipment improperly stored outside secondary containment with loose oil on the ground. 2 Section IV - FOLLOW UP Nevada Oil, LLC / Sandy Bend Tank Battery (ARU002244 / CWA) Inspection Date 04/03/2024 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. Section V - LIST OF APPENDICES Appendix 1 - Photograph Log - 12 photos taken 4/3/24. 3 Nevada Oil, LLC / Sandy Bend Tank Battery (ARU002244 / CWA) Inspection Date 04/03/2024 Appendix 1 Photograph Log 12 Photos UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: Nevada Oil, LLC - Sandy Bend Tank Battery off Sandy Bend Rd at 33.157587, -92.396525. City: Urbana County/Parish: Union State: Arkansas Photo File Name: P4020063 Orientation: SE Date of Photo: 04/03/2024 Time of Photo: 1013 Latitude: 33.157649 Longitude: -92.396618 Photographer: Kerri McCabe Description: Looking SE, this photo showed the signage at the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: Nevada Oil, LLC - Sandy Bend Tank Battery off Sandy Bend Rd at 33.157587, -92.396525. City: Urbana County/Parish: Union State: Arkansas Photo File Name: P4020064 Orientation: NE Date of Photo: 04/03/2024 Time of Photo: 1013 Latitude: 33.157426 Longitude: -92.396589 Photographer: Kerri McCabe Description: Looking NE, this photo showed an overview of the facility with loose oil on the ground outside secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: Nevada Oil, LLC - Sandy Bend Tank Battery off Sandy Bend Rd at 33.157587, -92.396525. City: Urbana County/Parish: Union State: Arkansas Photo File Name: P4020065 Orientation: NE Date of Photo: 04/03/2024 Time of Photo: 1013 Latitude: 33.157426 Longitude: -92.396589 Photographer: Kerri McCabe Description: Looking NE, this photo showed a closeup of the loose oil observed in Photo No. 2. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: Nevada Oil, LLC - Sandy Bend Tank Battery off Sandy Bend Rd at 33.157587, -92.396525. City: Urbana County/Parish: Union State: Arkansas Photo File Name: P4020066 Orientation: E-SE Date of Photo: 04/03/2024 Time of Photo: 1014 Latitude: 33.157649 Longitude: -92.396618 Photographer: Kerri McCabe Description: Looking E-SE, this photo showed loose oil inside secondary containment at the front of the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: Nevada Oil, LLC - Sandy Bend Tank Battery off Sandy Bend Rd at 33.157587, -92.396525. City: Urbana County/Parish: Union State: Arkansas Photo File Name: P4020067 Orientation: S-SW Date of Photo: 04/03/2024 Time of Photo: 1014 Latitude: 33.157679 Longitude: -92.396694 Photographer: Kerri McCabe Description: Looking S-SW, this photo showed an eroded foundation around one of the tank bottoms and water stored inside secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: Nevada Oil, LLC - Sandy Bend Tank Battery off Sandy Bend Rd at 33.157587, -92.396525. City: Urbana County/Parish: Union State: Arkansas Photo File Name: P4020068 Orientation: S Date of Photo: 04/03/2024 Time of Photo: 1014 Latitude: 33.157626 Longitude: -92.396691 Photographer: Kerri McCabe Description: Looking S, this photo showed loose oil and oil-saturated leaf litter inside secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: Nevada Oil, LLC - Sandy Bend Tank Battery off Sandy Bend Rd at 33.157587, -92.396525. City: Urbana County/Parish: Union State: Arkansas Photo File Name: P4020069 Orientation: SW Date of Photo: 04/03/2024 Time of Photo: 1015 Latitude: 33.157626 Longitude: -92.396691 Photographer: Kerri McCabe Description: Looking SW, this photo showed an additional view of the loose oil and oil-saturated leaf litter inside secondary containment from Photo No. 6. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: Nevada Oil, LLC - Sandy Bend Tank Battery off Sandy Bend Rd at 33.157587, -92.396525. City: Urbana County/Parish: Union State: Arkansas Photo File Name: P4020070 Orientation: W-SW Date of Photo: 04/03/2024 Time of Photo: 1015 Latitude: 33.157571 Longitude: -92.396695 Photographer: Kerri McCabe Description: Looking W-SW, this photo showed loose oil inside secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 Location: Nevada Oil, LLC - Sandy Bend Tank Battery off Sandy Bend Rd at 33.157587, -92.396525. City: Urbana County/Parish: Union State: Arkansas Photo File Name: P4020071 Orientation: NW Date of Photo: 04/03/2024 Time of Photo: 1015 Latitude: 33.157571 Longitude: -92.396695 Photographer: Kerri McCabe Description: Looking NW, this photo showed a hole in one of the storage tanks and loose oil inside secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 10 Location: Nevada Oil, LLC - Sandy Bend Tank Battery off Sandy Bend Rd at 33.157587, -92.396525. City: Urbana County/Parish: Union State: Arkansas Photo File Name: P4020072 Orientation: E-NE Date of Photo: 04/03/2024 Time of Photo: 1015 Latitude: 33.157571 Longitude: -92.396695 Photographer: Kerri McCabe Description: Looking N-NE, this photo showed an additional view of the inside of secondary containment from Photo No. 9. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 11 Location: Nevada Oil, LLC - Sandy Bend Tank Battery off Sandy Bend Rd at 33.157587, -92.396525. City: Urbana County/Parish: Union State: Arkansas Photo File Name: P4020073 Orientation: W Date of Photo: 04/03/2024 Time of Photo: 1016 Latitude: 33.157585 Longitude: -92.396484 Photographer: Kerri McCabe Description: Looking W, this photo showed a storage tank outside secondary containment with loose oil on the ground. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 12 Location: Nevada Oil, LLC - Sandy Bend Tank Battery off Sandy Bend Rd at 33.157587, -92.396525. City: Urbana County/Parish: Union State: Arkansas Photo File Name: P4020074 Orientation: SE Date of Photo: 04/03/2024 Time of Photo: 1016 Latitude: 33.157585 Longitude: -92.396484 Photographer: Kerri McCabe Description: Looking SE, this photo showed an overview of the storage tank from Photo No. 11.