Document J3d1EmVgMm5p8qQ1MRyRELEm2

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 03/05/2025 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 Irma Nacatoch Unit SWD/EOR Tank Battery From Willisville, State Highway 371 North, right on Hwy 76, and then right onto an oilfield lease road at 33.545100, -93.218400. Willisville, AR 71730 451 North Washington El Dorado, AR 71864 Nevada County 870-862-9950 Michael L. Burns Person Responsible for Operation (870-310-1501) hrowan@ecgcpa.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: N/A ARU002290 N/A 211111 1311 Personnel participating in inspection: Kerri McCabe (lead) EPA / Region 6 ECDW Michael Blaha EPA / Region 6 ECDW Inspector / Enforcement Officer Inspector / Enforcement Officer EPA Lead Inspector Signature/Date Supervisor Signature/Date KERRI MCCABE Kerri McCabe Digitally signed by KERRI MCCABE Date: 2025.04.10 15:49:41 -05'00' Date JEANNE ECKHART Date: 2025.04.14 07:37:19 -05'00' Digitally signed by JEANNE ECKHART Jeanne Eckhart Date 6ENFORM-019-R8.2 (02/12/2020) 1 Nevada Oil, LLC / Irma Nacatoch Unit SWD/EOR Tank Battery (ARU002290 / CWA) Inspection Date 03/05/2025 Section I - INTRODUCTION PURPOSE OF THE INSPECTION EPA Region 6 inspectors Kerri McCabe (lead) and Michael Blaha arrived at the Nevada Oil, LLC / Irma Nacatoch Unit SWD/EOR Tank Battery ("facility") located from State Highway 371 North, right on Hwy 76, and then right onto an oilfield lease road at 33.545100, -93.218400 in Willisville, Nevada County, Arkansas; at 1320 on 03/05/2025 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 / Irma Nacatoch Unit SWD/EOR Tank Battery facility, which contains one (1) tank for saltwater storage and one (1) Class II saltwater disposal (SWD) well or Enhanced Oil Recovery (EOR) well. Map 1. Aerial imagery (Google Earth dated 08/03/2023) of the Nevada Oil, LLC / Irma Nacatoch Unit SWD/EOR Battery facility. 2 Nevada Oil, LLC / Irma Nacatoch Unit SWD/EOR Tank Battery (ARU002290 / CWA) Inspection Date 03/05/2025 Section II - OBSERVATIONS I observed the facility signage, secondary containment, pipes and valves, storage tank, and the SWD injection well or EOR well; see Appendix 1 (Photographs Log), Photos No. 1 through No. 3. For additional GPS location and photo metadata, see Appendix 1. I observed loose crude oil and saltwater inside secondary containment, see Photos No. 4 through No. 7. I observed the motor and pump for the SWD/EOR well outside secondary containment with loose and saltwater saturating the ground, see Photos No. 8 through No. 10. 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 following: Loose crude oil and saltwater inside secondary containment (Photos No. 4 through No. 7), and The motor and pump for the SWD/EOR well outside secondary containment with loose oil and saltwater saturating the ground (Photos No. 8 through No. 10). 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 - 10 photos taken 03/05/2025. 3 Nevada Oil, LLC / Irma Nacatoch Unit SWD-EOR Tank Battery (ARU002290 / CWA) Inspection Date 03/05/2025 Appendix 1 Photograph Log 10 Photos UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: From Willisville (Waterloo Community), State Hwy 371, right on Hwy 76, right onto an oilfield lease road at 33.545100, -93.218400. City: Willisville (Nevark) County/Parish: Nevada State: Arkansas Photo File Name: 100-0738 Orientation: 355 N Date of Photo: 03/05/2025 Time of Photo: 1322 Latitude: 33.544967 Longitude: -93.218317 Photographer: Kerri McCabe Description: Looking N, this photo shows the signage at the Irma Nacatoch (Sand) Unit SWD/EOR Tank Battery ("facility"). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: From Willisville (Waterloo Community), State Hwy 371, right on Hwy 76, right onto an oilfield lease road at 33.545100, -93.218400. City: Willisville (Nevark) County/Parish: Nevada State: Arkansas Photo File Name: 100-0739 Orientation: 267 W Date of Photo: 03/05/2025 Time of Photo: 1322 Latitude: 33.545000 Longitude: -93.218367 Photographer: Kerri McCabe Description: Looking W, this photo shows an overview of the facility with a saltwater disposal (SWD) injection well or an enhanced oil recovery (EOR) well. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: From Willisville (Waterloo Community), State Hwy 371, right on Hwy 76, right onto an oilfield lease road at 33.545100, -93.218400. City: Willisville (Nevark) County/Parish: Nevada State: Arkansas Photo File Name: 100-0740 Orientation: 210 SSW Date of Photo: 03/05/2025 Time of Photo: 1323 Latitude: 33.544983 Longitude: -93.218400 Photographer: Kerri McCabe Description: Looking SSW, this photo shows the front view of the inside of the secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: From Willisville (Waterloo Community), State Hwy 371, right on Hwy 76, right onto an oilfield lease road at 33.545100, -93.218400. City: Willisville (Nevark) County/Parish: Nevada State: Arkansas Photo File Name: 100-0741 Orientation: 102 ESE Date of Photo: 03/05/2025 Time of Photo: 1323 Latitude: 33.544967 Longitude: -93.218617 Photographer: Kerri McCabe Description: Looking ESE, this photo shows the back view of the inside of the secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: From Willisville (Waterloo Community), State Hwy 371, right on Hwy 76, right onto an oilfield lease road at 33.545100, -93.218400. City: Willisville (Nevark) County/Parish: Nevada State: Arkansas Photo File Name: 100-0742 Orientation: 77 ENE Date of Photo: 03/05/2025 Time of Photo: 1324 Latitude: 33.544917 Longitude: -93.218600 Photographer: Kerri McCabe Description: Looking ENE, this photo shows loose crude oil and saltwater inside the secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: From Willisville (Waterloo Community), State Hwy 371, right on Hwy 76, right onto an oilfield lease road at 33.545100, -93.218400. City: Willisville (Nevark) County/Parish: Nevada State: Arkansas Photo File Name: 100-0743 Orientation: 45 NE Date of Photo: 03/05/2025 Time of Photo: 1324 Latitude: 33.544883 Longitude: -93.218483 Photographer: Kerri McCabe Description: Looking NE, this photo shows the sump area and pump for the secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: From Willisville (Waterloo Community), State Hwy 371, right on Hwy 76, right onto an oilfield lease road at 33.545100, -93.218400. City: Willisville (Nevark) County/Parish: Nevada State: Arkansas Photo File Name: 100-0744 Orientation: 30 NNE Date of Photo: 03/05/2025 Time of Photo: 1324 Latitude: 33.544850 Longitude: -93.218433 Photographer: Kerri McCabe Description: Looking NNE, this photo shows a closeup of the sump and pump for secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: From Willisville (Waterloo Community), State Hwy 371, right on Hwy 76, right onto an oilfield lease road at 33.545100, -93.218400. City: Willisville (Nevark) County/Parish: Nevada State: Arkansas Photo File Name: 100-0745 Orientation: 74 ENE Date of Photo: 03/05/2025 Time of Photo: 1324 Latitude: 33.544867 Longitude: -93.218417 Photographer: Kerri McCabe Description: Looking ENE, this photo shows the SWD/EOR well motor and pump outside secondary containment with residual oil and saltwater staining. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 Location: From Willisville (Waterloo Community), State Hwy 371, right on Hwy 76, right onto an oilfield lease road at 33.545100, -93.218400. City: Willisville (Nevark) County/Parish: Nevada State: Arkansas Photo File Name: 100-0746 Orientation: 22 NNE Date of Photo: 03/05/2025 Time of Photo: 1325 Latitude: 33.544850 Longitude: -93.218283 Photographer: Kerri McCabe Description: Looking NNE, this photo shows an additional view of the SWD/EOR motor and pump and staining from Photo No. 8. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 10 Location: From Willisville (Waterloo Community), State Hwy 371, right on Hwy 76, right onto an oilfield lease road at 33.545100, -93.218400. City: Willisville (Nevark) County/Parish: Nevada State: Arkansas Photo File Name: 100-0747 Orientation: 224 SW Date of Photo: 03/05/2025 Time of Photo: 1325 Latitude: 33.544967 Longitude: -93.218300 Photographer: Kerri McCabe Description: Looking SW, this photo shows a closeup of the SWD/EOR motor and pump outside secondary containment and no guard over the motor belt.