Document K6gavqxaawdb53DbOVYYmJ1oX

EPA Inspection Report - Page 1 of 16 Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 03/11/2024 Water Clean Water Act Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: LaRay Oil, LLC Morgan #1 Latitude: 33.33494, Longitude: -92.50977 Calion, AR, 71724 5028 Highway 7 South Louann, Arkansas, 71751 Calhoun County 870-918-9859 Jimmy R. Newton larayoilco@sat-co.net FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: NA ARU002233 NA 211111 1311 Personnel participating in inspection: Uma Lad EPA/Region 6 ECDW Kerri McCabe EPA/Region 6 ECDW Michael Blaha EPA/Region 6 ECDW Enforcement Officer/Inspector Enforcement Officer/Inspector Enforcement Officer/Inspector EPA Lead Inspector Signature/Date Supervisor Signature/Date UMA LAD Uma Lad Digitally signed by UMA LAD Date: 2024.04.11 09:35:02 -05'00' Date JEANNE ECKHART Date: 2024.04.12 17:16:31 -05'00' Digitally signed by JEANNE ECKHART Jeanne Eckhart Date 6ENFORM-019-R8.2 (02/12/2020) 1 EPA Inspection Report - Page 2 of 16 Section I - INTRODUCTION LaRay Oil, LLC - Morgan #1 / ARU002233 (CWA) Inspection Date 03/11/2024 PURPOSE OF THE INSPECTION EPA Region 6 inspector Michael Blaha, Kerri McCabe, and I, Uma Lad arrived at the LaRay Oil, LLC, Morgan #1, located at the intersection of East Calhoun County Road 244 and Oil Field Road 10 (33.33494, -92.50977) at 4:00 PM on March 11, 2024, for an unannounced inspection. No facility representatives were present at the time of the inspection. The inspection was conducted under 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 LaRay Oil Company, Morgan #1, which consisted of 14 storage tanks. Section II - OBSERVATIONS I observed the facility sign, secondary containment, pipes, valves, and tanks located at the facility; see Appendix 1 (photo log), photo No. 1 and No. 2. For additional GPS location and photo metadata, see Appendix 1. I observed a gap at the base of one (1) crude oil storage tank and corrosion at the base of one (1) saltwater and crude oil storage tank, see photo No. 3 and No. 4. Outside of secondary containment, I observed standing water that leached through secondary containment with a total dissolved solids (TDS) reading of 1,427 mg/L, see photo No. 5 through No. 7. I observed a capped secondary containment discharge pipe that was leaking, see photo No. 8 through No. 10. In a pond at the southeast corner of the facility, I observed a TDS reading of 177.4 mg/L, see photo No. 11. In a water body north of the facility and across East Calhoun County Road 244, I observed a background TDS reading of 55.9 mg/L, see photo No. 12. All TDS field readings observed throughout the inspection were taken with a properly calibrated, EPAissued, YSI Pro 30 conductivity meter. 2 EPA Inspection Report - Page 3 of 16 Section III - AREAS OF CONCERN LaRay Oil, LLC - Morgan #1 / ARU002233 (CWA) Inspection Date 03/11/2024 No closing conference was held due to no LaRay Oil, LLC staff being present during the inspection. Areas of concern at the time of the inspection include the gap at the base of the crude oil storage tank, corrosion at the base of the saltwater and crude oil storage tank, the leaking secondary containment discharge valve, and the elevated TDS reading outside of secondary containment in the leached water from the secondary containment berm. Section IV - FOLLOW UP Inspector will conduct follow-up phone calls with the company representatives over the coming weeks and months to ensure areas of concern are properly addressed. Section V - LIST OF APPENDICES Appendix 1 - Photo Log - 12 photos taken on 03/11/2024 3 EPA Inspection Report - Page 4 of 16 LaRay Oil, LLC - Morgan #1 / ARU002233 (CWA) Inspection Date 03/11/2024 Appendix 1 Photograph Log 12 Photos EPA Inspection Report - Page 5 of 16 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.33494, -92.50977 City: Calion Photo No. 1 County/Parish: Calhoun State: Arkansas Photo File Name: R0010151 Orientation: E Date of Photo: 03/11/2024 Time of Photo: 4:51 PM Latitude: 33.33494 Longitude: -92.50951 Photographer: Kerri McCabe Description: This photo was taken looking east and shows the facility sign. EPA Inspection Report - Page 6 of 16 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.33494, -92.50977 City: Calion Photo No. 2 County/Parish: Calhoun State: Arkansas Photo File Name: R0010145 Orientation: E Date of Photo: 03/11/2024 Time of Photo: 4:38 PM Latitude: 33.33494 Longitude: -92.50976 Photographer: Kerri McCabe Description: This photo was taken looking east and shows an overview of the facility. EPA Inspection Report - Page 7 of 16 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.33494, -92.50977 City: Calion Photo No. 3 County/Parish: Calhoun State: Arkansas Photo File Name: R0010147 Orientation: N Date of Photo: 03/11/2024 Time of Photo: 4:49 PM Latitude: 33.33491 Longitude: -92.50951 Photographer: Kerri McCabe Description: This photo was taken looking north and shows a gap at the base of a crude oil tank. EPA Inspection Report - Page 8 of 16 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.33494, -92.50977 City: Calion Photo No. 4 County/Parish: Calhoun State: Arkansas Photo File Name: R0010149 Orientation: NW Date of Photo: 03/11/2024 Time of Photo: 4:51 PM Latitude: 33.33492 Longitude: -92.50945 Photographer: Kerri McCabe Description: This photo was taken looking northwest and shows corrosion at the base of a tank storing saltwater and crude oil. EPA Inspection Report - Page 9 of 16 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.33494, -92.50977 City: Calion Photo No. 5 County/Parish: Calhoun State: Arkansas Photo File Name: R0010152 Orientation: N/A Date of Photo: 03/11/2024 Time of Photo: 4:53 PM Latitude: 33.33487 Longitude: -92.50946 Photographer: Kerri McCabe Description: This photo shows a TDS reading of 1,427 mg/L in standing water that leached through secondary containment. EPA Inspection Report - Page 10 of 16 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.33494, -92.50977 City: Calion Photo No. 6 County/Parish: Calhoun State: Arkansas Photo File Name: R0010153 Orientation: NW Date of Photo: 03/11/2024 Time of Photo: 4:53 PM Latitude: 33.33483 Longitude: -92.50942 Photographer: Kerri McCabe Description: This photo was taken looking northwest and shows standing water that leached through secondary containment with the TDS reading of 1,427 mg/L. EPA Inspection Report - Page 11 of 16 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.33494, -92.50977 City: Calion Photo No. 7 County/Parish: Calhoun State: Arkansas Photo File Name: R0010155 Orientation: E Date of Photo: 03/11/2024 Time of Photo: 4:54 PM Latitude: 33.33482 Longitude: -92.50944 Photographer: Kerri McCabe Description: This photo was taken looking west and shows the standing water that leached through secondary containment and vegetation in the area. EPA Inspection Report - Page 12 of 16 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.33494, -92.50977 City: Calion Photo No. 8 County/Parish: Calhoun State: Arkansas Photo File Name: R0010156 Orientation: NW Date of Photo: 03/11/2024 Time of Photo: 4:57 PM Latitude: 33.33493 Longitude: -92.50902 Photographer: Kerri McCabe Description: This photo was taken looking northwest and shows a capped secondary containment discharge pipe that is leaking. EPA Inspection Report - Page 13 of 16 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.33494, -92.50977 City: Calion Photo No. 9 County/Parish: Calhoun State: Arkansas Photo File Name: R0010158 Orientation: N Date of Photo: 03/11/2024 Time of Photo: 4:57 PM Latitude: 33.33493 Longitude: -92.50905 Photographer: Kerri McCabe Description: This photo was taken looking north and shows a capped secondary containment discharge pipe that is leaking. EPA Inspection Report - Page 14 of 16 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.33494, -92.50977 City: Calion Photo No. 10 County/Parish: Calhoun State: Arkansas Photo File Name: R0010159 Orientation: N Date of Photo: 03/11/2024 Time of Photo: 4:57 PM Latitude: 33.33494 Longitude: -92.50905 Photographer: Kerri McCabe Description: This photo was taken looking north and shows erosion from the leaking secondary containment discharge valve. EPA Inspection Report - Page 15 of 16 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.33494, -92.50977 City: Calion Photo No. 11 County/Parish: Calhoun State: Arkansas Photo File Name: R0010160 Orientation: N/A Date of Photo: 03/11/2024 Time of Photo: 4:58 PM Latitude: 3 33.33491 Longitude: -92.50896 Photographer: Kerri McCabe Description: This photo shows a TDS reading of 177.4 mg/L from a pond at the southeast corner of the facility. EPA Inspection Report - Page 16 of 16 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.33494, -92.50977 City: Calion Photo No. 12 County/Parish: Calhoun State: Arkansas Photo File Name: R0010161 Orientation: N/A Date of Photo: 03/11/2024 Time of Photo: 5:03 PM Latitude: 33.33558 Longitude: -92.50889 Photographer: Kerri McCabe Description: This photo shows a background TDS reading of 55.9 mg/L from a pond north of the facility, across from East Calhoun County Road 244.