Document KyNkXE9MxXRXVoVnVoza2V6r

Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date(s): Media: Regulatory Program(s) Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: 02/12/2015 CWA (Water) NPDES - BRINE Lutex Oil, Ltd Lutex Oil, Ltd Highway 183 (29.687336N, -97.643366W) Luling, TX 78648 P.O. Box 549 Luling, TX 78648 Caldwell Mr. Lloyd L. Tiller FRS Number: Identification/Permit Number: Media Number: NAICS: SIC: Facility Representatives: N/A TXU011033 N/A Mr. Lloyd L. Tiller 512-738-1427 Metadata EPA Inspectors: State Inspector(s): Other Inspector(s): Title: Author: Subject: Keywords: EPA Lead Inspector Signature/Date Supervisor Signature/Date Jack Arias Matthew Rudolph 6EN-WR 6EN-WR 214-665-8164 214-665-6434 Lutex Oil Ltd. Luling Caldwell Texas US EPA Region 6 Compliance Assurance and Enforcement Division Dallas TX Inspection Report Clean Water Act (CWA) Brine Discharge Brine Produced Water Oil and Gas CWA Jack A. Arias WILLIE LANE Willie Lane, Jr. Digitally signed by WILLIE LANE DN: c=US, o=U.S. Government, ou=USEPA, ou=Staff, cn=WILLIE LANE, dnQualifier=0000007235 Date: 2015.05.13 14:23:55 -05'00' 5/5/15 Date Date Lutex Oil Ltd. Inspection Dates: 02/12/2015 Section I - INTRODUCTION PURPOSE OF THE INSPECTION The purpose of the inspection was to determine if the facility complied with Section 301 of the Clean Water Act (CWA), and to identify and document discharges to waters of the United States. The Inspection was conducted under the authority of Section 308 of the CWA. FACILITY DESCRIPTION The facility is known as the Lutex Oil Ltd. and is located north of Luling in Caldwell County, Texas (Photo 1). The facility is located on an oil and gas lease at Latitude 29.687336N and Longitude -97.643366W (photo 1). The lease consists of production wells, injection wells, vessels, flow lines, collection points, and other equipment used for the production of crude oil and natural gas. Production wells produce a mixture of produced water and crude oil (well fluids). Flow lines are used to transport well fluids to various locations on the lease. Collection points known as tank batteries consist of various tanks, vessels, and equipment used to separated and store the produced water and crude oil. At the facility there are 400barrel tanks surrounded by soil containment walls. Produced water is typically high in salts, commonly known as oil field brine. The crude oil is sold for profit and the produced water and/or brine is transported to and disposed of in various injection wells. Section II - OBSERVATIONS When we arrived at this facility on February 12, 2015, I noticed that some battery tanks were surrounded with vegetation and the containing walls around the tanks were small and improperly constructed. We drove around the facility area and observed flow paths of fluids, flow lines on the ground, PVC and polypipe lines going into the pond and creek (photos 2, 6, 9, 11, 13, 17). We found that the Salt Branch creek flows through the facility (Photo 1 and 2). At Latitude: 29.687265N and Longitude: -97.639825W, we observed a rusted flow line going into Salt Branch Creek (photo 2). We measured the Total Dissolve Salt (TSS) and obtained a reading of 3,500 ppm TSS (photo 2). We did not observed aquatic life, and found dead vegetation and foam formations. Next to the road, there was an illegal dumping notice located 5 feet from Salt Branch Creek (photo 4 ). At Latitude: 29.687572N and Longitude: -97.641376W in Salt Branch Creek, we found a polypipe line going into the creek and observed foam formations floating on the water (photos 5 and 6). The Total Dissolve Salt (TSS) was 4,100 ppm. We did not observed aquatic life (photo 6). The polypipe is located approximately 70 feet from Cora Malone Lease, Well#12 RRC#02936 (photo 8). At Latitude: 29.687460N and Longitude:-97.642541W, we found a PVC pipe going into Salt Branch Creek (photos 11 and 13). We measured the Total Soluble Salts (TSS) and obtained a lecture of 9,000 ppm TSS (photo 12). This PVC Pipe is located approximately 114 feet south from the Lutex Oil Ltd. Cora Malone Lease, Well#3 RRC#02936 (photo 10). At Latitude: 29.687296N and Longitude: -97.643079W, we found foam formations and oil residues floating on Salt Branch Creek (photo 14). We measured the Total Soluble Salts and obtained a lecture of 10,500 ppm TSS (photo 15). This point is approximately 150 feet south of the Lutex Oil Ltd. Cora Malone Lease, Well#3 RRC#02936. At Latitude: 29.687336N and Longitude: -97.643366W, there was an indication of a pipeline placed in Salt Branch creek (photos 17 and 19). The pipe showed alternated holes that may allow discharge of produced water into the creek (photo 19). We measured the Total Soluble Salts and obtained a lecture of 11,200 ppm TSS (photo 18). This point is approximately 221 feet southeast of the Lutex Oil Ltd. M. Merriwether Lease, Well#4 RRC#01504 (photo 2 Lutex Oil Ltd. Inspection Dates: 02/12/2015 16). We collected background data. We went upstream 1,900 feet of Salt Branch Creek and measured Total Soluble Salts and obtained a lecture of 300 ppm TSS (photo 21). It was an indication of fresh water. We chose another point 547 feet north from salt branch creek and measured the Total Soluble Salts and obtained a lecture of 200 ppm TSS (photo 20). Section III - AREAS OF CONCERN Rusted pipes, PVC pipes, Poly pipes, perforated pipes, and high concentrations of fluids in Salt Branch creek are a concern at this facility. The containing wall and placing of flow lines are not being properly managed. Section IV - FOLLOW UP Discuss inspection report with management to determine follow up. Section V - LIST OF APPENDICES Appendix 1 - Photo Log - 16 photos taken 2/12/15 Appendix 2 - USGS topographical map 3 Lutex Oil Ltd. Inspection Date 2/12/2015 Appendix 1 Photograph Log UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Lutex Oil Ltd. City: Luling, TX Photo No. 1 County/Parish: Caldwell State: Texas Photo File Name: Facility Map Date of Photo: NA Latitude: N 29.687336 (Red Point) Longitude: W -97.643366 (Red point) Time of Photo: NA Author: Jack Arias Description: Layout of Lutex Oil Ltd. Orange point indicates the highest salinity concentration of 11,200 parts-per-million (ppm) Total Soluble Salts (TSS) that was observed in Salt Creek. Blue points indicates back ground salinity for Salt Branch Creek in relation to the facility data (200 and 300 ppm TSS). Yellow indicates the TSS concentrations observed along Salt Branch Creek (between 3,500 to 10,500 ppm TSS). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Lutex Oil Ltd. City: Luling, TX Photo No. 2 County/Parish: Caldwell State: Texas Photo File Name: DSCF2544.JPG Date of Photos: 2/12/2015 Time of Photos: 10:21 am Latitude: N 29.687265 Longitude: W -97.639825 Orientation: Facing west Map Datum: WGS-84 Photographer: Jack Arias Description: We are standing on CR 128 and looking to the west at Salt Branch Creek. Overview of the Salt Branch Creek showing a rusted flow line in the creek. At this location we determined the Total Soluble Salt (TSS) of Salt Branch Creek to be 3,500 parts-per-million (ppm) TSS. I did not observe aquatic life and found dead vegetation. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Lutex Oil Ltd. City: Luling, TX Photo No. 3 County/Parish: Caldwell State: Texas Photo File Name: DSCF2543.JPG Date of Photos: 2/12/2015 Time of Photos: 10:21 am Latitude: N 29.687265 Longitude: W -97.639825 Orientation: Facing west Map Datum: WGS-84 Photographer: Jack Arias Description: We are standing on CR 128 and looking to the west at Salt Branch Creek. At this location we determined the Total Soluble Salt (TSS) of Salt Branch Creek to be 3,500 parts-per-million (ppm) TSS. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Lutex Oil Ltd. City: Luling, TX Photo No. 4 County/Parish: Caldwell State: Texas Photo File Name: DSCF2545.JPG Date of Photo: 2/12/2015 Time of Photo: 10:23 am Latitude: N 29.687246 Longitude: W -97.639762 Orientation: Facing Northeast Map Datum: WGS-84 Photographer: Jack Arias Description: Enlarged view of an illegal dumping notice located 5 feet from Salt Branch Creek. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Lutex Oil Ltd. City: Luling, TX Photo No. 5 County/Parish: Caldwell State: Texas Photo File Name: DSCF2546.JPG Date of Photos: 2/12/2015 Time of Photos: 10:28 am Latitude: N 29.687345 Longitude: W -97.639970 Orientation: Facing east Map Datum: WGS-84 Photographer: Jack Arias Description: North side of the creek. Looking showing dead vegetation and foam formations. did not observe aquatic life. east with CR 128. An The Total Soluble Salts overview of Salt Branch Creek (TSS) reading was 3,500 ppm. I UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Lutex Oil Ltd. City: Luling, TX Photo No. 6 County/Parish: Caldwell State: Texas Photo File Name: DSCF2548.JPG Date of Photo: 2/12/2015 Time of Photos: 10:34 am Latitude: N 29.687572 Longitude: W -97.641376 Orientation: Facing east Map Datum: WGS-84 Photographer: Jack Arias Description: Overview of Salt Branch Creek showing a polypipe line going into the creek and foam and algae formations. The Total Soluble Salt (TSS) reading was 4,100 ppm. I did not observe aquatic life. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Lutex Oil Ltd. City: Luling, TX Photo No. 7 County/Parish: Caldwell State: Texas Photo File Name: DSCF2547.JPG Date of Photo: 2/12/2015 Time of Photos: 10:34 am Latitude: N 29.687572 Longitude: W -97.641376 Orientation: Facing east Map Datum: WGS-84 Photographer: Jack Arias Description: The Total Dissolve Salt (TSS) reading was 4,100 ppm. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Lutex Oil Ltd. City: Luling, TX Photo No. 8 County/Parish: Caldwell State: Texas Photo File Name: DSCF2549.JPG Date of Photo: 2/12/2015 Time of Photos: 10:36 am Latitude: N 29.687757 Longitude: W -97.641292 Orientation: Facing east Map Datum: WGS-84 Photographer: Jack Arias Description: Overview of the Lutex Oil Ltd. Cora Malone Lease, Well#12 RRC#02936. This well is approximately 70 feet north from Salt Branch Creek. It was operating at time of inspection. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Lutex Oil Ltd. City: Luling, TX Photo No. 9 County/Parish: Caldwell State: Texas Photo File Name: DSCF2550.JPG Date of Photo: 2/12/2015 Time of Photos: 10:38 am Latitude: N 29.687572 Longitude: W -97.641376 Orientation: Facing south Map Datum: WGS-84 Photographer: Jack Arias Description: Overview of Salt branch creek showing a polypipe going into the creek (see photo 6). It is located approximately 70 feet south from Cora Malone Lease, Well#12 RRC#02936. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Lutex Oil Ltd. City: Luling, TX Photo No. 10 County/Parish: Caldwell State: Texas Photo File Name: DSCF2551.JPG Date of Photo: 2/12/2015 Time of Photos: 10:38 am Latitude: N 29.687772 Longitude: W -97.642623 Orientation: Facing North Map Datum: WGS-84 Photographer: Jack Arias Description: Overview of the Lutex Oil Ltd. Cora Malone Lease, Well#3 RRC#02936. This well is approximately 120 feet north from Salt Branch Creek. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Lutex Oil Ltd. City: Luling, TX Photo No. 11 County/Parish: Caldwell State: Texas Photo File Names: DSCF2552 Date of Photos: 2/12/2015 Time of Photos: 10:42 am; 10:44 am Latitude: N 29.687460 Longitude: W -97.642541 Orientation: Facing east Map Datum: WGS-84 Photographer: Jack Arias Description: Part 1, overview of a PVC pipe going into the Salt branch Creek. I measured the Total Soluble Salts (TSS) and obtained a measurement of 9,000 ppm TSS. This PVC Pipe is going into corroded pipe and is located approximately 114 feet south from the Lutex Oil Ltd. Cora Malone Lease, Well#3 RRC#02936. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Lutex Oil Ltd. City: Luling, TX Photo No. 12 County/Parish: Caldwell State: Texas Photo File Names: DSCF2554.JPG Date of Photos: 2/12/2015 Time of Photos: 10:44 am Latitude: N 29.687460 Longitude: W -97.642541 Orientation: Facing east Map Datum: WGS-84 Photographer: Jack Arias Description: Part 2, Total Soluble Salts (TSS) measurement was 9,000 ppm TSS. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Lutex Oil Ltd. City: Luling, TX Photo No. 13 County/Parish: Caldwell State: Texas Photo File Name: DSCF2553.JPG Date of Photos: 2/12/2015 Time of Photos: 10:42 am Latitude: N 29.687460 Longitude: W -97.642541 Orientation: Facing east Map Datum: WGS-84 Photographer: Jack Arias Description: Part 3, overview of a PVC pipe going into the Salt branch Creek (see photo 11). I measured the Total Soluble Salts (TSS) and obtained a reading of 9,000 ppm TSS. This PVC Pipe is located approximately 114 feet south from the Lutex Oil Ltd. Cora Malone Lease, Well#3 RRC#02936. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Lutex Oil Ltd. City: Luling, TX Photo No. 14 County/Parish: Caldwell State: Texas Photo File Name: DSCF2557.JPG Date of Photo: 2/12/2015 Time of Photos: 10:52 am Latitude: N 29.687296 Longitude: W -97.643079 Orientation: Facing south Map Datum: WGS-84 Photographer: Jack Arias Description: North side of banck looking south. Overview of foam formations and oil residues floating on Salt Branch Creek. I measured the Total Soluble Salts and obtained a reading of 10,500 ppm TSS. This point is approximately 150 feet south of the Lutex Oil Ltd. Cora Malone Lease, Well#3 RRC#02936. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Lutex Oil Ltd. City: Luling, TX Photo No. 15 County/Parish: Caldwell State: Texas Photo File Name: DSCF2556.JPG Date of Photo: 2/12/2015 Time of Photos: 10:52 am Latitude: N 29.687296 Longitude: W -97.643079 Orientation: Facing south Map Datum: WGS-84 Photographer: Jack Arias Description: Total Soluble Salts obtained a reading of 10,500 ppm TSS. This point is approximately 150 feet south of the Lutex Oil Ltd. Cora Malone Lease, Well#3 RRC#02936 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Lutex Oil Ltd. City: Luling, TX Photo No. 16 County/Parish: Caldwell State: Texas Photo File Name: DSCF2567.JPG Date of Photo: Date of Photo: 2/12/2015 Time of Photos: 11:54 am Latitude: N 29.687429 Longitude: W -97.644061 Orientation: Facing North Map Datum: WGS-84 Photographer: Jack Arias Description: Overview of the Lutex Oil Ltd. M. Merriwether Lease, Well#4 RRC#01504. This well is approximately 108 feet North from Salt Branch Creek. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Lutex Oil Ltd. City: Luling, TX Photo No. 17 County/Parish: Caldwell State: Texas Photo File Name: DSCF2566.JPG Date of Photos: 2/12/2015 Time of Photos: 11:51 am Latitude: N 29.687336 Longitude: W -97.643366 Orientation: Facing south Map Datum: WGS-84 Photographer: Jack Arias Description: I observed a perforated pipe line placed under water in Salt Branch creek. (See photo 19) Pipe showed alternated holes that may allow discharge of produced water into the creek. We were unable to determine what the pipe was connected to. We determined and measured the Total Soluble Salts of 11,200 ppm TSS at this location. This location is approximately 221 feet southeast of the Lutex Oil Ltd. M. Merriwether Lease, Well#4 RRC#01504. This location is also where we observed the highest TSS reading in Salt Branch Creek. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Lutex Oil Ltd. City: Luling, TX Photo No. 18 County/Parish: Caldwell State: Texas Photo File Name: DSCF2563.JPG Date of Photos: 2/12/2015 Time of Photos: 11:46 am Latitude: N 29.687336 Longitude: W -97.643366 Orientation: Facing south Map Datum: WGS-84 Photographer: Jack Arias Description: Total Soluble Salts was 11,200 ppm TSS. This location is approximately 221 feet southeast of the Lutex Oil Ltd. M. Merriwether Lease, Well#4 RRC#01504. This location is also where we observed the highest TSS reading in Salt Branch Creek. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Lutex Oil Ltd. City: Luling, TX Photo No. 19 County/Parish: Caldwell State: Texas Photo File Name: DSCF2564.JPG Date of Photo: Date of Photo: 2/12/2015 Time of Photo: 11:46 am Latitude: N 29.687336 Longitude: W -97.643366 Orientation: Facing south Map Datum: WGS-84 Photographer: Jack Arias Description: Closeup of the perforated pipe from Photo 17. water. Most of the pipe was submerged under UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Lutex Oil Ltd. City: Luling, TX Photo No. 20 County/Parish: Caldwell State: Texas Photo File Name: DSCF2560.JPG; DSCF2559.JPG Date of Photos: 2/12/2015 Time of photos: 11:13 am Latitude: N 29.688856 Longitude: W -97.642918 Orientation: Facing west Map Datum: WGS-84 Photographer: Jack Arias Description: Background information. Indication of fresh water near Salt Branch creek. This is a pond located approximately 550 feet north and up-gradient of Salt Branch Creek. We determined the salinity in this pond to be 200 ppm TSS. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Lutex Oil Ltd. City: Luling, TX Photo No. 21 County/Parish: Caldwell State: Texas Photo File Names: DSCF2562.JPG; DSCF2561.JPG Date of Photos: 2/12/2015 Time of Photos: 11:32 am Latitude: N 29.687075 Longitude: W -97.648460 Orientation: Facing east Map Datum: WGS-84 Photographer: Jack Arias Description: This photo is of Salt Branch Creek approximately 1,645 feet (a third of a mile) upstream of where we observed the highest salinity concentration of 11,200 ppm TSS. At this location we determined the salinity (Total Soluble Salts) of Salt Branch to be 300 ppm TSS. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Lutex Oil Ltd. City: Luling, TX Photo No. 22 County/Parish: Caldwell State: Texas Lutex Oil Ltd. Inspection Date 2/12/2015 Appendix 2 Photograph Log UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Lutex Oil Ltd. City: Luling, TX Photo No. 1 County/Parish: Caldwell State: Texas USGS Aerial map showing tributary of Salt branch. Blue line is an indication of relative permanence. Point Source elevation 358 ft. Elevation is between 350 and 370 ft. Background is between 200 and 300 ppm. Elevations demonstrated downstream flow of produced water (brine fluids) towards Salt Branch. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Lutex Oil Ltd. City: Luling, TX Photo No. 2 County/Parish: Caldwell State: Texas USGS Topo Map showing tributary of Salt branch. Blue line is an indication of relative permanence. Point Source elevation 358 ft. Elevation is between 350 and 370 ft. Background is between 200 and 300 ppm. Elevations demonstrated downstream flow of produced water (brine fluids) towards Salt Branch. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Lutex Oil Ltd. City: Luling, TX Photo No. 3 County/Parish: Caldwell State: Texas USGS Hydro-NHD Map showing hydrologic connection of tributary of Salt Branch to Salt Branch and Plum Creek. Blue line is an indication of relative permanence. Point Source of contamination is 11,200 ppm with an elevation of 364 ft. Background is between 200 and 300 ppm. Elevations demonstrated downstream flow of produced water (brine fluids) towards Salt Branch and Plum Creek.