Document MJ3D0E6OgVO6Xnw2mnLdqV00a

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date: Media Program: Regulatory Program: 01/13/2026 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: Drake Operating, LLC Charivari Creek Nacatoch Sand Unit Off Pereogeethe Road at 33.249630, -92.188985 Hermitage, AR 71647 P.O. Box 11137 El Dorado, AR 71730 Bradley County 870-315-4365 Mike Tribble mike.tribble@yahoo.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: N/A ARU002349 N/A 211111 1311 Personnel participating in inspection: Uma Lad (Lead) EPA / Region 6 ECDW Kerri McCabe EPA / Region 6 ECDW Inspector / Enforcement Officer Inspector / Enforcement Officer EPA Lead Inspector Signature/Date UMA LAD Uma Lad Digitally signed by UMA LAD Date: 2026.02.20 08:22:38 -06'00' Date Supervisor Signature/Date JEANNE ECKHART Date: 2026.02.20 11:59:08 -06'00' Digitally signed by JEANNE ECKHART Jeanne Eckhart Date 6ENFORM-019-R9 (02/27/2025) 1 Drake Operating, LLC / Charivari Creek Nacatoch Sand Unit (ARU002349 / CWA) Inspection Date 01/13/2026 Section I - INTRODUCTION PURPOSE OF THE INSPECTION EPA Region 6 inspectors Uma Lad and Kerri McCabe arrived at the Drake Operating, LLC / Charivari Creek Nacatoch Sand Unit, located off Pereogeethe Road 415 at 33.249630, -92.188985, at 2:25 PM on 01/13/2026 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 at Drake Operating, LLC / Charivari Creek Nacatoch Sand Unit, which consists of six (6) storage tanks, two (2) separators, one (1) gun barrel tank, one (1) production well, and one (1) saltwater disposal (SWD) injection well. Section II - OBSERVATIONS I observed the facility, associated signage, production well, SWD injection well, separators, gun barrel separator, storage tanks and secondary containment, and a catchment basin outside secondary containment; see Appendix 1 (Photograph Log), Photo No. 1 through No. 3 and Photo No. 7 and No. 9. For additional GPS location and photo metadata, see Appendix 1. I observed a concrete secondary containment wall with cracks, see Photo No. 5. I observed loose oil inside secondary containment, see Photo No. 6. I observed loose oil at the production well, see Photo No. 10. I observed dead vegetation or lack of vegetation outside of secondary containment, which can be an indicator of a past saltwater discharge, see Photo No. 11. Section III - AREAS OF CONCERN No closing conference was held due to no Drake Operating, LLC staff present during the inspection. Areas of concern at the time of the inspection are: A concrete secondary containment wall with cracks, which can impact the wall's ability to contain oil in the event of a discharge; Loose oil around inside secondary containment; Loose oil at the production well; Potential indicators of past saltwater discharge based on lack of or dead vegetation outside secondary containment at the facility. 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. 2 Drake Operating, LLC / Charivari Creek Nacatoch Sand Unit (ARU002349 / CWA) Inspection Date 01/13/2026 Section V - LIST OF APPENDICES Appendix 1 - Photograph Log - 11 photos taken 01/13/2026. 3 Drake Operating, LLC / Charivari Creek Nacatoch Sand Unit (ARU002349 / CWA) Inspection Date 01/13/2026 Appendix 1 Photograph Log 11 Photos UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Appendix 1 Photo No. 1 Facility/Location: Drake Operating, LLC / Charivari Creek Nacatoch Sand Unit off Pereogeethe Road 415 at 33.249630, -92.188985 City: Hermitage County: Bradley County State: AR Direction: SW Filename: R0011251.JPG Photo Date: 01/13/2026 Time: 14:27:26 Photographer: Uma Lad Witness Name: Kerri McCabe Description: This photo was taken facing southwest and shows the facility sign. Latitude: 3314'58.668" N Longitude: 9211'20.346" W UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Appendix 1 Photo No. 2 Facility/Location: Drake Operating, LLC / Charivari Creek Nacatoch Sand Unit off Pereogeethe Road 415 at 33.249630, -92.188985 City: Hermitage County: Bradley County State: AR Direction: SW Filename: R0011252.JPG Photo Date: 01/13/2026 Time: 14:27:52 Photographer: Uma Lad Witness Name: Kerri McCabe Description: This photo was taken facing southwest and shows a facility overview. Latitude: 3314'58.314" N Longitude: 9211'20.406" W UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Appendix 1 Photo No. 3 Facility/Location: Drake Operating, LLC / Charivari Creek Nacatoch Sand Unit off Pereogeethe Road 415 at 33.249630, -92.188985 City: Hermitage County: Bradley County State: AR Direction: SW Filename: R0011253.JPG Photo Date: 01/13/2026 Time: 14:28:02 Photographer: Uma Lad Witness Name: Kerri McCabe Description: This photo was taken facing southwest and shows another facility overview. Latitude: 3314'58.404" N Longitude: 9211'20.49" W UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Appendix 1 Photo No. 4 Facility/Location: Drake Operating, LLC / Charivari Creek Nacatoch Sand Unit off Pereogeethe Road 415 at 33.249630, -92.188985 City: Hermitage County: Bradley County State: AR Direction: SSW Filename: R0011255.JPG Photo Date: 01/13/2026 Time: 14:30:20 Photographer: Uma Lad Witness Name: Kerri McCabe Description: This photo was taken facing south-southwest and shows the pump to the SWD well. Latitude: 3314'59.286" N Longitude: 9211'20.922" W UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Appendix 1 Photo No. 5 Facility/Location: Drake Operating, LLC / Charivari Creek Nacatoch Sand Unit off Pereogeethe Road 415 at 33.249630, -92.188985 City: Hermitage County: Bradley County State: AR Direction: SW Filename: R0011270.JPG Photo Date: 01/13/2026 Time: 14:29:49 Photographer: Uma Lad Witness Name: Kerri McCabe Description: Latitude: This photo was taken facing southwest and shows cracks in the concrete secondary containment. 3314'58.95" N Longitude: 9211'20.886" W UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Appendix 1 Photo No. 6 Facility/Location: Drake Operating, LLC / Charivari Creek Nacatoch Sand Unit off Pereogeethe Road 415 at 33.249630, -92.188985 City: Hermitage County: Bradley County State: AR Direction: S Filename: R0011261.JPG Photo Date: 01/13/2026 Time: 14:30:57 Photographer: Uma Lad Witness Name: Kerri McCabe Description: This photo was taken facing south and shows loose oil inside secondary containment. Latitude: 3314'59.052" N Longitude: 9211'20.94" W UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Appendix 1 Photo No. 7 Facility/Location: Drake Operating, LLC / Charivari Creek Nacatoch Sand Unit off Pereogeethe Road 415 at 33.249630, -92.188985 City: Hermitage County: Bradley County State: AR Direction: WSW Filename: R0011262.JPG Photo Date: 01/13/2026 Time: 14:31:19 Photographer: Uma Lad Witness Name: Kerri McCabe Description: Latitude: This photo was taken facing west-southwest and shows a catchment basin behind the tank battery. 3314'59.376" N Longitude: 9211'21.222" W UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Appendix 1 Photo No. 8 Facility/Location: Drake Operating, LLC / Charivari Creek Nacatoch Sand Unit off Pereogeethe Road 415 at 33.249630, -92.188985 City: Hermitage County: Bradley County State: AR Direction: SSW Filename: R0011269.JPG Photo Date: 01/13/2026 Time: 14:29:33 Photographer: Uma Lad Witness Name: Kerri McCabe Description: This photo was taken facing south-southwest and shows the sign on the production well. Latitude: 3314'58.938" N Longitude: 9211'20.238" W UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Appendix 1 Photo No. 9 Facility/Location: Drake Operating, LLC / Charivari Creek Nacatoch Sand Unit off Pereogeethe Road 415 at 33.249630, -92.188985 City: Hermitage County: Bradley County State: AR Direction: SSW Filename: R0011267.JPG Photo Date: 01/13/2026 Time: 14:28:22 Photographer: Uma Lad Witness Name: Kerri McCabe Description: Latitude: This photo was taken facing south-southwest and shows the production well at the facility. 3314'58.8" N Longitude: 9211'20.334" W UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Appendix 1 Photo No. 10 Facility/Location: Drake Operating, LLC / Charivari Creek Nacatoch Sand Unit off Pereogeethe Road 415 at 33.249630, -92.188985 City: Hermitage County: Bradley County State: AR Direction: SSW Filename: R0011268.JPG Photo Date: 01/13/2026 Time: 14:28:47 Photographer: Uma Lad Witness Name: Kerri McCabe Description: This photo was taken facing south-southwest and shows loose oil at the pumpjack. Latitude: 3314'58.854" N Longitude: 9211'19.716" W UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Appendix 1 Photo No. 11 Facility/Location: Drake Operating, LLC / Charivari Creek Nacatoch Sand Unit off Pereogeethe Road 415 at 33.249630, -92.188985 City: Hermitage County: Bradley County State: AR Direction: SSW Filename: R0011265.JPG Photo Date: 01/13/2026 Time: 14:29:56 Photographer: Uma Lad Witness Name: Kerri McCabe Description: Latitude: This photo was taken facing south-southwest and shows an area on the side of the facility, outside of secondary containment, with a lack of vegetation or dead vegetation, which is one indicator of past saltwater discharge. 3314'59.1" N Longitude: 9211'21.024" W