Document G5kZ4nj2Lny2odvmRBemQ4MZ7

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 01/15/2025 Water (CWA) Water (CWA) NPDES Industrial Stormwater (MSGP) Program Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: Capstone Oilfield Disposal of Arkansas, LLC Flanagan, Tom 1 SWD Tank Battery In Cecil from Highway 96, then Highway 41, then right onto Highway 32 (Sandstone Ridge Road), then right onto a gas lease road at 35.388535, 93.965165. Ozark, AR, 72930 P.O. Box 698 Hennessey, OK 73742 Franklin County 405-853-7170 Chase Holder (405-853-1540) Person Responsible for Operation cholder4@icloud.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: N/A ADEQ AFIN 24-00109 for the facility; ARR001252 N/A 213112 1389 Personnel participating in inspection: Kerri McCabe (lead) EPA / Region 6 ECDW Amy Huneycutt ADEQ - Office of Water Quality Inspector / Enforcement Officer Inspector Supervisor EPA Lead Inspector Signature/Date Supervisor Signature/Date KERRI MCCABE Kerri McCabe Digitally signed by KERRI MCCABE Date: 2025.02.18 14:49:03 -06'00' Date JEANNE ECKHART Date: 2025.02.25 09:37:16 -06'00' Digitally signed by JEANNE ECKHART Jeanne Eckhart Date 6ENFORM-019-R8.2 (02/12/2020) 1 Capstone Oilfield Disposal of Arkansas, LLC / Flanagan, Tom 1 SWD Tank Battery (ARR001252 / CWA) Inspection Date 01/15/2025 Section I - INTRODUCTION PURPOSE OF THE INSPECTION EPA Region 6 Inspector Kerri McCabe (lead) arrived at the Capstone Oilfield Disposal of Arkansas, LLC / Flanagan, Tom 1 SWD Tank Battery ("facility") at 1315 on 01/15/2025 for an announced inspection. The facility is located outside Cecil, Franklin County, Arkansas from Highway 96, then Highway 41, then right onto Highway 32 (Sandstone Ridge Road), then right onto a gas lease road at 35.388535, -93.965165. No facility representatives were present at the time of the inspection. Ms. Amy Huneycutt, Inspector Supervisor with ADEQ - Office of Water Quality - Compliance Branch, was present at the time of the inspection. The inspection was conducted by the authority of the Clean Water Act (CWA) and the National Pollution Discharge Elimination System (NPDES) Industrial Stormwater General Permit (IGP; ARR001252) issued by the Arkansas Division of Environmental Quality (hereafter "ADEQ") to determine compliance with Environmental Protection Agency (EPA) regulations. Details of the latest IGP inspection conducted by ADEQ - Office of Water Quality on 02/22/2024 can be found at the following hyperlink: https://www.adeq.state.ar.us/downloads/WebDatabases/InspectionsOnline/129334-insp.pdf FACILITY DESCRIPTION EPA conducted an inspection on the Capstone Oilfield Disposal of Arkansas, LLC / Flanagan, Tom 1 SWD Tank Battery, which contained one (1) tank battery, eight (8) storage tanks for produced water, one (1) unloading containment area, and one (1) Class II saltwater disposal (SWD) injection well. Map 1. Aerial imagery (Google Earth dated 11/07/2023) of the Capstone Oilfield Disposal of Arkansas, LLC / Flanagan, Tom 1 SWD Tank Battery. 2 Capstone Oilfield Disposal of Arkansas, LLC / Flanagan, Tom 1 SWD Tank Battery (ARR001252 / CWA) Inspection Date 01/15/2025 Section II - OBSERVATIONS I observed two (2) tanks outside secondary containment, and one (1) tank is missing a lid; see Appendix 1 (Photograph Log), Photos No. 1 and No. 2. For additional GPS location and photo metadata, see Appendix 1. Section III - AREAS OF CONCERN No closing conference was held due to no personnel with Capstone Oilfield Disposal of Arkansas, LLC being present during the inspection. Areas of concern at the time of the inspection include the following: One (1) tank outside secondary containment with a missing lid, see Part 1, 1.7 of the general permit. 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. Section V - LIST OF APPENDICES Appendix 1 - Photograph Log - 2 photos taken 01/15/2025. Appendix 2 - ADEQ IGP No-Exposure Check Sheet 3 Capstone Oilfield Disposal of Arkansas, LLC / Flanagan, Tom 1 SWD Tank Battery (ARR001252 / CWA) Inspection Date 01/15/2025 Appendix 1 Photograph Log 2 Photos UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: From Highway 96, then Highway 41, then right onto Highway 32 (Sandstone Ridge Road), then right onto a gas lease road at 35.388535, -93.965165. City: Cecil (Ozark) County/Parish: Franklin State: Arkansas Photo File Name: 100-0445 Orientation: 16 NNE Date of Photo: 01/15/2025 Time of Photo: 1336 Latitude: 35.388784 Longitude: -93.964902 Photographer: Kerri McCabe Description: Looking NNE, this photo shows two storage tanks outside containment; one tank is open. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: From Highway 96, then Highway 41, then right onto Highway 32 (Sandstone Ridge Road), then right onto a gas lease road at 35.388535, -93.965165. City: Cecil (Ozark) County/Parish: Franklin State: Arkansas Photo File Name: 100-0447 Orientation: 85 E Date of Photo: 01/15/2025 Time of Photo: 1337 Latitude: 35.388817 Longitude: -93.964933 Photographer: Kerri McCabe Description: Looking E, this photo shows one tank from Photo No. 1 with an open top. Appendix 2 No-Exposure Check Sheet No-Exposure Exclusion Verification Are any of the following materials or activities exposed to precipitation now or in the foreseeable future? Answering "Yes" to any of these questions indicates the facility is not eligible for the No-Exposure Exclusion. a. Using, storing, or cleaning industrial machinery or equipment and areas where residuals from using, storing, or cleaning industrial machinery or equipment remain and are exposed to stormwater? Comments: Y N b. Are materials or residuals on the ground or in stormwater inlets from spills/leaks? Comments: Y N c. Are materials or products from past industrial activity exposed? Comments: Y N d. Is material handling equipment exposed except adequately maintained vehicles? Comments: Y N e. Are materials or products during loading/unloading or transporting activities exposed? Comments: Y N f. Materials or products stored outdoors except final products intended for outside use (e.g., new cars) where exposure to stormwater does not result in the discharge of pollutants? Y N Comments: g. Materials contained in open, deteriorated, or leaking storage drums, barrels, tanks, and similar containers? Y N Comments: h. Materials or products handled/stored on roads or railways owned or maintained by the discharger? Comments: Y N i. Waste materials exposed except waste in covered, non-leaking containers (e.g., dumpsters)? Comments: Y N j. Application or disposal of process wastewater unless otherwise permitted? Comments: Permitted for saltwater and other oilfield liquid wastes Y N k. Particulate matter or visible deposits of residuals from roof stacks and/or vents not otherwise regulated (i.e., under an air quality control permit) and evident in the stormwater outflow? Y N Comments: SWD is temporarily shut down.