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Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: 03/05/2025 Water (CWA) Water (CWA) Brine Program (Oil & Gas inspection) Bonds Company Production, LLC Curry Lease Tank Battery From Stephens, State Highway 57, right on Ouachita County Road 79, left on oilfield road at 33.513497, -93.045767. Stephens, AR 71764 210 Jasper Street Stephens, AR 71764 Ouachita County 870-904-4719 Paul Bonds (870-904-4719) Person Responsible for Operation FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: N/A ARU002287 N/A 211111 1311 Personnel participating in inspection: Kerri McCabe (lead) EPA / Region 6 ECDW Michael Blaha EPA / Region 6 ECDW Paul Bonds Bonds Company Production, LLC RJ (no last name provided) Bonds Company Production, LLC Inspector / Enforcement Officer Inspector / Enforcement Officer Person Responsible for Operation Pumper EPA Lead Inspector Signature/Date Supervisor Signature/Date KERRI MCCABE Kerri McCabe Digitally signed by KERRI MCCABE Date: 2025.05.29 13:08:34 -05'00' Date JEANNE ECKHART Date: 2025.05.29 15:56:19 -05'00' Digitally signed by JEANNE ECKHART Jeanne Eckhart Date 6ENFORM-019-R8.2 (02/12/2020) 1 Section I - INTRODUCTION Bonds Company Production, LLC / Curry Lease Tank Battery (ARU002287 / CWA) Inspection Date 03/05/2025 PURPOSE OF THE INSPECTION Environmental Protection Agency (EPA) Region 6 inspectors Kerri McCabe (lead) and Michael Blaha arrived at the Bonds Company Production, LLC / Curry Lease Tank Battery ("facility") located from State Highway 57, right on Ouachita County Road 79, left on oilfield road at 33.513497, -93.045767 in Stephens, Ouachita County, Arkansas; at 0945 on 03/05/2025 for an unannounced inspection. After notifying Mr. Glen Owens, Inspector Supervisor with the Arkansas Oil and Gas Commission (AOGC), Mr. Paul Bonds arrived onsite to represent the facility during the inspection. The inspection was conducted by the authority of the Clean Water Act (CWA) to determine compliance with 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 Bonds Company Production, LLC / Curry Lease Tank Battery facility, which contains six (6) tanks for crude oil and saltwater storage and one (1) pump outside secondary containment used for saltwater injection into nearby Class II Saltwater Disposal (SWD) wells. Map 1. Aerial imagery (Google Earth dated 12/11/2024) of the Bonds Company Production, LLC / Curry Lease Tank Battery facility. 2 Bonds Company Production, LLC / Curry Lease Tank Battery (ARU002287 / CWA) Inspection Date 03/05/2025 Section II - OBSERVATIONS I observed the facility signage, secondary containment, pipes and valves, storage tanks, separators/treaters, and a pump for nearby Class II SWD injection wells; see Appendix 1 (Facility Photograph Log), Photo No. 1 through No. 3. For additional GPS location and photo metadata, see Appendix 1. I observed the pump used for saltwater transfer outside secondary containment with loose crude oil and saltwater on the ground, see Photos No. 3 through No. 6 and Photo No. 16. I observed transfer lines for product at the secondary containment structure and loose oil on the subsurface catchment buckets for those transfer lines, see Photos No. 7 through No. 10. I observed the inside of the secondary containment with loose crude oil and saltwater, see Photos No. 11 through No. 15 and Photos No. 17 and No. 18. I observed a saltwater storage tank with a hole that was actively leaking, see Photos No. 13 and No. 14. I observed a flowpath caused by the discharge of saltwater from the secondary containment drainpipe to the point of entry into the unnamed tributary of Cypress Creek, see Appendix 2. I observed the interior drainage area, the drainpipe, and the exterior flowpath for the secondary containment structure, see Photos No. 17 through No. 23. I observed the signage, two (2) production wells, two (2) SWD injection wells, and two (2) workover pits associated with the facility, see Photos No. 24 and No. 25 and Photos No. 35 through No. 41. I observed loose crude oil and saltwater outside secondary containment as well as saltwater staining and dead vegetation associated with active and residual releases from the SWD pump and metal flowlines to the SWD injection wells, see Photos No. 26 through No. 34. During the inspection, I observed the flowpath caused by the active releases from the secondary containment discharge pipe and the flowlines and measured Total Dissolved Solids (TDS) at the following locations (see Appendix 2 for photos and metadata): Location Drainpipe Flowpath Point of Entry (POE) Background Downstream #1 Downstream #2 Downstream #3 Downstream #4 Downstream of Flowline #1 Downstream of Flowline #2 Time 1004 1007 1012 1015 1018 1022 1025 1109 1111 TDS (mg/L) 13,035 2,741 45.1 182.8 191.9 158.7 155.1 3,174 1,577 Temperature (C) 13.3 11.0 10.3 10.1 9.7 9.7 9.2 11.8 12.0 Photo No. 1 4 7 10 13 16 19 22 25 3 Bonds Company Production, LLC / Curry Lease Tank Battery (ARU002287 / CWA) Inspection Date 03/05/2025 Note: All TDS field readings observed throughout the inspection were taken with a properly calibrated, EPA-issued, YSI Pro30 Conductivity/TDS/Salinity/Temperature Meter (#Y60530). Section III - AREAS OF CONCERN A closing conference was held with Mr. Paul Bonds with Bonds Company Production, LLC. While EPA was at the facility, Mr. Bonds and RJ, his pumper, stopped the active releases of saltwater at a storage tank, secondary containment drainpipe, and the two (2) flowline couplings to the SWD injection wells. Mr. Bonds was informed that the inspection was still under review, and that an inspection report would be provided documenting the inspection findings. Areas of concern at the time of the inspection include the following: Loose crude oil and saltwater from an SWD pump outside secondary containment (Photos No. 3 through No. 6), Transfer pipes with subsurface or missing catchment buckets and loose crude oil on the ground (Photos No. 7 through No. 10), Loose crude oil and saltwater inside secondary containment (Photos No. 11 and No. 12 and Photos No. 15, No. 17 and No. 18), An active leak of saltwater from a storage tank (Photos No. 13 and No. 14), An open drainpipe without a cap actively draining loose crude oil and saltwater (Photos No. 19 through No. 23), Two (2) production wells with residual crude oil on the ground and unlined workover pits with loose crude oil (Photos No. 24 and No. 25 and Photos No. 40 and No. 41), and Loose crude oil and saltwater outside secondary containment from the SWD pump, open drainpipe, and two (2) metal flowlines (Photos No. 26 and No. 28 through No. 34). 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. Section V - LIST OF APPENDICES Appendix 1 - Facility Photograph Log - 41 photos taken 03/05/2025. Appendix 2 - TDS Photograph Log - 27 photos taken 03/05/2025. 4 Bonds Company Production, LLC / Curry Lease Tank Battery (ARU002287 / CWA) Inspection Date 03/05/2025 Appendix 1 Facility Photograph Log 41 Photos UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0633 Orientation: 89 E Date of Photo: 03/05/2025 Time of Photo: 0946 Latitude: 33.513667 Longitude: -93.051933 Photographer: Kerri McCabe Description: Looking E, this photo shows the signage for the Bonds Company Production, LLC - Curry Lease ("facility"). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0634 Orientation: 56 ENE Date of Photo: 03/05/2025 Time of Photo: 0948 Latitude: 33.513350 Longitude: -93.051883 Photographer: Kerri McCabe Description: Looking ENE, this photo shows an overview of the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0635 Orientation: 87 E Date of Photo: 03/05/2025 Time of Photo: 0948 Latitude: 33.513417 Longitude: -93.051950 Photographer: Kerri McCabe Description: Looking E, this photo shows the saltwater disposal (SWD) pump outside secondary containment with loose crude oil and saltwater observed on the ground. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0636 Orientation: 67 ENE Date of Photo: 03/05/2025 Time of Photo: 0948 Latitude: 33.513433 Longitude: -93.051933 Photographer: Kerri McCabe Description: Looking ENE, this photo shows an open-top catch bucket for the SWD pump outside secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0637 Orientation: 64 ENE Date of Photo: 03/05/2025 Time of Photo: 0948 Latitude: 33.513433 Longitude: -93.051947 Photographer: Kerri McCabe Description: Looking ENE, this photo shows loose crude oil and saltwater on the ground around the SWD pump. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0638 Orientation: 113 ESE Date of Photo: 03/05/2025 Time of Photo: 0948 Latitude: 33.513483 Longitude: -93.051967 Photographer: Kerri McCabe Description: Looking ESE, this photo shows an additional view of the loose crude oil and saltwater on the ground from the SWD pump. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0639 Orientation: 32 NNE Date of Photo: 03/05/2025 Time of Photo: 0949 Latitude: 33.513600 Longitude: -93.052050 Photographer: Kerri McCabe Description: Looking NNE, this photo shows the transfer lines for the crude oil tanks with subsurface catchment buckets for two of the three pipes. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0640 Orientation: 42 NE Date of Photo: 03/05/2025 Time of Photo: 0949 Latitude: 33.513600 Longitude: -93.052050 Photographer: Kerri McCabe Description: Looking NE, this photo shows one transfer pipe with a subsurface catchment bucket with loose crude oil on the ground. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0641 Orientation: 43 NE Date of Photo: 03/05/2025 Time of Photo: 0949 Latitude: 33.513633 Longitude: -93.052083 Photographer: Kerri McCabe Description: Looking NE, this photo shows an additional transfer pipe with a subsurface catchment bucket with loose crude oil on the ground. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 10 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0642 Orientation: 56 ENE Date of Photo: 03/05/2025 Time of Photo: 0949 Latitude: 33.513633 Longitude: -93.052083 Photographer: Kerri McCabe Description: Looking ENE, this photo shows an additional transfer pipe without a catchment bucket. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 11 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0643 Orientation: 110 ESE Date of Photo: 03/05/2025 Time of Photo: 0949 Latitude: 33.513717 Longitude: -93.052000 Photographer: Kerri McCabe Description: Looking ESE, this photo shows the inside of the secondary containment (front view; right) with loose crude oil and saltwater. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 12 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0644 Orientation: 21 NNE Date of Photo: 03/05/2025 Time of Photo: 0950 Latitude: 33.513717 Longitude: -93.052000 Photographer: Kerri McCabe Description: Looking NNE, this photo shows the inside of the secondary containment (front view; left) with loose crude oil and saltwater. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 13 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0645 Orientation: 60 ENE Date of Photo: 03/05/2025 Time of Photo: 0950 Latitude: 33.513650 Longitude: -93.051917 Photographer: Kerri McCabe Description: Looking ENE, this photo shows a saltwater storage tank that was actively leaking inside secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 14 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0646 Orientation: 53 NE Date of Photo: 03/05/2025 Time of Photo: 0950 Latitude: 33.513650 Longitude: -93.051903 Photographer: Kerri McCabe Description: Looking NE, this photo shows an additional view of the saltwater storage tank from Photo No. 13 that was actively leaking inside secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 15 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0647 Orientation: 105 ESE Date of Photo: 03/05/2025 Time of Photo: 0951 Latitude: 33.513750 Longitude: -93.051903 Photographer: Kerri McCabe Description: Looking ESE, this photo shows the inside of the secondary containment (front view; right) with loose crude oil and saltwater. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 16 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0648 Orientation: 162 SSE Date of Photo: 03/05/2025 Time of Photo: 0951 Latitude: 33.513550 Longitude: -93.051917 Photographer: Kerri McCabe Description: Looking SSE, this photo shows an additional (top view) of the SWD pump outside secondary containment with loose crude oil and saltwater. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 17 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0649 Orientation: 26 NNE Date of Photo: 03/05/2025 Time of Photo: 0952 Latitude: 33.513483 Longitude: -93.051833 Photographer: Kerri McCabe Description: Looking NNE, this photo shows the sump area and flowpath inside secondary containment for the drainpipe associated with the facility. Directional arrow added for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 18 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0651 Orientation: 20 NNE Date of Photo: 03/05/2025 Time of Photo: 0952 Latitude: 33.513497 Longitude: -93.051791 Photographer: Kerri McCabe Description: Looking NNE, this photo shows an overview of the backside of the secondary containment with loose crude oil and saltwater. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 19 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0652 Orientation: 26 NNE Date of Photo: 03/05/2025 Time of Photo: 0952 Latitude: 33.513383 Longitude: -93.051791 Photographer: Kerri McCabe Description: Looking NNE, this photo shows the drainpipe for secondary containment that was open and actively releasing loose saltwater. Note residual loose crude oil at drainpipe. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 20 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0653 Orientation: 316 NW Date of Photo: 03/05/2025 Time of Photo: 0952 Latitude: 33.513350 Longitude: -93.051817 Photographer: Kerri McCabe Description: Looking NW, this photo shows the flowpath for the drainpipe for the secondary containment. Directional arrow added for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 21 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0654 Orientation: 7 N Date of Photo: 03/05/2025 Time of Photo: 0953 Latitude: 33.513433 Longitude: -93.051800 Photographer: Kerri McCabe Description: Looking N, this photo shows an additional view of the drainpipe for secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 22 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0655 Orientation: 47 NE Date of Photo: 03/05/2025 Time of Photo: 0953 Latitude: 33.513333 Longitude: -93.051867 Photographer: Kerri McCabe Description: Looking NE, this photo shows an additional view of the flowpath for the drainpipe for the secondary containment. Directional arrow added for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 23 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0656 Orientation: 97 E Date of Photo: 03/05/2025 Time of Photo: 0953 Latitude: 33.513183 Longitude: -93.051867 Photographer: Kerri McCabe Description: Looking E, this photo shows the continuation of the flowpath from Photo No. 22. Directional arrow added for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 24 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0671 Orientation: 319 NW Date of Photo: 03/05/2025 Time of Photo: 1016 Latitude: 33.512383 Longitude: -93.051967 Photographer: Kerri McCabe Description: Looking NW, this photo shows a production well associated with the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 25 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0673 Orientation: 296 WNW Date of Photo: 03/05/2025 Time of Photo: 1017 Latitude: 33.512250 Longitude: -93.052000 Photographer: Kerri McCabe Description: Looking WNW, this photo shows a pit next to the production well from Photo No. 24 that contained loose crude oil. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 26 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0683 Orientation: 257 WSW Date of Photo: 03/05/2025 Time of Photo: 1034 Latitude: 33.513167 Longitude: -93.052017 Photographer: Kerri McCabe Description: Looking WSW, this photo shows loose crude oil and saltwater adjacent to the facility (see Photo No. 16 for frame of reference). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 27 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0684 Orientation: 50 NE Date of Photo: 03/05/2025 Time of Photo: 1034 Latitude: 33.513167 Longitude: -93.052017 Photographer: Kerri McCabe Description: Looking NE, this photo shows the proximity of the loose crude oil and saltwater from Photo No. 26 to the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 28 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0685 Orientation: 357 N Date of Photo: 03/05/2025 Time of Photo: 1034 Latitude: 33.513050 Longitude: -93.052050 Photographer: Kerri McCabe Description: Looking N, this photo shows a closeup of the loose crude oil and saltwater from Photo No. 26. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 29 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0686 Orientation: 355 N Date of Photo: 03/05/2025 Time of Photo: 1036 Latitude: 33.513000 Longitude: -93.052200 Photographer: Kerri McCabe Description: Looking N, this photo shows a metal flowline from the facility to the SWD injection well actively leaking. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 30 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0687 Orientation: 217 SW Date of Photo: 03/05/2025 Time of Photo: 1036 Latitude: 33.513000 Longitude: -93.052216 Photographer: Kerri McCabe Description: Looking SW, this photo shows saltwater staining and dead vegetation around the flowline in Photo No. 29. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 31 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0688 Orientation: 45 NE Date of Photo: 03/05/2025 Time of Photo: 1037 Latitude: 33.513050 Longitude: -93.052250 Photographer: Kerri McCabe Description: Looking NE, this photo shows an additional view of the actively leaking flowline from Photo No. 29. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 32 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0689 Orientation: 31 NNE Date of Photo: 03/05/2025 Time of Photo: 1037 Latitude: 33.513083 Longitude: -93.052167 Photographer: Kerri McCabe Description: Looking NNE, this photo shows an additional view of the actively leaking flowline from Photo No. 29. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 33 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0690 Orientation: 102 ESE Date of Photo: 03/05/2025 Time of Photo: 1038 Latitude: 33.512900 Longitude: -93.052367 Photographer: Kerri McCabe Description: Looking ESE, this photo shows an additional metal flowline with an active leak at a coupling on the line. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 34 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0691 Orientation: 177 S Date of Photo: 03/05/2025 Time of Photo: 1039 Latitude: 33.512767 Longitude: -93.052467 Photographer: Kerri McCabe Description: Looking S, this photo shows an overview of the area of the second actively leaking flowline from Photo No. 33. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 35 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0692 Orientation: 88 E Date of Photo: 03/05/2025 Time of Photo: 1043 Latitude: 33.512450 Longitude: -93.052767 Photographer: Kerri McCabe Description: Looking E, this photo shows the signage for the Curry #13 SWD injection well associated with the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 36 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0693 Orientation: 139 SE Date of Photo: 03/05/2025 Time of Photo: 1044 Latitude: 33.512483 Longitude: -93.052867 Photographer: Kerri McCabe Description: Looking SE, this photo shows the Curry #13 SWD injection well associated with the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 37 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0694 Orientation: 123 ESE Date of Photo: 03/05/2025 Time of Photo: 1044 Latitude: 33.512183 Longitude: -93.052850 Photographer: Kerri McCabe Description: Looking ESE, this photo shows the signage for the Curry #A-1 SWD injection well associated with the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 38 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0695 Orientation: 4 N Date of Photo: 03/05/2025 Time of Photo: 1045 Latitude: 33.512017 Longitude: -93.052900 Photographer: Kerri McCabe Description: Looking N, this photo shows the Curry #A-1 SWD injection well associated with the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 39 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0696 Orientation: 319 NW Date of Photo: 03/05/2025 Time of Photo: 1059 Latitude: 33.513467 Longitude: -93.053717 Photographer: Kerri McCabe Description: Looking NW, this photo shows the signage for the Curry #7 production well associated with the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 40 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0697 Orientation: 40 NE Date of Photo: 03/05/2025 Time of Photo: 1059 Latitude: 33.513450 Longitude: -93.053683 Photographer: Kerri McCabe Description: Looking NE, this photo shows the Curry #7 production well and a pit associated with the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 41 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0698 Orientation: 35 NE Date of Photo: 03/05/2025 Time of Photo: 1059 Latitude: 33.513460 Longitude: -93.053683 Photographer: Kerri McCabe Description: Looking NE, this photo shows a closer view of the pit in Photo No. 40. Bonds Company Production, LLC / Curry Lease Tank Battery (ARU002287 / CWA) Inspection Date 03/05/2025 Appendix 2 TDS Photograph Log 27 Photos UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0659 Orientation: 358 N Date of Photo: 03/05/2025 Time of Photo: 1004 Latitude: 33.513300 Longitude: -93.051483 Photographer: Kerri McCabe Description: Looking N, this photo shows a Total Dissolved Solids (TDS) reading of 13,035 mg/L for the water in the flowpath from the Bonds Company Production, LLC - Curry Lease Tank Battery ("facility"). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0660 Orientation: 351 N Date of Photo: 03/05/2025 Time of Photo: 1004 Latitude: 33.513317 Longitude: -93.051517 Photographer: Kerri McCabe Description: Looking N, this photo shows the upstream characteristics of the TDS reading from Photo No. 1. Directional arrow added for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0661 Orientation: 82 E Date of Photo: 03/05/2025 Time of Photo: 1004 Latitude: 33.513317 Longitude: -93.051547 Photographer: Kerri McCabe Description: Looking E, this photo shows the downstream characteristics of the TDS reading from Photo No. 1. Directional arrow added for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0662 Orientation: 3 N Date of Photo: 03/05/2025 Time of Photo: 1007 Latitude: 33.513300 Longitude: -93.051450 Photographer: Kerri McCabe Description: Looking N, this photo shows a TDS reading of 2,741 mg/L at the discharge point of entry (POE) into an unnamed tributary of Cypress Creek. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0663 Orientation: 2 N Date of Photo: 03/05/2025 Time of Photo: 1007 Latitude: 33.513233 Longitude: -93.051417 Photographer: Kerri McCabe Description: Looking N, this photo shows the upstream characteristics of the TDS reading from Photo No. 4. Directional arrow added for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0664 Orientation: 181 S Date of Photo: 03/05/2025 Time of Photo: 1008 Latitude: 33.513200 Longitude: -93.051433 Photographer: Kerri McCabe Description: Looking S, this photo shows the downstream characteristics of the TDS reading from Photo No. 4. Directional arrows added for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0665 Orientation: 73 ENE Date of Photo: 03/05/2025 Time of Photo: 1012 Latitude: 33.513367 Longitude: -93.051250 Photographer: Kerri McCabe Description: Looking ENE, this photo shows a TDS reading of 45.1 mg/L for the background location upstream of the discharge POE. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0666 Orientation: 87 E Date of Photo: 03/05/2025 Time of Photo: 1012 Latitude: 33.513367 Longitude: -93.051240 Photographer: Kerri McCabe Description: Looking E, this photo shows the upstream characteristics of the TDS reading from Photo No. 7. Directional arrow added for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0667 Orientation: 166 SSE Date of Photo: 03/05/2025 Time of Photo: 1012 Latitude: 33.513304 Longitude: -93.051265 Photographer: Kerri McCabe Description: Looking SSE, this photo shows the downstream characteristics of the TDS reading from Photo No. 7. Directional arrow added for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 10 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0668 Orientation: 51 NE Date of Photo: 03/05/2025 Time of Photo: 1015 Latitude: 33.513050 Longitude: -93.051717 Photographer: Kerri McCabe Description: Looking NE, this photo shows a TDS reading of 182.8 mg/L for a location downstream (DS #1) of the discharge POE. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 11 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0669 Orientation: 47 NE Date of Photo: 03/05/2025 Time of Photo: 1015 Latitude: 33.513050 Longitude: -93.051633 Photographer: Kerri McCabe Description: Looking NE, this photo shows the upstream characteristics of the TDS reading from Photo No. 10. Directional arrow added for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 12 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0670 Orientation: 124 SE Date of Photo: 03/05/2025 Time of Photo: 1015 Latitude: 33.512917 Longitude: -93.051700 Photographer: Kerri McCabe Description: Looking SE, this photo shows the downstream characteristics of the TDS reading from Photo No. 10. Directional arrow added for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 13 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0674 Orientation: 11 NNE Date of Photo: 03/05/2025 Time of Photo: 1018 Latitude: 33.512000 Longitude: -93.051650 Photographer: Kerri McCabe Description: Looking NNE, this photo shows a TDS reading of 191.9 mg/L for a location downstream (DS #2) of the discharge POE. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 14 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0675 Orientation: 31 NNE Date of Photo: 03/05/2025 Time of Photo: 1018 Latitude: 33.512167 Longitude: -93.051583 Photographer: Kerri McCabe Description: Looking NNE, this photo shows the upstream characteristics of the TDS reading from Photo No. 13. Directional arrow added for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 15 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0676 Orientation: 130 SE Date of Photo: 03/05/2025 Time of Photo: 1018 Latitude: 33.512217 Longitude: -93.051600 Photographer: Kerri McCabe Description: Looking SE, this photo shows the downstream characteristics of the TDS reading from Photo No. 13. Directional arrow added for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 16 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0677 Orientation: 89 E Date of Photo: 03/05/2025 Time of Photo: 1022 Latitude: 33.511550 Longitude: -93.052383 Photographer: Kerri McCabe Description: Looking E, this photo shows a TDS reading of 158.7 mg/L for a location downstream (DS #3) of the discharge POE. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 17 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0678 Orientation: 85 E Date of Photo: 03/05/2025 Time of Photo: 1022 Latitude: 33.511583 Longitude: -93.052400 Photographer: Kerri McCabe Description: Looking E, this photo shows the upstream characteristics of the TDS reading from Photo No. 16. Directional arrow added for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 18 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0679 Orientation: 251 WSW Date of Photo: 03/05/2025 Time of Photo: 1022 Latitude: 33.511597 Longitude: -93.052400 Photographer: Kerri McCabe Description: Looking WSW, this photo shows the downstream characteristics of the TDS reading from Photo No. 16. Directional arrow added for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 19 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0680 Orientation: 349 N Date of Photo: 03/05/2025 Time of Photo: 1025 Latitude: 33.511533 Longitude: -93.053267 Photographer: Kerri McCabe Description: Looking N, this photo shows a TDS reading of 155.1 mg/L for a location downstream (DS #4) of the discharge POE. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 20 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0681 Orientation: 95 E Date of Photo: 03/05/2025 Time of Photo: 1026 Latitude: 33.511518 Longitude: -93.053219 Photographer: Kerri McCabe Description: Looking E, this photo shows the upstream characteristics of the TDS reading from Photo No. 19. Directional arrow added for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 21 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0682 Orientation: 302 WNW Date of Photo: 03/05/2025 Time of Photo: 1026 Latitude: 33.511501 Longitude: -93.053186 Photographer: Kerri McCabe Description: Looking WNW, this photo shows the downstream characteristics of the TDS reading from Photo No. 19. Directional arrow added for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 22 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0699 Orientation: 73 ENE Date of Photo: 03/05/2025 Time of Photo: 1109 Latitude: 33.512783 Longitude: -93.053250 Photographer: Kerri McCabe Description: Looking ENE, this photo shows a TDS reading of 3,174 mg/L for an unnamed tributary downstream of two flowline releases. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 23 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0700 Orientation: 92 E Date of Photo: 03/05/2025 Time of Photo: 1109 Latitude: 33.512770 Longitude: -93.053250 Photographer: Kerri McCabe Description: Looking E, this photo shows the upstream characteristics of the TDS reading from Photo No. 22. Directional arrow added for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 24 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0701 Orientation: 317 NW Date of Photo: 03/05/2025 Time of Photo: 1109 Latitude: 33.512783 Longitude: -93.053267 Photographer: Kerri McCabe Description: Looking NW, this photo shows the downstream characteristics of the TDS reading from Photo No. 22. Directional arrow added for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 25 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0702 Orientation: 53 NE Date of Photo: 03/05/2025 Time of Photo: 1111 Latitude: 33.512900 Longitude: -93.053117 Photographer: Kerri McCabe Description: Looking NE, this photo shows a TDS reading of 1,577 mg/L for an unnamed tributary downstream of two flowline releases. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 26 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0703 Orientation: 45 NE Date of Photo: 03/05/2025 Time of Photo: 1111 Latitude: 33.512900 Longitude: -93.053117 Photographer: Kerri McCabe Description: Looking NE, this photo shows the upstream characteristics of the TDS reading from Photo No. 25. Directional arrow added for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 27 Location: From Stephens, State Highway 57, right on Ouachita County Road 79, left on Oilfield Road at 33.513497, -93.045767. City: Stephens County/Parish: Ouachita State: Arkansas Photo File Name: 100-0704 Orientation: 206 SSW Date of Photo: 03/05/2025 Time of Photo: 1111 Latitude: 33.512900 Longitude: -93.053150 Photographer: Kerri McCabe Description: Looking SSW, this photo shows the downstream characteristics of the TDS reading from Photo No. 25. Directional arrow added for clarity.