Document NjKGvvegRn4OrmR8Kkv7JNdD

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 09/16/2022 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: Northcote Cleveland LLC Osage B Lease Latitude: 36.259597, Longitude: -96.225672 Prue, Oklahoma, 74060 701 S Eighth St Ponca City, Oklahoma, 74601 Osage County 580-304-1193 Cody Mather Owner/Operator Cody_mather@hotmail.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: n/a OKU000856 n/a 211111 1311 Personnel participating in inspection: Matthew Allen EPA, Region 6ECDW Inspector EPA Lead Inspector Signature/Date Supervisor Signature/Date MATTHEW ALLEN Digitally signed by MATTHEW ALLEN DN: c=US, o=U.S. Government, ou=Environmental Protection Agency, cn=MATTHEW ALLEN, 0.9.2342.19200300.100.1.1=68001004162907 Date: 2022.10.26 16:49:10 -05'00' Matthew Allen Date JEANNE ECKHART Date: 2022.10.27 13:42:33 -05'00' Digitally signed by JEANNE ECKHART Jeanne Eckhart (acting) Date 6ENFORM-019-R8.2 (02/12/2020) 1 Section I - INTRODUCTION Northcote Cleveland, LLC/ Osage B Lease Inspection Date 09/16/2022 PURPOSE OF THE INSPECTION EPA Region 6 inspector Matthew Allen arrived at the Northcote Cleveland, LLC, Osage B Lease (EPA ID No. OKU000856), at 10:15 AM on 09/16/2022 for an announced inspection. This was a follow up inspection, the original spill inspection was conducted by EPA Inspector, Matthew Allen on 09/03/2022 in response to a spill notification (NRC# 1346621) received from Bureau of Indian Affairs (BIA), Osage Agency, inspector, Jeff McGuire. The inspection was conducted by the authority of the Clean Water Act to determine compliance with Environmental Protection Agency (EPA) regulations. There were no other federal, tribal, state, or local agency representatives present at the time of the inspection. FACILITY DESCRIPTION EPA conducted a follow up inspection on the Northcote Cleveland, LLC, Osage B Lease. The spill originated from a 2-inch diameter poly production flowline which transported produced water (oil and saltwater) from the producing well to the oil separation/storage facility (tank battery). The Osage B Lease was located north of New Prue Road, east of the confluence of Mud Creek into Keystone Lake, in Osage County, Oklahoma. Section II - OBSERVATIONS See Appendix 1 (photo log) which is attached to this narrative report for additional visual, descriptive and location information for the photos referenced in observations section below. At the release point, I observed a ditch/trench where the repaired flowline was being buried to prevent recurrence of the spill event, see photo No. 1. I observed the flowpath from the release point to the point of entry (POE), the flowpath had been disturbed by heavy equipment during other cleanup activities, but residual salt was visible on the surface of the soil and the flowpath had not been cleaned or remediated at the time of the inspection (see photo No. 2) I observed significant soil and rock fill into the main channel of the impacted tributary this soil fill was a result of the banks being pulled into the main channel of the tributary. I also observed oil-stained soil and rocks present in the "fill" material (photo's No. 3, 4, 6, 7, 8, 9, 11, 17, 18). I observed a row of oil-stained rocks and soil which had been removed from the tributary and piled approximately 15 feet south of tributary. (See photo No. 10). I observed a small section of the impacted tributary where oil staining and residual salt were present, evidence that flushing activities had not been conducted, or inadequate flushing had occurred. (Photos No. 12, 13, 15) 2 Northcote Cleveland, LLC/ Osage B Lease Inspection Date 09/16/2022 I observed the location of the most upstream temporary containment dam. At the time of the inspection, the dam had been partially removed, see photo No 14. As the inspection continued downstream, I observed additional areas where the banks of the tributary were pulled into the main channel resulting in contaminated soil and rocks partially filling the channel. (Photos No. 17 and 18). I observed two areas where the original main channel of the tributary had been filled in and a new channel had been dug. See photos No. 19 and No. 20 for additional description and location information. I observed multiple locations where soil was dug from the banks of the tributary and placed in the bed of the tributary to cover oil-stained areas. Evidence of these observations can be seen in photos No. 21, 22, 23, 24, 25, 26, and 27. I observed a final area along the impacted tributary where "clean B" industrial absorbent had been applied to oil and oil stains at the final pool of water along the tributary. See photo No. 28. I observed oil-stained rocks along the base of New Prue Road as the road crossed Mud Creek/Keystone Lake. There was much less staining present than during the previous two inspections. I did observe a film on the water, but it was not oil sheen. See photo's No. 29, 30, and 31. I observed a large section of shoreline along Mud Creek/Keystone Lake which had previously been impacted with oil and oil-staining. At the time of the inspection, the area was clean with no evidence of oil or oil stains. See photo No. 32. Section III - AREAS OF CONCERN There were multiple areas along the impacted tributary where oil staining and salt crystals present in the main channel indicated inadequate flushing operations to remove contamination from the impacted tributary. Additional clean up should occur to remove the residual salt and oil staining. Much of the tributary was "filled" with soil and rocks which was pulled in from the banks. Some of this fill material itself was contaminated with oil and brine. The fill material is covering areas where residual salt and oil are still present in the main channel of the tributary. The fill material should be removed from the main channel, and the residual salt and oil stains should be removed from the impacted tributary. 3 Section IV - FOLLOW UP Northcote Cleveland, LLC/ Osage B Lease Inspection Date 09/16/2022 EPA inspector Matthew Allen conducted a follow-up call with Cody Mather 09/22/2022 at 11:21 AM. The call lasted 15 minutes. I voiced my areas of concern from the inspection listed, Mr. Mather stated much of the fill was a result of efforts to remove buried and partially buried, abandoned flowlines along the impacted tributary. Mr. Mather stated he had been on contact with the landowner and was working to address their concerns during the clean-up effort. Mr. Mather stated there was a meeting between himself and the landowner, which was planned to occur the week of September 26, I requested to be informed and invited to that meeting, but never heard back from Mr. Mather. EPA will continue to perform follow-up inspections at the facility until satisfactory results are observed. Section V - LIST OF APPENDICES Appendix 1 - Photo Log - 32 photos taken 09/16/2022 4 Northcote Cleveland LLC/ Osage B Lease (CWA) Inspection Date: 09/16/2022 Appendix 1 Photograph Log 32 Photos UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 1 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0767 Orientation: S Date of Photo: 09/16/2022 Time of Photo: 10:19 AM Latitude: 36.259597 Longitude: -96.225672 Photographer: Matthew Allen Description: This was the release point of the spill. A trench had been dug to bury the repaired flowline to prevent recurrence of the spill. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 2 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0768 Orientation: S Date of Photo: 09/16/2022 Time of Photo: 10:22 AM Latitude: 36.259467 Longitude: -96.225801 Photographer: Matthew Allen Description: This was the flowpath of the spill, the dirt had been disturbed by equipment moving around the area but the flowpath had not yet been cleaned or remediated at the time of inspection. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 3 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0771 Orientation: SW Date of Photo: 09/16/2022 Time of Photo: 10:26 AM Latitude: 36.259401 Longitude: -96.226191 Photographer: Matthew Allen Description: This was the point of entry (POE) into the impacted tributary. The main channel had been filled with soil. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 4 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0772 Orientation: SW Date of Photo: 09/16/2022 Time of Photo: 10:26 AM Latitude: 36.259401 Longitude: -96.226191 Photographer: Matthew Allen Description: This was a view looking across the POE with a downstream view, the main channel had been filled with soil and the banks had been reshaped with heavy equipment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 5 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0773 Orientation: E Date of Photo: 09/16/2022 Time of Photo: 10:26 AM Latitude: 36.259401 Longitude: -96.226191 Photographer: Matthew Allen Description: This was a view from the POE looking upstream to an area not impacted by the spill. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 6 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0774 Orientation: SW Date of Photo: 09/16/2022 Time of Photo: 10:31 AM Latitude: 36.259367 Longitude: -96.226388 Photographer: Matthew Allen Description: This was a view of the altered and filled channel of the impacted tributary, approximately 150 feet downstream from the POE. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 7 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0775 Orientation: SW Date of Photo: 09/16/2022 Time of Photo: 10:33 AM Latitude: 36.259580 Longitude: -96.226488 Photographer: Matthew Allen Description: This was the impacted tributary showing soil and rock fill in the main channel of the tributary. Oil-stained rocks were still present in the tributary. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 8 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0776 Orientation: n/a Date of Photo: 09/16/2022 Time of Photo: 10:35 AM Latitude: 36.259640 Longitude: -96.226812 Photographer: Matthew Allen Description: This was a photo of oil-stained rocks and soil in the main channel of the impacted tributary. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 9 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0777 Orientation: SW Date of Photo: 09/16/2022 Time of Photo: 10:36 AM Latitude: 36.259783 Longitude: -96.226893 Photographer: Matthew Allen Description: This was a photo along a section of the impacted tributary showing soil and rock fill in the main channel. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 10 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0778 Orientation: SW Date of Photo: 09/16/2022 Time of Photo: 10:37 Latitude: 36.259783 Longitude: -96.226893 Photographer: Matthew Allen Description: This was a photo showing impacted soil and rocks which had been removed from the channel and banks of the impacted tributary. The soil and rocks were in a row approximately 15 feet south of the tributary. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 11 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0779 Orientation: n/a Date of Photo: 09/16/2022 Time of Photo: 10:38 AM Latitude: 36.260011 Longitude: -96.227187 Photographer: Matthew Allen Description: This was a photo of oil impacted soil and rock in the main channel of the tributary. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 12 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0780 Orientation: SW Date of Photo: 09/16/2022 Time of Photo: 10:40 AM Latitude: 36.260173 Longitude: -96.227318 Photographer: Matthew Allen Description: This was an area of the impacted tributary which had not been impacted by the soil fill. This section of the tributary had not been flushed to remove residual brine and oil stains were still present along the channel. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 13 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0781 Orientation: SW Date of Photo: 09/16/2022 Time of Photo: 10:41 AM Latitude: 36.260138 Longitude: -96.227606 Photographer: Matthew Allen Description: This was a photo of 2 rows of rocks placed in/across the main channel of the impacted tributary. Oil stains and residual brine impacts were captured in the photo along the area between the two rows of rocks. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 14 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0782 Orientation: N Date of Photo: 09/16/2022 Time of Photo: 10:42 AM Latitude: 36.260138 Longitude: -96.277606 Photographer: Matthew Allen Description: This was the location of the most upstream temporary containment dam. The dam had been partially removed at the time of the inspection. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 15 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0783 Orientation: SW Date of Photo: 09/16/2022 Time of Photo: 10:44 AM Latitude: 36.260138 Longitude: -96.227606 Photographer: Matthew Allen Description: This was a closeup view of the oil stains and residual brine impacts from photo No. 13. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 16 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0784 Orientation: S Date of Photo: 09/16/2022 Time of Photo: 10:45 AM Latitude: 36.260156 Longitude: -96.227791 Photographer: Matthew Allen Description: This was an area along the impacted tributary where the banks had not been altered during cleanup activities. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 17 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0785 Orientation: SW Date of Photo: 09/16/2022 Time of Photo: 10:46 AM Latitude: 36.260156 Longitude: -96.227791 Photographer: Matthew Allen Description: This was an area where the banks of the tributary had been pulled into the main channel. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 18 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0787 Orientation: S Date of Photo: 09/16/2022 Time of Photo: 10:49 AM Latitude: 36.260427 Longitude: -96.228432 Photographer: Matthew Allen Description: This was a photo of oil-stained rocks and soil filling the bed of the impacted tributary. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 19 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0788 Orientation: S Date of Photo: 09/16/2022 Time of Photo: 10:52 AM Latitude: 36.261184 Longitude: -96.229429 Photographer: Matthew Allen Description: This was an area where the stream had been filled with dirt and a new channel was dug along the north edge of the fill. The main channel was moved to the north by the operator to provide better access to a nearby oil well location. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 20 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0789 Orientation: S Date of Photo: 09/16/2022 Time of Photo: 10:54 AM Latitude: 36.261469 Longitude: -96.229938 Photographer: Matthew Allen Description: This was an area along a sharp bend in the tributary where the original oil and brine impacted channel was buried and a new channel was dug approximately 10 feet from the original channel. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 21 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0790 Orientation: SW Date of Photo: 09/16/2022 Time of Photo: 10:56 AM Latitude: 36.261689 Longitude: -96.229998 Photographer: Matthew Allen Description: This was an area where oil-stained rocks were still present in the channel. Dirt had been removed from the south bank of the tributary and placed in the channel to cover additional oil staining on the rock bed of the tributary. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 22 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0791 Orientation: S Date of Photo: 09/16/2022 Time of Photo: 10:57 Latitude: 36.261772 Longitude: -96.230206 Photographer: Matthew Allen Description: This was an area where dirt was removed from the bank of the tributary and placed in the bed of the tributary to cover oil-stained rock. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 23 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0792 Orientation: SW Date of Photo: 09/16/2022 Time of Photo: 10:59 AM Latitude: 36.261874 Longitude: -96.230564 Photographer: Matthew Allen Description: This was an overview of an area where dirt was removed from the banks and placed in the bed to cover oil stains. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 24 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0793 Orientation: SW Date of Photo: 09/16/2022 Time of Photo: 11:01 AM Latitude: 36.261913 Longitude: -96.230622 Photographer: Matthew Allen Description: This was a closeup view of the dirt covering oil stains along the bed of the tributary. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 25 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0794 Orientation: SE Date of Photo: 09/16/2022 Time of Photo: 11:02 AM Latitude: 36.261913 Longitude: -96.230622 Photographer: Matthew Allen Description: This is a portion of the bank where dirt was removed, then placed into the tributary bed to cover the remaining oil stains. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 26 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0795 Orientation: NE Date of Photo: 09/16/2022 Time of Photo: 11:04 AM Latitude: 36.262381 Longitude: -96.231289 Photographer: Matthew Allen Description: This was an area where dirt was pulled from the banks and placed in the bed to cover the oil-stained bed of the tributary. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 27 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0796 Orientation: SW Date of Photo: 09/16/2022 Time of Photo: 11:04 AM Latitude: 36.262381 Longitude: -96.231289 Photographer: Matthew Allen Description: This was a photo where soil was removed from the banks and placed in the bed to cover oil staining. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 28 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0797 Orientation: S Date of Photo: 09/16/2022 Time of Photo: 11:08 AM Latitude: 36.262091 Longitude: -96.232319 Photographer: Matthew Allen Description: This was an area along the impacted tributary where "clean B" industrial absorbent had been applied to oil and oil stains. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 29 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0798 Orientation: n/a Date of Photo: 09/16/2022 Time of Photo: 11:40 AM Latitude: 36.258157 Longitude: -96.232319 Photographer: Matthew Allen Description: This was the "rip rap" along New Prue Road, there was some oil staining present on the rocks but much less staining than during the two previous inspections. The film on the water was not oil sheen, when disturbed, the film remained fractured, evidence that it was not oil. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 30 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0799 Orientation: n/a Date of Photo: 09/16/2022 Time of Photo: 11:41 AM Latitude: 36.258141 Longitude: -96.232569 Photographer: Matthew Allen Description: This was oil-stained rip rap along New Prue Road. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 31 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0800 Orientation: W Date of Photo: 09/16/2022 Time of Photo: 11:43 AM Latitude: 36.258130 Longitude: -96.232778 Photographer: Matthew Allen Description: This was oil-stained rocks along the base of New Prue Road. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 32 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0801 Orientation: NW Date of Photo: 09/16/2022 Time of Photo: 11:44 AM Latitude: 36.258165 Longitude: -96.233004 Photographer: Matthew Allen Description: This was an area of shoreline which had obvious oil and oil staining during previous inspections. At the time of this inspection, the area was clean and free of oil and oil stains.