Document DvDKon57KL7nODYOEGaDO96vB

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 11/08/2024 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: SMI Operating Company, LLC E Gregory #5 Tank Battery In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.247317, -92.536617. El Dorado, AR, 71730 190 Vestal Loop Strong, AR 71765 Union County 870-951-0136 Jacob Agerton Owner / Operator agertonjay@icloud.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: N/A ARU002262 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: 2025.01.14 07:26:27 -06'00' Date JEANNE ECKHART Date: 2025.01.14 09:47:01 -06'00' Digitally signed by JEANNE ECKHART Jeanne Eckhart Date 6ENFORM-019-R8.2 (02/12/2020) 1 Section I - INTRODUCTION SMI Operating Company, LLC / E Gregory #5 Tank Battery (ARU002262 / CWA) Inspection Date 11/08/2024 PURPOSE OF THE INSPECTION EPA Region 6 inspector Kerri McCabe (lead) arrived at the SMI Operating Company, LLC / E Gregory #5 Tank Battery, located from Highway 63 E, then Armer Rd, left onto an oil lease road at 33.247317, 92.536617; at 1230 on 11/08/2024 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 SMI Operating Company, LLC / E Gregory #5 Tank Battery, which contained six (6) storage/separation tanks for crude oil and saltwater and one (1) oil production well (out of service). Signage on one of the tanks inside secondary containment was marked with "Pacific-Atlantic Oil Company." Communication with Mr. Glen Owen, Inspector Supervisor with AOGC, on 11/12/2024 confirmed that the facility had been sold to SMI Operating Company, LLC. Map 1. Aerial imagery (Google Earth dated 03/11/2024) of the SMI Operating Company, LLC / E Gregory #5 Tank Battery. 2 Section II - OBSERVATIONS SMI Operating Company, LLC / E Gregory #5 Tank Battery (ARU002262 / CWA) Inspection Date 11/08/2024 I observed the SMI Operating Company, LLC / E Gregory #5 Tank Battery facility and associated secondary containment, storage tanks, treaters/separators, and production well; see Appendix 1 (Photographs Log), see Photos No. 1 and No. 2. For additional GPS location and photo metadata, see Appendix 1. I observed loose oil and active leaks inside the secondary containment, see Photos No. 3 through No. 6. I observed an open hatch for one storage tank, see Photos No. 7 and No. 8. I observed active leaks and pools of saltwater inside the secondary containment with flow indicators directed towards the drainpipes, see Photos No. 9 through No. 12. I observed evidence of releases of crude oil and saltwater from two drainpipes for the secondary containment, see Photos No. 13 through No. 18. Both drainpipes were closed with either a shutoff valve or a cap during the inspection. I observed the loading lines and catchment buckets outside secondary containment, see Photos No. 19 and No. 20. Section III - AREAS OF CONCERN No closing conference was held due to no personnel with SMI Operating Company, LLC being present during the inspection. Mr. Jacob Agerton, contact on file with AOGC, was contacted via email on 11/12/2024 regarding the inspections of related facilities owned/operated by SMI Operating Company, LLC. Areas of concern at the time of the inspection include the following: No updated signage at the facility, Open hatch on one of the tanks, Active leaks of crude oil and loose oil inside secondary containment, Active leaks and pools of saltwater inside secondary containment, Releases of residual crude oil and saltwater from the drainpipes for secondary containment, and A missing cap for one of the drainpipes for secondary containment. Section IV - FOLLOW UP Inspector will conduct follow-up phone calls and emails 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 - 20 photos taken 11/08/2024. 3 SMI Operating Company, LLC / E Gregory #5 Tank Battery (ARU002262 / CWA) Inspection Date 11/08/2024 Appendix 1 Photograph Log 20 Photos UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.247317, 92.536617. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0326 Orientation: N Date of Photo: 11/08/2024 Time of Photo: 1255 Latitude: 33.247467 Longitude: -92.536950 Photographer: Kerri McCabe Description: Looking N, this photo shows a production well associated with the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.247317, 92.536617. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0327 Orientation: WSW Date of Photo: 11/08/2024 Time of Photo: 1256 Latitude: 33.247317 Longitude: -92.536617 Photographer: Kerri McCabe Description: Looking WSW, this photo shows an overview of the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.247317, 92.536617. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0328 Orientation: SSW Date of Photo: 11/08/2024 Time of Photo: 1256 Latitude: 33.247317 Longitude: -92.536633 Photographer: Kerri McCabe Description: Looking SSW, this photo shows the front of the tank battery at the loading lines. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.247317, 92.536617. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0329 Orientation: S Date of Photo: 11/08/2024 Time of Photo: 1257 Latitude: 33.247355 Longitude: -92.536679 Photographer: Kerri McCabe Description: Looking S, this photo shows loose oil inside secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.247317, 92.536617. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0330 Orientation: NE Date of Photo: 11/08/2024 Time of Photo: 1257 Latitude: 33.247333 Longitude: -92.536867 Photographer: Kerri McCabe Description: Looking NE, this photo shows loose oil inside secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.247317, 92.536617. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0331 Orientation: SE Date of Photo: 11/08/2024 Time of Photo: 1257 Latitude: 33.247300 Longitude: -92.536850 Photographer: Kerri McCabe Description: Looking SE, this photo shows loose oil and pooled saltwater inside the secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.247317, 92.536617. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0332 Orientation: ESE Date of Photo: 11/08/2024 Time of Photo: 1257 Latitude: 33.247309 Longitude: -92.536850 Photographer: Kerri McCabe Description: Looking ESE, this photo shows loose oil and pooled saltwater inside secondary containment and one (1) tank with an open hatch. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.247317, 92.536617. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0333 Orientation: ESE Date of Photo: 11/08/2024 Time of Photo: 1258 Latitude: 33.247306 Longitude: -92.536850 Photographer: Kerri McCabe Description: Looking ESE, this photo shows a closeup of the tank with an open hatch and pipe inside secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 Location: In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.247317, 92.536617. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0334 Orientation: E Date of Photo: 11/08/2024 Time of Photo: 1258 Latitude: 33.247267 Longitude: -92.536883 Photographer: Kerri McCabe Description: Looking E, this photo shows saltwater pooled below a tank inside secondary containment; there was a gap under the tank bottom. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 10 Location: In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.247317, 92.536617. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0335 Orientation: SE Date of Photo: 11/08/2024 Time of Photo: 1258 Latitude: 33.247267 Longitude: -92.536883 Photographer: Kerri McCabe Description: Looking SE, this photo shows high-level marks and flow indicators for crude oil and saltwater inside secondary containment that was directed toward the drainpipe. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 11 Location: In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.247317, 92.536617. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0336 Orientation: ESE Date of Photo: 11/08/2024 Time of Photo: 1258 Latitude: 33.247260 Longitude: -92.536883 Photographer: Kerri McCabe Description: Looking ESE, this photo shows a closeup of the drainpipe with loose oil and pooled saltwater noted in the area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 12 Location: In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.247317, 92.536617. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0337 Orientation: ESE Date of Photo: 11/08/2024 Time of Photo: 1258 Latitude: 33.247259 Longitude: -92.536874 Photographer: Kerri McCabe Description: Looking ESE, this photo shows an additional view of the drainpipe for secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 13 Location: In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.247317, 92.536617. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0338 Orientation: WSW Date of Photo: 11/08/2024 Time of Photo: 1258 Latitude: 33.247219 Longitude: -92.536930 Photographer: Kerri McCabe Description: Looking WSW, this photo shows residual loose oil and pooled saltwater with flow indicators downstream of the drainpipe for secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 14 Location: In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.247317, 92.536617. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0339 Orientation: E Date of Photo: 11/08/2024 Time of Photo: 1258 Latitude: 33.247198 Longitude: -92.536924 Photographer: Kerri McCabe Description: Looking E, this photo shows one of the drainpipes for secondary containment with a closed valve but no cap with residual loose oil and pooled saltwater downstream of the pipe. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 15 Location: In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.247317, 92.536617. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0340 Orientation: NE Date of Photo: 11/08/2024 Time of Photo: 1259 Latitude: 33.247150 Longitude: -92.537017 Photographer: Kerri McCabe Description: Looking NE, this photo shows one of the drainpipes for secondary containment with a closed valve but no cap (upstream view). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 16 Location: In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.247317, 92.536617. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0341 Orientation: WNW Date of Photo: 11/08/2024 Time of Photo: 1259 Latitude: 33.247167 Longitude: -92.537000 Photographer: Kerri McCabe Description: Looking WNW, this photo shows residual loose oil and flow indicators downstream of the drainpipe for secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 17 Location: In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.247317, 92.536617. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0342 Orientation: E Date of Photo: 11/08/2024 Time of Photo: 1259 Latitude: 33.247182 Longitude: -92.536938 Photographer: Kerri McCabe Description: Looking E, this photo shows another drainpipe with a cap for the secondary containment with residual loose oil and flow indicators downstream of the pipe. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 18 Location: In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.247317, 92.536617. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0343 Orientation: E Date of Photo: 11/08/2024 Time of Photo: 1259 Latitude: 33.247100 Longitude: -92.536800 Photographer: Kerri McCabe Description: Looking E, this photo shows a closeup of the drainpipe from Photo No. 17. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 19 Location: In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.247317, 92.536617. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0344 Orientation: NE Date of Photo: 11/08/2024 Time of Photo: 1259 Latitude: 33.247100 Longitude: -92.536814 Photographer: Kerri McCabe Description: Looking NE, this photo shows loose oil inside secondary containment (front view). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 20 Location: In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.247317, 92.536617. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0345 Orientation: NE Date of Photo: 11/08/2024 Time of Photo: 1300 Latitude: 33.247133 Longitude: -92.536783 Photographer: Kerri McCabe Description: Looking NE, this photo shows catchment buckets at the loading lines from crude oil storage.