Document NNDOaNr2QVa7zLKn2okX746Q

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 06/27/2022 Water Clean Water Act - National Pollution Discharge Elimination System (Brine) Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: McCann Resources, Inc Bowring Lease Latitude: 36.871074, Longitude: -96.125656 Bowring, Oklahoma, 74056 2300 N Lincoln Blvd Rm 101 Oklahoma City, Oklahoma, 73105 Osage County (918) 798-4365 Mark McCann Owner/Operator mccanncompanies@yahoo.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: n/a OKU000848 n/a 211111 1311 Personnel participating in inspection: Matthew Allen EPA, Region 6ECDW Dallas Nave BIA, Osage Agency Inspector Field Inspector EPA Lead Inspector Signature/Date Supervisor Signature/Date MATTHEW ALLEN Date: 2022.07.14 15:42:02 -05'00' Digitally signed by MATTHEW ALLEN Matthew Allen Date ANTHONY LOSTON Digitally signed by ANTHONY LOSTON DN: c=US, o=U.S. Government, ou=Environmental Protection Agency, cn=ANTHONY LOSTON, 0.9.2342.19200300.100.1.1=68001003655738 Date: 2022.07.18 08:56:06 -05'00' Anthony Loston (acting) Date 6ENFORM-019-R8.2 (02/12/2020) 1 Section I - INTRODUCTION McCann Resources, Inc / Bowring Lease Inspection Date 06/27/2022 PURPOSE OF THE INSPECTION EPA Region 6 inspector Matthew Allen arrived at the McCann Resources Inc, Bowring Lease, (EPA ID No. OKU000848) at 09:30 AM on 06/27/2022 for an unannounced inspection. There was no company representative present during the inspection. This was an EPA inspection in response to a National Response Center Spill Report (NRC# 1339940) which was received by EPA Region 6. EPA Inspector, Matthew Allen, also received notification of the spill from The Bureau of Indian Affairs (BIA) Osage Agency, Field Inspector, Dallas Nave. The inspection was conducted by the authority of the Clean Water Act to determine compliance with Environmental Protection Agency (EPA) regulations. BIA Filed Inspector, Dallas Nave, accepted an invitation to participate during the inspection. FACILITY DESCRIPTION EPA conducted an inspection beginning on the McCann Resources Inc, Bowring Lease, (GPS 36.871074, -96.125656) where a 2-inch diameter poly flowline carrying produced water (brine) and oil crossed an unnamed tributary. The flowline had pulled apart at a collar joint and spilled produced fluids directly into the main channel of an unnamed tributary of Mission Creek. The flowline carried fluids from the production well to the separation/storage facility (Bowring Lease tank battery). The Bowring Lease was located south of Bowring, Oklahoma, in Osage County. Section II - OBSERVATIONS During the inspection, I observed the Release Point and the Point of Entry (POE) into the main channel of an unnamed tributary of Mission Creek. I observed 3 men, employees of McCann Resources Inc, and a tank truck working to remove oil from the impacted tributary near the POE. The release point and POE were the same location (GPS 36.871074, -96.125656). The release point and POE are documented in Appendix 1 (photo log), Photo No. 1. I observed a 2-inch diameter poly flowline which had pulled apart at a collar connection in the middle of the streambed. At the time of the inspection there was a pinchoff tool installed on each end of the damaged flowline to prevent the release of additional produced water and oil. I observed crude oil floating on the water in the tributary and oil-stained rocks, soil and vegetation were present at the POE. Each of the POE observations are documented in Photo No. 1 (GPS 36.871074, -96.125656). Using a properly calibrated YSI Pro 30 conductivity meter, I observed an elevated Total Dissolved Solids (TDS) field reading of 54,136 mg/L in the main channel of the impacted tributary at the POE, this was the highest TDS field reading observed during the inspection, this was documented in Photo No. 2 (GPS 36.871105, -96.125708). I observed a "background" TDS field reading approximately 150 feet upstream from the POE along the main channel of the impacted tributary, the background reading was taken in a pool of water which was not impacted by the spill and can be seen in Photo No. 3 (GPS 36.871470, -96.125860). I observed oil floating on the surface of the water in the impacted tributary approximately 100 feet upstream from the 2 McCann Resources, Inc / Bowring Lease Inspection Date 06/27/2022 POE, oil staining was present on the banks and vegetation at the same location, this can be seen in Photo No. 4 (GPS 36.871202, -96.125883). I observed oil on the surface of the tributary and oil stains which showed a high-water mark along the bank of the tributary, this was documented in Photo No. 5 (GPS 36.871202, -96.125883) and was located approximately 75 feet upstream from the POE. Approximately 25 feet downstream from the POE, in the first downstream pool of water I observed a large smoldering log. I observed charred logs and vegetation in and along the tributary as well as thick black oil on the surface of the tributary, which appeared to have been burned in-situ. I also observed an elevated TDS field reading of 2,242 mg/L at the same location, these observations can be seen in Photos No. 6 and 7 (GPS 36.870984, -96125552). Approximately 75 feet downstream from the POE, in the main channel of the tributary, I observed an elevated TDS field reading of 8,121 mg/L, which was documented in Photo No.8 (36.870952, 96.125347). I observed a moderate amount of oil floating on the water in the impacted tributary and captured an accurate representation of the bed and bank features of the tributary with both upstream view and downstream view photos which were documented in Photos No. 9 & 10 (GPS 36.870952, 96.125347) respectively. I observed an elevated TDS field reading of 2,194 mg/L) as well as a floating oil absorbent containment boom approximately 150 feet downstream from the POE, these observations were documented in Photos No. 11 & 12 (GPS 36.871095, -96.125060). Approximately 0.25 miles downstream from the POE, I observed an elevated TDS field reading of 2,975 mg/L and documented the physical characteristics of the tributaries' bed and bank features, these observations were documented in Photos No. 13, 14 and 15 (GPS 36.869907, -96.122289). I observed an elevated TDS field reading of 493 mg/L which was documented in Photo No. 16 (GPS 36.866742, -96.119610), this reading was observed approximately 135 feet upstream from the confluence of the impacted tributary and Mission Creek. I observed a TDS field reading of 227 mg/L along the impacted tributary where the water depth was approximately 2 inches deep and actively flowing with moderate flow toward Mission Creek, this reading was taken approximately 30 feet upstream from the confluence of the impacted tributary and Mission Creek, this was documented in Photo No. 17 (GPS 36.866470, -96.119427). I observed a TDS field reading of 335.3 mg/L in Mission Creek at the confluence of the impacted tributary and Mission Creek, which was documented in Photo No. 18 (GPS 36.866379, -96.119401). I observed and documented the impacted tributary as is flowed into Mission Creek, this was documented in Photo No. 19 (36.866379, -96.119401). I observed the streambed and bank of Mission Creek with a view looking southeast from the confluence of the impacted tributary with Mission Creek, this observation was documented in Photo No. 20 (36.866379, -96.119401). I did not observe any temporary containment structures at the time of the inspection to prevent the downstream migration of brine contaminated waters. 3 Section III - AREAS OF CONCERN McCann Resources, Inc / Bowring Lease Inspection Date 06/27/2022 EPA Region 6 inspector conducted a conference call with Mark McCann at the end of the inspection which began at 12:52 PM and lasted 3 minutes. I conveyed my primary areas of concern which were the containment and removal of brine and oil impacted water to prevent further downstream migration and impacts. I also noted the need to clean oil-stained banks, rocks, and vegetation along the impacted area. Section IV - FOLLOW UP EPA Inspector, Matthew Allen, conducted a follow-up call with Mark McCann on 06/29/2022 which began at 10:23 AM and lasted 3 minutes. Mr. McCann stated his employees had removed approximately 6 tank truck loads of impacted water from the tributary and had applied oil absorbent pads to remove much of the oil from the surface of the tributary. Mr. McCann stated his employees would continue working to reduce pollution in the tributary until satisfactory results are achieved. The EPA Inspector informed Mr. McCann there would be a follow-up inspection within the following 7-10 days to assess progress of the cleanup efforts. Section V - LIST OF APPENDICES Appendix 1 - Photo Log - 20 photos taken 06/27/2022 4 McCann Resources Inc/ Bowring Lease (CWA) Inspection Date: 06/27/2022 Appendix 1 Photograph Log 20 Photos UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.871074, -96.125656 City: Bowring Photo No. 1 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0605 Orientation: NW Date of Photo: 06/27/2022 Time of Photo: 9:49 AM Latitude: 36.871074 Longitude: -96.125656 Photographer: Matthew Allen Description: This was the Release Point and the Point of Entry (POE) of the spill. The 2-inch diameter poly flowline was parted in the middle of the streambed. There was a pinch-off tool installed on each side of the damaged flowline to prevent additional fluid release from the flowline. Crude oil was floating on the surface of the water and crude oil stains were on the rocks, soil, and vegetation in and around the tributary. This unnamed tributary was a tributary of Mission Creek. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.871074, -96.125656 City: Bowring Photo No. 2 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0607 Orientation: n/a Date of Photo: 06/27/2022 Time of Photo: 09:57 Latitude: 36.871105 Longitude: -96.125708 Photographer: Matthew Allen Description: This was an elevated Total Dissolved Solids (TDS) field reading of 54,236 mg/L taken in the pool where the produced water entered the tributary (POE). This field reading and all others included in this report/photo log were taken with a properly calibrated YSI Pro 30 conductivity meter. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.871074, -96.125656 City: Bowring Photo No. 3 County/Parish: Osage State: Oklahoma Photo File Name: DSC0608 Orientation: n/a Date of Photo: 06/27/2022 Time of Photo: 10:07 AM Latitude: 36.871470 Longitude: -96.125860 Photographer: Matthew Allen Description: This was a "background" TDS field reading of 259.0 mg/L taken approximately 150 feet upstream from the POE. This field reading was taken in a pool of water along the main channel of the tributary which was not impacted by the spilled fluids. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.871074, -96.125656 City: Bowring Photo No. 4 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0609 Orientation: NW Date of Photo: 06/27/2022 Time of Photo: 10:13 AM Latitude: 36.871202 Longitude: -96.125883 Photographer: Matthew Allen Description: This was a photo of oil floating on the surface of the impacted tributary, oil staining was also present on the banks and vegetation. This photo was taken approximately 100 feet upstream from the POE in the same pool of water as the POE, oil was blown west/upstream by wind across the surface of the pool. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.871074, -96.125656 City: Bowring Photo No. 5 County/Parish: Osage State: Oklahoma Photo File Name: DSC0610 Orientation: N Date of Photo: 06/27/2022 Time of Photo: 10:13 AM Latitude: 36.871202 Longitude: -96.125883 Photographer: Matthew Allen Description: This was a photo showing oil stains along a high-water mark on the bank of the tributary. Oil was also floating on the surface of the tributary. This photo was taken approximately 75 feet upstream from the POE in the same pool of water as the POE. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.871074, -96.125656 City: Bowring Photo No. 6 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0612 Orientation: NW Date of Photo: 06/27/2022 Time of Photo: 10:28 AM Latitude: 36.870984 Longitude: -96.125552 Photographer: Matthew Allen Description: This photo was taken approximately 25 feet downstream from the POE in the first downstream pool from the POE. There was smoke coming from the log in the upper left corner of the photo. A large dead tree was burned and the oil floating on the surface of the water in the tributary was dark black and thick, and appeared to have been burned in-situ. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.871074, -96.125656 City: Bowring Photo No. 7 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0611 Orientation: n/a Date of Photo: 06/27/2022 Time of Photo: 10:27 AM Latitude: 36.870984 Longitude: -96.125552 Photographer: Matthew Allen Description: This was an elevated TDS field of 2,242 mg/L reading taken in a shallow portion of the first pool of water downstream from the POE, this reading was taken approximately 25 feet downstream from the POE. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.871074, -96.125656 City: Bowring Photo No. 8 County/Parish: Osage State: Oklahoma Photo File Name: DSCN6013 Orientation: n/a Date of Photo: 06/27/2022 Time of Photo: 10:35 AM Latitude: 36.870952 Longitude: -96.125347 Photographer: Matthew Allen Description: This was an elevated TDS field reading of 8,121 mg/L taken approximately 75 feet downstream from the POE in the first pool of water downstream from the POE. This reading was taken in a deeper section of the main channel of the impacted tributary. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.871074, -96.125656 City: Bowring Photo No. 9 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0614 Orientation: W Date of Photo: 06/27/2022 Time of Photo: 10:39 AM Latitude: 36.870952 Longitude: -96.125347 Photographer: Matthew Allen Description: This was a photo showing the bed and bank features of the tributary. This photo was taken from a location approximately 75 feet downstream from the POE with a view looking to the west/upstream toward the POE. Oil was present on the surface of the water and on the vegetation along the banks of the tributary. The elevated TDS field reading of 8,121 mg/L was taken at this location. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.871074, -96.125656 City: Bowring Photo No. 10 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0615 Orientation: NE Date of Photo: 06/27/2022 Time of Photo: 10:41 AM Latitude: 36.870952 Longitude: -96.125347 Photographer: Matthew Allen Description: This was a photo showing the bed and bank features of the tributary. This photo was taken from a location approximately 75 feet downstream from the POE with a view looking to the northeast/downstream from the POE. Oil was present on the surface of the water and on the vegetation along the banks of the tributary. The elevated TDS field reading of 8,121 mg/L was taken at this location. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.871074, -96.125656 City: Bowring Photo No. 11 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0616 Orientation: n/a Date of Photo: 06/27/2022 Time of Photo: 11:00 AM Latitude: 36.871095 Longitude: -96.125060 Photographer: Matthew Allen Description: This was an elevated TDS field reading of 2,194 mg/L taken at lower end of the first downstream pool. This reading was taken approximately 150 feet downstream from the POE. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.871074, -96.125656 City: Bowring Photo No. 12 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0617 Orientation: W Date of Photo: 06/27/2022 Time of Photo: 11:02 AM Latitude: 36.871095 Longitude: -96.125060 Photographer: Matthew Allen Description: This was a floating oil absorbent boom which had been placed across the tributary by the operator to prevent migration of oil downstream. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.871074, -96.125656 City: Bowring Photo No. 13 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0623 Orientation: n/a Date of Photo: 06/27/2022 Time of Photo: 12:16 PM Latitude: 36.869907 Longitude: -96.122289 Photographer: Matthew Allen Description: This was an elevated TDS field reading of 2,975 mg/L taken in the main channel of the impacted tributary approximately 0.25 miles downstream from the POE. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.871074, -96.125656 City: Bowring Photo No. 14 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0624 Orientation: SE Date of Photo: 06/27/2022 Time of Photo: 12:18 PM Latitude: 36.869907 Longitude: -96.122289 Photographer: Matthew Allen Description: This was a view looking southeast/downstream from the same location as Photo No 13. This photo was an accurate representation of the bed and bank features of the tributary. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.871074, -96.125656 City: Bowring Photo No. 15 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0625 Orientation: W Date of Photo: 06/27/2022 Time of Photo: 12:18 PM Latitude: 36.869907 Longitude: -96.122289 Photographer: Matthew Allen Description: This was a view looking west/upstream from the same location as Photo No 13. This photo was an accurate representation of the bed and bank features of the tributary. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.871074, -96.125656 City: Bowring Photo No. 16 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0618 Orientation: n/a Date of Photo: 06/27/2022 Time of Photo: 11:55 AM Latitude: 36.866742 Longitude: -96.119610 Photographer: Matthew Allen Description: This was an elevated TDS field reading of 493 mg/L, this was the last "pool" of water along the impacted tributary before the tributary flowed into Mission Creek. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.871074, -96.125656 City: Bowring Photo No. 17 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0619 Orientation: n/a Date of Photo: 06/27/2022 Time of Photo: 11:58 AM Latitude: 36.866470 Longitude: -96.119427 Photographer: Matthew Allen Description: This was a TDS field reading taken in a section of the tributary where the water depth was approximately 2 inches deep. This measurement was taken approximately 30 feet upstream in the impacted tributary before the confluence with Mission Creek. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.871074, -96.125656 City: Bowring Photo No. 18 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0620 Orientation: n/a Date of Photo: 06/27/2022 Time of Photo: 12:01 PM Latitude: 36.866379 Longitude: -96.119401 Photographer: Matthew Allen Description: This was a TDS field reading of 335.3 mg/L taken in Mission Creek at the confluence with the impacted tributary. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.871074, -96.125656 City: Bowring Photo No. 19 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0621 Orientation: S Date of Photo: 06/27/2022 Time of Photo: 12:03 PM Latitude: 36.866379 Longitude: -96.119401 Photographer: Matthew Allen Description: This was a photo taken while standing in the impacted tributary. The impacted tributary flowed from the bottom of the photo, north to south, into the large pool of water. The large pool of water was Mission Creek. Mission Creek flowed from right to left in the photo, or west to east. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.871074, -96.125656 City: Bowring Photo No. 20 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0622 Orientation: SE Date of Photo: 06/27/2022 Time of Photo: 12:04 PM Latitude: 36.866379 Longitude: -96.119401 Photographer: Matthew Allen Description: This was a photo taken at the confluence of the impacted tributary and Mission Creek. The photo provided a view to the southeast and looked downstream along Mission Creek. Mission Creek flowed from right to left, or west to east in this photo. The impacted tributary flowed into Mission Creek from the lower left corner of the photo.