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Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 07/16/2024 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: MidAmerica Environmental Holdings, LLC USA Disposal - El Dorado 101 Warehouse Drive El Dorado, AR 71730 4101 Old Oak Drive Little Rock, AR 72212 Union County 850-525-8830 William L. White (850-525- Principal / CEO 8830) bwhite@apollowater.tech ; bwhite@midamerica.holdings FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: N/A ARU002251; ADEQ permit 5077-WR-7 (administratively extended) for AFIN 70-01210 N/A 213112 1389 Personnel participating in inspection: Kerri McCabe (lead) EPA / Region 6 ECDW Michael Blaha EPA / Region 6 ECDW Michael Young ADEQ / Office of Water Quality Kirk Brown Trekker Energy Services Inspector / Enforcement Officer Inspector / Enforcement Officer Inspector Supervisor Director of Operations EPA Lead Inspector Signature/Date Supervisor Signature/Date KERRI MCCABE Kerri McCabe Digitally signed by KERRI MCCABE Date: 2024.08.06 13:33:36 -05'00' Date JEANNE ECKHART Date: 2024.08.15 08:45:29 -05'00' Digitally signed by JEANNE ECKHART Jeanne Eckhart Date 6ENFORM-019-R8.2 (02/12/2020) 1 MidAmerica Environmental Holdings, LLC / USA Disposal (El Dorado) (CWA / ARU002251) Inspection Date 07/16/2024 Section I - INTRODUCTION PURPOSE OF THE INSPECTION EPA Region 6 inspectors Kerri McCabe (lead) and Michael Blaha arrived at MidAmerica Environmental Holdings, LLC / USA Disposal (El Dorado) facility, located at 101 Warehouse Drive, El Dorado, Arkansas, 71730 at 33.204359, -92.613940; at 0845 on 07/16/2024 for an announced inspection. Mr. Kirk Brown, Trekker Energy Services, was 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. Mr. Michael Young with Arkansas Department of Energy and Environment - Division of Environmental Quality - Office of Water Quality - Compliance Branch (hereafter "ADEQ"), was present at the time of the inspection. The facility was last inspected on 05/22/2024 by Inspector Kerri McCabe. FACILITY DESCRIPTION EPA conducted an inspection on the MidAmerica Environmental Holdings, LLC / USA Disposal (El Dorado) facility, which is a drilling mud bulking facility for oil-based and water-based drilling fluids, Exploration and Production (E&P) wastes, and additional liquid wastes listed in the State No-Discharge (SND) permit issued by the State of Arkansas. There are five (5) concrete holding pits, 23 frac tanks, one (1) storage building for bulking material (sawdust), one (1) concrete slab for stockpiling bulked material (sawdust blended with liquid wastes), one (1) stormwater pond, and several outbuildings used as storage and office space. Approximately 6.5 acres of the active property have been used for land filling and land application of bulked material. The facility was formally a mining site and borrow pit for clay soil. Map 1. Aerial imagery (Google Earth dated 05/14/2023) of the MidAmerica Environmental Holdings, LLC - USA Disposal (El Dorado) facility. 2 MidAmerica Environmental Holdings, LLC / USA Disposal (El Dorado) (CWA / ARU002251) Inspection Date 07/16/2024 Section II - OBSERVATIONS I observed the signage and overviews of areas from the four main directions of the facility, see Appendix 1 (Photograph Log), Photo No. 1 through No. 5. For additional GPS location and photo metadata, see Appendix 1. I observed the concrete pits used for mixing liquid wastes with sawdust, see Photo No. 6 and No. 7. I observed frac tanks with liquid wastes, the bulked material staging area (partially covered), and the concrete pits used for collecting and storing leachate from the bulked material, see Photo No. 8 through No. 11. I observed areas on the property, which contained jurisdictional wetlands, with soil disturbing activities, scattered or stacked bulked material, bulked material leachate and staining, and dead vegetation; see Photo No. 12 through No. 19. I observed the stormwater pond and associated drainpipes (permitted by the state under an Industrial Stormwater General Permit, IGP), an additional pipe from an unknown source, and the receiving stream; see Photo No. 20 through No. 26. I observed the former wastewater treatment area and associated drainage path to the stormwater pond, a concrete pit for liquid waste storage, and areas used for equipment/outbuilding storage; see Photo No. 27 through No. 29. Section III - AREAS OF CONCERN A closing conference was held with Mr. Kirk Brown of Trekker Energy Services during the inspection. The closing conference focused on the current conditions of the areas of concern previously identified in the 05/22/2024 inspection, the placement of fill in/near wetlands, and the actively leaking pipe (source unknown) at the stormwater pond and receiving stream. Areas of concern at the time of the inspection include the following: Uncovered bulked material at the storage area, Loose sawdust throughout the facility production area, Numerous frac tanks with contents not identified, Concrete mixing pits without adequate freeboard and damaged concrete berms, Soil disturbing activities, scattered/stacked bulked material, bulked material leachate and staining, and dead vegetation within or near wetlands, Lower drainpipe for the stormwater pond cannot be inspected, and An actively dripping pipe, of an unknown source, crossing the receiving stream at the stormwater pond. 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. 3 MidAmerica Environmental Holdings, LLC / USA Disposal (El Dorado) (CWA / ARU002251) Inspection Date 07/16/2024 Section V - LIST OF APPENDICES Appendix 1 - Photograph Log - 29 photos taken 07/16/2024. 4 MidAmerica Environmental Holdings, LLC / USA Disposal (El Dorado) (CWA / ARU002251) Inspection Date 07/16/2024 Appendix 1 Photograph Log 29 Photos UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: MidAmerica Environmental Holdings, LLC / USA Disposal (El Dorado) facility, located at 101 Warehouse Drive at 33.204359, -92.613940 City: El Dorado County/Parish: Union County State: Arkansas Photo File Name: 100-0223 Orientation: SSW Date of Photo: 07/16/2024 Time of Photo: 0912 Latitude: 33.204250 Longitude: -92.614150 Photographer: Kerri McCabe Description: Looking SSW, signage at the USA Disposal facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: MidAmerica Environmental Holdings, LLC / USA Disposal (El Dorado) facility, located at 101 Warehouse Drive at 33.204359, -92.613940 City: El Dorado County/Parish: Union County State: Arkansas Photo File Name: 100-0224 Orientation: NE Date of Photo: 07/16/2024 Time of Photo: 0914 Latitude: 33.204283 Longitude: -92.614433 Photographer: Kerri McCabe Description: Looking NE, frac tanks and portable totes stored at the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: MidAmerica Environmental Holdings, LLC / USA Disposal (El Dorado) facility, located at 101 Warehouse Drive at 33.204359, -92.613940 City: El Dorado County/Parish: Union County State: Arkansas Photo File Name: 100-0225 Orientation: WNW Date of Photo: 07/16/2024 Time of Photo: 0914 Latitude: 33.204283 Longitude: -92.614433 Photographer: Kerri McCabe Description: Looking WNW, additional frac tanks and staged bulked material (liquid wastes mixed with sawdust) at the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: MidAmerica Environmental Holdings, LLC / USA Disposal (El Dorado) facility, located at 101 Warehouse Drive at 33.204359, -92.613940 City: El Dorado County/Parish: Union County State: Arkansas Photo File Name: 100-0226 Orientation: S Date of Photo: 07/16/2024 Time of Photo: 0914 Latitude: 33.204283 Longitude: -92.614433 Photographer: Kerri McCabe Description: Looking S, building used for sawdust storage. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: MidAmerica Environmental Holdings, LLC / USA Disposal (El Dorado) facility, located at 101 Warehouse Drive at 33.204359, -92.613940 City: El Dorado County/Parish: Union County State: Arkansas Photo File Name: 100-0227 Orientation: SW Date of Photo: 07/16/2024 Time of Photo: 0915 Latitude: 33.204267 Longitude: -92.614550 Photographer: Kerri McCabe Description: Looking SW, frac tanks and former wastewater treatment area located at the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: MidAmerica Environmental Holdings, LLC / USA Disposal (El Dorado) facility, located at 101 Warehouse Drive at 33.204359, -92.613940 City: El Dorado County/Parish: Union County State: Arkansas Photo File Name: 100-0228 Orientation: SSW Date of Photo: 07/16/2024 Time of Photo: 0915 Latitude: 33.204267 Longitude: -92.615117 Photographer: Kerri McCabe Description: Looking SSW, one of two concrete pits (South Pit) used to mix liquid wastes and sawdust. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: MidAmerica Environmental Holdings, LLC / USA Disposal (El Dorado) facility, located at 101 Warehouse Drive at 33.204359, -92.613940 City: El Dorado County/Parish: Union County State: Arkansas Photo File Name: 100-0229 Orientation: SE Date of Photo: 07/16/2024 Time of Photo: 0916 Latitude: 33.204217 Longitude: -92.615200 Photographer: Kerri McCabe Description: Looking SE, two of two concrete pits (North Pit) used to mix liquid wastes and sawdust. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: MidAmerica Environmental Holdings, LLC / USA Disposal (El Dorado) facility, located at 101 Warehouse Drive at 33.204359, -92.613940 City: El Dorado County/Parish: Union County State: Arkansas Photo File Name: 100-0230 Orientation: N Date of Photo: 07/16/2024 Time of Photo: 0916 Latitude: 33.204350 Longitude: -92.615300 Photographer: Kerri McCabe Description: Looking N, bulked material stored under a covering in front of a concrete pit used to catch any leachate running off the material. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 Location: MidAmerica Environmental Holdings, LLC / USA Disposal (El Dorado) facility, located at 101 Warehouse Drive at 33.204359, -92.613940 City: El Dorado County/Parish: Union County State: Arkansas Photo File Name: 100-0231 Orientation: NNE Date of Photo: 07/16/2024 Time of Photo: 0916 Latitude: 33.204367 Longitude: -92.615217 Photographer: Kerri McCabe Description: Looking NNE, berm built up around frac tanks holding unknown liquid wastes. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 10 Location: MidAmerica Environmental Holdings, LLC / USA Disposal (El Dorado) facility, located at 101 Warehouse Drive at 33.204359, -92.613940 City: El Dorado County/Parish: Union County State: Arkansas Photo File Name: 100-0232 Orientation: NW Date of Photo: 07/16/2024 Time of Photo: 0917 Latitude: 33.204467 Longitude: -92.615233 Photographer: Kerri McCabe Description: Looking NW, bulked material under cover in front of the concrete pit used for collecting leachate from the bulked material. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 11 Location: MidAmerica Environmental Holdings, LLC / USA Disposal (El Dorado) facility, located at 101 Warehouse Drive at 33.204359, -92.613940 City: El Dorado County/Parish: Union County State: Arkansas Photo File Name: 100-0233 Orientation: WSW Date of Photo: 07/16/2024 Time of Photo: 0917 Latitude: 33.204483 Longitude: -92.615367 Photographer: Kerri McCabe Description: Looking WSW, the concrete pit below the leachate collection pit. This pit was below the required freeboard level listed in the state-issued permit (5077-WR-7). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 12 Location: MidAmerica Environmental Holdings, LLC / USA Disposal (El Dorado) facility, located at 101 Warehouse Drive at 33.204359, -92.613940 City: El Dorado County/Parish: Union County State: Arkansas Photo File Name: 100-0234 Orientation: WSW Date of Photo: 07/16/2024 Time of Photo: 0919 Latitude: 33.205200 Longitude: -92.616050 Photographer: Kerri McCabe Description: Looking WSW, bulked material scattered around the facility property and dead trees noted at the property edge. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 13 Location: MidAmerica Environmental Holdings, LLC / USA Disposal (El Dorado) facility, located at 101 Warehouse Drive at 33.204359, -92.613940 City: El Dorado County/Parish: Union County State: Arkansas Photo File Name: 100-0235 Orientation: W Date of Photo: 07/16/2024 Time of Photo: 0920 Latitude: 33.205317 Longitude: -92.616883 Photographer: Kerri McCabe Description: Looking W, erodible soils from land disturbance activities, leachate staining from bulked material, and dead vegetation all observed within a wetland at the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 14 Location: MidAmerica Environmental Holdings, LLC / USA Disposal (El Dorado) facility, located at 101 Warehouse Drive at 33.204359, -92.613940 City: El Dorado County/Parish: Union County State: Arkansas Photo File Name: 100-0236 Orientation: SSW Date of Photo: 07/16/2024 Time of Photo: 0920 Latitude: 33.205317 Longitude: -92.616883 Photographer: Kerri McCabe Description: Looking SSW, bulked material, with leachate staining, stacked adjacent to and placed into the wetland in Photo No. 13. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 15 Location: MidAmerica Environmental Holdings, LLC / USA Disposal (El Dorado) facility, located at 101 Warehouse Drive at 33.204359, -92.613940 City: El Dorado County/Parish: Union County State: Arkansas Photo File Name: 100-0237 Orientation: NW Date of Photo: 07/16/2024 Time of Photo: 0920 Latitude: 33.205307 Longitude: -92.616883 Photographer: Kerri McCabe Description: Looking NW, an additional view of the bulked material stacked adjacent to and placed into the wetland in Photo No. 13. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 16 Location: MidAmerica Environmental Holdings, LLC / USA Disposal (El Dorado) facility, located at 101 Warehouse Drive at 33.204359, -92.613940 City: El Dorado County/Parish: Union County State: Arkansas Photo File Name: 100-0238 Orientation: W Date of Photo: 07/16/2024 Time of Photo: 0923 Latitude: 33.204667 Longitude: -92.615783 Photographer: Kerri McCabe Description: Looking W, soil disturbance activities and dead vegetation at the perimeter of the property and within an additional wetland onsite. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 17 Location: MidAmerica Environmental Holdings, LLC / USA Disposal (El Dorado) facility, located at 101 Warehouse Drive at 33.204359, -92.613940 City: El Dorado County/Parish: Union County State: Arkansas Photo File Name: 100-0239 Orientation: W Date of Photo: 07/16/2024 Time of Photo: 0924 Latitude: 33.204367 Longitude: -92.616117 Photographer: Kerri McCabe Description: Looking W, a closer view of the dead vegetation and erodible soils from Photo No. 16. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 18 Location: MidAmerica Environmental Holdings, LLC / USA Disposal (El Dorado) facility, located at 101 Warehouse Drive at 33.204359, -92.613940 City: El Dorado County/Parish: Union County State: Arkansas Photo File Name: 100-0240 Orientation: NW Date of Photo: 07/16/2024 Time of Photo: 0924 Latitude: 33.204350 Longitude: -92.616133 Photographer: Kerri McCabe Description: Looking NW, an additional view of the dead vegetation and disturbed soil near the wetland in Photo No. 16 and No. 17. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 19 Location: MidAmerica Environmental Holdings, LLC / USA Disposal (El Dorado) facility, located at 101 Warehouse Drive at 33.204359, -92.613940 City: El Dorado County/Parish: Union County State: Arkansas Photo File Name: 100-0241 Orientation: SSW Date of Photo: 07/16/2024 Time of Photo: 0924 Latitude: 33.204350 Longitude: -92.616133 Photographer: Kerri McCabe Description: Looking SSW, an additional view of the erodible soils adjacent to the wetland in Photo No. 16 through No. 18. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 20 Location: MidAmerica Environmental Holdings, LLC / USA Disposal (El Dorado) facility, located at 101 Warehouse Drive at 33.204359, -92.613940 City: El Dorado County/Parish: Union County State: Arkansas Photo File Name: 100-0242 Orientation: SSE Date of Photo: 07/16/2024 Time of Photo: 0924 Latitude: 33.204267 Longitude: -92.616050 Photographer: Kerri McCabe Description: Looking SSE, the stormwater pond, permitted by the state under an IGP (ARR001445), with a fluid level that was lower than the fluid level noted during the 05/22/2024 inspection. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 21 Location: MidAmerica Environmental Holdings, LLC / USA Disposal (El Dorado) facility, located at 101 Warehouse Drive at 33.204359, -92.613940 City: El Dorado County/Parish: Union County State: Arkansas Photo File Name: 100-0243 Orientation: SSE Date of Photo: 07/16/2024 Time of Photo: 0925 Latitude: 33.204167 Longitude: -92.616033 Photographer: Kerri McCabe Description: Looking SSE, the upper drainpipe for the stormwater pond has been capped on the inside of the pond. The lower drainpipe was not observed. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 22 Location: MidAmerica Environmental Holdings, LLC / USA Disposal (El Dorado) facility, located at 101 Warehouse Drive at 33.204359, -92.613940 City: El Dorado County/Parish: Union County State: Arkansas Photo File Name: 100-0244 Orientation: SSE Date of Photo: 07/16/2024 Time of Photo: 0925 Latitude: 33.204167 Longitude: -92.616033 Photographer: Kerri McCabe Description: Looking SSE, a closeup of the cap on the upper drainpipe in Photo No. 21. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 23 Location: MidAmerica Environmental Holdings, LLC / USA Disposal (El Dorado) facility, located at 101 Warehouse Drive at 33.204359, -92.613940 City: El Dorado County/Parish: Union County State: Arkansas Photo File Name: 100-0245 Orientation: SSW Date of Photo: 07/16/2024 Time of Photo: 0925 Latitude: 33.204117 Longitude: -92.616017 Photographer: Kerri McCabe Description: Looking SSW, an exterior view of the upper drainpipe for the stormwater pond. The cap was off, but the valve was closed. The lower drainpipe was not observed. The thinner, white pipe in the photo was actively dripping into the receiving stream; source of pipe was unknown. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 24 Location: MidAmerica Environmental Holdings, LLC / USA Disposal (El Dorado) facility, located at 101 Warehouse Drive at 33.204359, -92.613940 City: El Dorado County/Parish: Union County State: Arkansas Photo File Name: 100-0246 Orientation: SSW Date of Photo: 07/16/2024 Time of Photo: 0925 Latitude: 33.204117 Longitude: -92.616031 Photographer: Kerri McCabe Description: Looking SSW, a closeup view of the thinner, white pipe (unknown source) actively dripping into the receiving stream from Photo No. 23. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 25 Location: MidAmerica Environmental Holdings, LLC / USA Disposal (El Dorado) facility, located at 101 Warehouse Drive at 33.204359, -92.613940 City: El Dorado County/Parish: Union County State: Arkansas Photo File Name: 100-0247 Orientation: SSW Date of Photo: 07/16/2024 Time of Photo: 0926 Latitude: 33.204117 Longitude: -92.616031 Photographer: Kerri McCabe Description: Looking SSW, the receiving stream upstream of the stormwater pond drainpipes. Coloration of the stream was typical for the area, and live fishes were observed. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 26 Location: MidAmerica Environmental Holdings, LLC / USA Disposal (El Dorado) facility, located at 101 Warehouse Drive at 33.204359, -92.613940 City: El Dorado County/Parish: Union County State: Arkansas Photo File Name: 100-0248 Orientation: WSW Date of Photo: 07/16/2024 Time of Photo: 0926 Latitude: 33.204117 Longitude: -92.616031 Photographer: Kerri McCabe Description: Looking WSW, the receiving stream downstream of the stormwater pond drainpipes. Coloration of the stream was typical for the area, and live fishes were observed. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 27 Location: MidAmerica Environmental Holdings, LLC / USA Disposal (El Dorado) facility, located at 101 Warehouse Drive at 33.204359, -92.613940 City: El Dorado County/Parish: Union County State: Arkansas Photo File Name: 100-0249 Orientation: SE Date of Photo: 07/16/2024 Time of Photo: 0926 Latitude: 33.204017 Longitude: -92.615633 Photographer: Kerri McCabe Description: Looking SE, drainage area for the southern portion of the facility with stormwater flow directed toward the stormwater pond. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 28 Location: MidAmerica Environmental Holdings, LLC / USA Disposal (El Dorado) facility, located at 101 Warehouse Drive at 33.204359, -92.613940 City: El Dorado County/Parish: Union County State: Arkansas Photo File Name: 100-0250 Orientation: SSW Date of Photo: 07/16/2024 Time of Photo: 0936 Latitude: 33.204117 Longitude: -92.615233 Photographer: Kerri McCabe Description: Looking SSW, a concrete holding pit for the storage of liquid wastes located in the former wastewater treatment area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 29 Location: MidAmerica Environmental Holdings, LLC / USA Disposal (El Dorado) facility, located at 101 Warehouse Drive at 33.204359, -92.613940 City: El Dorado County/Parish: Union County State: Arkansas Photo File Name: 100-0251 Orientation: SE Date of Photo: 07/16/2024 Time of Photo: 0936 Latitude: 33.204050 Longitude: -92.615017 Photographer: Kerri McCabe Description: Looking SE, frac tanks or other storage containers have been removed from an area next to the sawdust storage building.