Document NOyqeQk6dXvGvompnXgw7D6V

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 4/3/24 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: LBOC, LLC Reynolds C-3 SWD Tank Battery From Highway 7 North, thence Arkansas Highway 335, thence N Texas Rd, thence Hayes City Rd, thence Ouachita County Rd 68, thence Ouachita County Rd 511, off oil field lease road at 33.389937, -92.645310. Norphlet, AR 71759 787 Baugh Street Norphlet, AR 71759 Ouachita County 870-546-3457 Scott Carter Person Responsible for Operation longbrosoil@yahoo.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: N/A ARU002247 N/A 211111 1311 Personnel participating in inspection: Kerri McCabe (lead) EPA / Region 6 ECDW Inspector / Enforcement Officer EPA Lead Inspector Signature/Date Supervisor Signature/Date KERRI MCCABE Kerri McCabe Digitally signed by KERRI MCCABE Date: 2024.05.07 07:38:50 -05'00' Date JEANNE ECKHART Date: 2024.05.09 08:59:01 -05'00' Digitally signed by JEANNE ECKHART Jeanne Eckhart Date 6ENFORM-019-R8.2 (02/12/2020) 1 Section I - INTRODUCTION LBOC, LLC / Reynolds C-3 SWD Tank Battery (ARU002247 / CWA) Inspection Date 04/03/2024 PURPOSE OF THE INSPECTION EPA Region 6 Inspector Kerri McCabe (lead) arrived at the LBOC, LLC / Reynolds C-3 SWD Tank Battery, located from Highway 7 North, thence Arkansas Highway 335, thence N Texas Rd, thence Hayes City Rd, thence Ouachita County Rd 68, thence Ouachita County Rd 511, off oil field lease road at 33.389937, 92.645310; at 1543 on 4/3/24 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 on the LBOC, LLC / Reynolds C-3 SWD Tank Battery, which contains one (1) oil-water separator, four (4) storage tanks, one (1) saltwater disposal (SWD) well, and one (1) crude oil production well. Section II - OBSERVATIONS I observed the facility sign, secondary containment, pipes and valves, and storage tanks located at the facility; see Appendix 1 (Photographs Log), Photo No. 1 through No. 2. For additional GPS location and photo metadata, see Appendix 1. I observed the drainpipe for secondary containment with a closed valve and a cap (partially threaded); salt crystals were observed on the ground around the drainpipe; see Photo No. 3 through No. 5. I observed the transfer pipe through secondary containment without a catch bucket and loose oil on the ground, see Photo No. 6. I observed the SWD well to have loose oil and solid waste around the area, see Photo No. 7. I observed active leaks of crude oil and saltwater inside secondary containment, see Photo No. 8, No. 10 through No. 11. I observed woody vegetation within the firewall berm, see Photo No. 9. Section III - AREAS OF CONCERN No closing conference was held due to no personnel with LBOC, LLC being present during the inspection. Areas of concern at the time of the inspection include the drainpipe with a partially threaded cap and evidence of salt crystals around the pipe, the transfer pipe without a catch bucket and loose oil around the pipe, the loose oil and solid waste around the SWD well, active leaks at valves and tanks inside secondary containment, and woody vegetation within the firewall berm. 2 Section IV - FOLLOW UP LBOC, LLC / Reynolds C-3 SWD Tank Battery (ARU002247 / CWA) Inspection Date 04/03/2024 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. Section V - LIST OF APPENDICES Appendix 1 - Photograph Log - 11 photos taken 4/3/24. 3 LBOC, LLC / Reynolds C-3 SWD Tank Battery (ARU002247 / CWA) Inspection Date 04/03/2024 Appendix 1 Photograph Log 11 Photos UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: LBOC, LLC - Reynolds C-3 SWD Tank Battery from Ouachita County Rd 511 off oil field lease road at 33.389937, -92.645310. City: Smackover County/Parish: Ouachita State: Arkansas Photo File Name: P4020102 Orientation: NW Date of Photo: 04/03/2024 Time of Photo: 1613 Latitude: 33.389942 Longitude: -92.645167 Photographer: Kerri McCabe Description: Looking NW, this photo showed the signage at the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: LBOC, LLC - Reynolds C-3 SWD Tank Battery from Ouachita County Rd 511 off oil field lease road at 33.389937, -92.645310. City: Smackover County/Parish: Ouachita State: Arkansas Photo File Name: P4020103 Orientation: W Date of Photo: 04/03/2024 Time of Photo: 1613 Latitude: 33.389891 Longitude: -92.645393 Photographer: Kerri McCabe Description: Looking W, this photo showed an overview of the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: LBOC, LLC - Reynolds C-3 SWD Tank Battery from Ouachita County Rd 511 off oil field lease road at 33.389937, -92.645310. City: Smackover County/Parish: Ouachita State: Arkansas Photo File Name: P4020104 Orientation: NE Date of Photo: 04/03/2024 Time of Photo: 1613 Latitude: 33.389923 Longitude: -92.645376 Photographer: Kerri McCabe Description: Looking NE, this photo showed the drainpipe for the secondary containment; I noted the valve was closed and the pipe had a cap. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: LBOC, LLC - Reynolds C-3 SWD Tank Battery from Ouachita County Rd 511 off oil field lease road at 33.389937, -92.645310. City: Smackover County/Parish: Ouachita State: Arkansas Photo File Name: P4020105 Orientation: NE Date of Photo: 04/03/2024 Time of Photo: 1614 Latitude: 33.389923 Longitude: -92.645376 Photographer: Kerri McCabe Description: Looking NE, this photo showed a closeup of the drainpipe from Photo No. 3; an active leak was noted at the drainpipe cap. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: LBOC, LLC - Reynolds C-3 SWD Tank Battery from Ouachita County Rd 511 off oil field lease road at 33.389937, -92.645310. City: Smackover County/Parish: Ouachita State: Arkansas Photo File Name: P4020106 Orientation: E-SE Date of Photo: 04/03/2024 Time of Photo: 1614 Latitude: 33.389923 Longitude: -92.645376 Photographer: Kerri McCabe Description: Looking E-SE, this photo showed a closeup of salt crystals under the drainpipe from Photo No. 3. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: LBOC, LLC - Reynolds C-3 SWD Tank Battery from Ouachita County Rd 511 off oil field lease road at 33.389937, -92.645310. City: Smackover County/Parish: Ouachita State: Arkansas Photo File Name: P4020107 Orientation: W-NW Date of Photo: 04/03/2024 Time of Photo: 1614 Latitude: 33.389948 Longitude: -92.645179 Photographer: Kerri McCabe Description: Looking W-NW, this photo showed a transfer pipe through secondary containment without a catch bucket and loose oil on the ground. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: LBOC, LLC - Reynolds C-3 SWD Tank Battery from Ouachita County Rd 511 off oil field lease road at 33.389937, -92.645310. City: Smackover County/Parish: Ouachita State: Arkansas Photo File Name: P4020108 Orientation: W Date of Photo: 04/03/2024 Time of Photo: 1615 Latitude: 33.390011 Longitude: -92.645066 Photographer: Kerri McCabe Description: Looking W, this photo showed the saltwater disposal (SWD) well with loose oil and solid waste on the ground. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: LBOC, LLC - Reynolds C-3 SWD Tank Battery from Ouachita County Rd 511 off oil field lease road at 33.389937, -92.645310. City: Smackover County/Parish: Ouachita State: Arkansas Photo File Name: P4020109 Orientation: E Date of Photo: 04/03/2024 Time of Photo: 1615 Latitude: 33.390027 Longitude: -92.645148 Photographer: Kerri McCabe Description: Looking E, this photo showed an active saltwater leak into secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 Location: LBOC, LLC - Reynolds C-3 SWD Tank Battery from Ouachita County Rd 511 off oil field lease road at 33.389937, -92.645310. City: Smackover County/Parish: Ouachita State: Arkansas Photo File Name: P4020110 Orientation: E-SE Date of Photo: 04/03/2024 Time of Photo: 1616 Latitude: 33.390089 Longitude: -92.645173 Photographer: Kerri McCabe Description: Looking E-SE, this photo showed woody vegetation growing in the firewall. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 10 Location: LBOC, LLC - Reynolds C-3 SWD Tank Battery from Ouachita County Rd 511 off oil field lease road at 33.389937, -92.645310. City: Smackover County/Parish: Ouachita State: Arkansas Photo File Name: P4020111 Orientation: S-SE Date of Photo: 04/03/2024 Time of Photo: 1616 Latitude: 33.390050 Longitude: -92.645264 Photographer: Kerri McCabe Description: Looking S-SE, this photo showed a saltwater release inside secondary containment with staining, salt crystals, and dead vegetation. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 11 Location: LBOC, LLC - Reynolds C-3 SWD Tank Battery from Ouachita County Rd 511 off oil field lease road at 33.389937, -92.645310. City: Smackover County/Parish: Ouachita State: Arkansas Photo File Name: P4020112 Orientation: SW Date of Photo: 04/03/2024 Time of Photo: 1618 Latitude: 33.389990 Longitude: -92.645269 Photographer: Kerri McCabe Description: Looking SW, this photo showed a valve for a storage tank with loose oil inside secondary containment.