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Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 04/17/2025 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: C12: Arkansas Oil, LLC Midway Smackover Unit Tract #17 Tank Battery From Lewisville (Baker Community), at State Hwy 82 East, left on State Hwy 29, right on Lafayette CR 25, and then right onto an oilfield lease road at 33.459617, -93.582800. Lewisville, AR 71845 Hwy 25 1124 Lowerville, AR 71545 Lafayette County 501-772-3456 Paul Appel (832-628-3016) Person Responsible for Operation Robert Thomasson, Representative / robert@standardgas.org FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: N/A ARU002304 N/A 211111 1311 Personnel participating in inspection: Kerri McCabe (lead) EPA / Region 6 ECDW Michael Blaha EPA / Region 6 ECDW Uma Lad EPA / Region 6 ECDW Inspector / Enforcement Officer Inspector / Enforcement Officer Inspector / Enforcement Officer EPA Lead Inspector Signature/Date Supervisor Signature/Date Kerri McCabe Jeanne Eckhart 6ENFORM-019-R8.2 (02/12/2020) 1 Date Date Section I - INTRODUCTION C12: Arkansas Oil, LLC / MSU Tract #17 Tank Battery (ARU002304 / CWA) Inspection Date 04/17/2025 PURPOSE OF THE INSPECTION EPA Region 6 inspectors Kerri McCabe (lead), Michael Blaha, and Uma Lad arrived at the C12: Arkansas Oil, LLC / Midway Smackover Unit Tract #17 Tank Battery ("facility") located from State Highway 82 East, left on State Highway 29, right on Lafayette County Road 25, and then right onto an oilfield lease road at 33.459617, -93.582800 in Lewisville (Baker Community), Lafayette County, Arkansas; at 1110 on 04/17/2025 for an unannounced inspection. Mr. Michael Pearson represented the facility 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 C12: Arkansas Oil, LLC / Midway Smackover Unit Tract #17 Tank Battery facility, which contains four (4) tank batteries with a total of ten (10) tanks that include storage, separation, and free water knock out (FWKO) for crude oil and saltwater processing and storage. Map 1. Aerial imagery (Google Earth dated 10/30/2023) of the C12: Arkansas Oil, LLC / Midway Smackover Unit Tract #17 Tank Battery facility. 2 C12: Arkansas Oil, LLC / MSU Tract #17 Tank Battery (ARU002304 / CWA) Inspection Date 04/17/2025 Section II - OBSERVATIONS I observed the facility signage, secondary containment, pipes and valves, storage tanks, and separators/treaters; see Appendix 1 (Photographs Log), Photos No. 1 and No. 2. For additional GPS location and photo metadata, see Appendix 1. I observed a tank battery with two (2) saltwater storage tanks and a pump, a drainpipe with no shutoff valve or cap, and an erosion gully through the berm; see Photos No. 3 through No. 5. I observed a tank battery with three (3) separators and numerous flowlines, see Photo No. 6. I observed the upstream and downstream drainage area for the facility, see Photos No. 7, No. 8, and No. 12. I observed a tank battery with two (2) crude oil storage tanks, one (1) gun barrel, and one FWKO tank; a transfer line without a catchment bucket, loose crude oil on the ground outside secondary containment, and a drainpipe without a shutoff valve or cap; see Photos No. 9 through No. 11. I observed a tank battery with one (1) crude oil storage tank and a drainpipe without a shutoff valve or cap, see Photos No. 13 and No. 14. Section III - AREAS OF CONCERN A closing conference was held with Mr. Micheal Pearson with C12: Arkansas Oil, LLC after the inspection. Areas of concern at the time of the inspection include the following: Drainpipes for tank batteries that did not have shutoff valves or caps (Photos No. 4, No. 11, and No. 14), An erosion gully in the berm for the saltwater storage tank battery (Photo No. 5 and No. 7), Loose crude oil on the ground outside the crude oil storage tank battery (Photo No. 9), No catchment bucket for the transfer line outside secondary containment for the crude oil storage tank battery (Photo No. 9), and Evidence of a historic saltwater release that has not been properly remediated (Photo No. 12). 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 - Photograph Log - 14 photos taken 04/17/2025. 3 C12: Arkansas Oil, LLC / MSU Tract #17 Tank Battery (ARU002304 / CWA) Inspection Date 04/17/2025 Appendix 1 Photograph Log 14 Photos UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: From Lewisville (Baker Community), at State Hwy 82 East, left on State Hwy 29, right on Lafayette CR 25, and then right onto an oilfield lease road at 33.459617, -93.582800. City: Lewisville County/Parish: Lafayette State: Arkansas Photo File Name: 100-0826 Orientation: 41 NE Date of Photo: 04/17/2025 Time of Photo: 1115 Latitude: 33.459617 Longitude: -93.582800 Photographer: Kerri McCabe Description: Looking NE, this photo shows the signage for the C12: Arkansas Oil, LLC - Midway Smackover Unit Tract #17 Tank Battery ("facility"). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: From Lewisville (Baker Community), at State Hwy 82 East, left on State Hwy 29, right on Lafayette CR 25, and then right onto an oilfield lease road at 33.459617, -93.582800. City: Lewisville County/Parish: Lafayette State: Arkansas Photo File Name: 100-0827 Orientation: 69 ENE Date of Photo: 04/17/2025 Time of Photo: 1115 Latitude: 33.459633 Longitude: -93.582950 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 Lewisville (Baker Community), at State Hwy 82 East, left on State Hwy 29, right on Lafayette CR 25, and then right onto an oilfield lease road at 33.459617, -93.582800. City: Lewisville County/Parish: Lafayette State: Arkansas Photo File Name: 100-0828 Orientation: 350 N Date of Photo: 04/17/2025 Time of Photo: 1119 Latitude: 33.459850 Longitude: -93.582767 Photographer: Kerri McCabe Description: Looking N, this photo shows one of four tank batteries (saltwater storage and pump) observed at the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: From Lewisville (Baker Community), at State Hwy 82 East, left on State Hwy 29, right on Lafayette CR 25, and then right onto an oilfield lease road at 33.459617, -93.582800. City: Lewisville County/Parish: Lafayette State: Arkansas Photo File Name: 100-0829 Orientation: 347 NNW Date of Photo: 04/17/2025 Time of Photo: 1119 Latitude: 33.459850 Longitude: -93.582783 Photographer: Kerri McCabe Description: Looking NNW, this photo shows the drainpipe for the tank battery in Photo No. 3 without a shutoff valve or cap. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: From Lewisville (Baker Community), at State Hwy 82 East, left on State Hwy 29, right on Lafayette CR 25, and then right onto an oilfield lease road at 33.459617, -93.582800. City: Lewisville County/Parish: Lafayette State: Arkansas Photo File Name: 100-0830 Orientation: 336 NNW Date of Photo: 04/17/2025 Time of Photo: 1119 Latitude: 33.459867 Longitude: -93.582683 Photographer: Kerri McCabe Description: Looking NNW, this photo shows an erosion gully in the berm of the tank battery from Photo No. 3. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: From Lewisville (Baker Community), at State Hwy 82 East, left on State Hwy 29, right on Lafayette CR 25, and then right onto an oilfield lease road at 33.459617, -93.582800. City: Lewisville County/Parish: Lafayette State: Arkansas Photo File Name: 100-0831 Orientation: 133 SE Date of Photo: 04/17/2025 Time of Photo: 1120 Latitude: 33.459950 Longitude: -93.582350 Photographer: Kerri McCabe Description: Looking SE, this photo shows two of four tank batteries (separators) observed at the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: From Lewisville (Baker Community), at State Hwy 82 East, left on State Hwy 29, right on Lafayette CR 25, and then right onto an oilfield lease road at 33.459617, -93.582800. City: Lewisville County/Parish: Lafayette State: Arkansas Photo File Name: 100-0832 Orientation: 0 N Date of Photo: 04/17/2025 Time of Photo: 1121 Latitude: 33.459700 Longitude: -93.582500 Photographer: Kerri McCabe Description: Looking N, this photo shows the upstream drainage area from the tank battery in Photo No. 3. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: From Lewisville (Baker Community), at State Hwy 82 East, left on State Hwy 29, right on Lafayette CR 25, and then right onto an oilfield lease road at 33.459617, -93.582800. City: Lewisville County/Parish: Lafayette State: Arkansas Photo File Name: 100-0833 Orientation: 81 E Date of Photo: 04/17/2025 Time of Photo: 1121 Latitude: 33.459700 Longitude: -93.582500 Photographer: Kerri McCabe Description: Looking E, this photo shows the downstream drainage area from the tank battery in Photo No. 3. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 Location: From Lewisville (Baker Community), at State Hwy 82 East, left on State Hwy 29, right on Lafayette CR 25, and then right onto an oilfield lease road at 33.459617, -93.582800. City: Lewisville County/Parish: Lafayette State: Arkansas Photo File Name: 100-0837 Orientation: 31 NNE Date of Photo: 04/17/2025 Time of Photo: 1123 Latitude: 33.459483 Longitude: -93.582717 Photographer: Kerri McCabe Description: Looking NNE, this photo shows three of four tank batteries (crude oil storage) observed at the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 10 Location: From Lewisville (Baker Community), at State Hwy 82 East, left on State Hwy 29, right on Lafayette CR 25, and then right onto an oilfield lease road at 33.459617, -93.582800. City: Lewisville County/Parish: Lafayette State: Arkansas Photo File Name: 100-0834 Orientation: 326 NNW Date of Photo: 04/17/2025 Time of Photo: 1122 Latitude: 33.459617 Longitude: -93.582500 Photographer: Kerri McCabe Description: Looking NNW, this photo shows the backside of the tank battery from Photo No. 9. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 11 Location: From Lewisville (Baker Community), at State Hwy 82 East, left on State Hwy 29, right on Lafayette CR 25, and then right onto an oilfield lease road at 33.459617, -93.582800. City: Lewisville County/Parish: Lafayette State: Arkansas Photo File Name: 100-0835 Orientation: 191 S Date of Photo: 04/17/2025 Time of Photo: 1122 Latitude: 33.459633 Longitude: -93.582500 Photographer: Kerri McCabe Description: Looking S, this photo shows the drainpipe for the tank battery in Photo No. 9 without a shutoff valve or cap. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 12 Location: From Lewisville (Baker Community), at State Hwy 82 East, left on State Hwy 29, right on Lafayette CR 25, and then right onto an oilfield lease road at 33.459617, -93.582800. City: Lewisville County/Parish: Lafayette State: Arkansas Photo File Name: 100-0836 Orientation: 100 E Date of Photo: 04/17/2025 Time of Photo: 1122 Latitude: 33.459583 Longitude: -93.582367 Photographer: Kerri McCabe Description: Looking E, this photo shows an area downstream of the facility that appeared to be impacted by a historic saltwater kill. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 13 Location: From Lewisville (Baker Community), at State Hwy 82 East, left on State Hwy 29, right on Lafayette CR 25, and then right onto an oilfield lease road at 33.459617, -93.582800. City: Lewisville County/Parish: Lafayette State: Arkansas Photo File Name: 100-0838 Orientation: 112 ESE Date of Photo: 04/17/2025 Time of Photo: 1124 Latitude: 33.459483 Longitude: -93.582700 Photographer: Kerri McCabe Description: Looking ESE, this photo shows four of four tank batteries observed at the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 14 Location: From Lewisville (Baker Community), at State Hwy 82 East, left on State Hwy 29, right on Lafayette CR 25, and then right onto an oilfield lease road at 33.459617, -93.582800. City: Lewisville County/Parish: Lafayette State: Arkansas Photo File Name: 100-0839 Orientation: 8 N Date of Photo: 04/17/2025 Time of Photo: 1124 Latitude: 33.459350 Longitude: -93.582583 Photographer: Kerri McCabe Description: Looking N, this photo shows the drainpipe for the tank battery in Photo No. 13 without a shutoff valve or cap.