Document Ozaba0mqRZR4VooRKbZz2BgZv

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 04/15/2025 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: Enerco Operating Corporation Clark Tank Battery Off County Road 249 at 33.320769, -93.813836 Genoa, AR 71840 11535 East Ricks Circle Dallas, TX 75230 Miller County 870-953-0287 Terry Collum Field Supervisor terrycollum@enercooperating.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: N/A ARU002311 N/A 211111 1311 Personnel participating in inspection: Uma Lad EPA / Region 6 ECDW Kerri McCabe EPA / Region 6 ECDW Michael Blaha EPA / Region 6 ECDW Inspector / Enforcement Officer Inspector / Enforcement Officer Inspector / Enforcement Officer EPA Lead Inspector Signature/Date UMA LAD Uma Lad Digitally signed by UMA LAD Date: 2025.06.09 14:13:19 -05'00' Date Supervisor Signature/Date JEANNE ECKHART Date: 2025.06.10 14:34:19 -05'00' Digitally signed by JEANNE ECKHART Jeanne Eckhart Date 6ENFORM-019-R8.2 (02/12/2020) 1 Enerco Operating Corporation / Clark Tank Battery (ARU002311 / CWA) Inspection Date 04/15/2025 Section I - INTRODUCTION PURPOSE OF THE INSPECTION Environmental Protection Agency (EPA) Region 6 inspectors Uma Lad, Kerri McCabe, and Michael Blaha arrived at the Enerco Operating Corporation / Clark Tank Battery, located off County Road 249 at 33.320769, -93.813836, at 5:30 PM on 04/15/2025 for an unannounced 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 Enerco Operating Corporation / Clark Tank Battery, which consists of three (3) storage tanks. Section II - OBSERVATIONS I observed the facility and associated signage and secondary containment with storage tanks; see Appendix 1 (Photograph Log), Photo No. 1 and No. 2. For additional GPS location and photo metadata, see Appendix 1. I observed woody vegetation on the secondary containment berm, see Photo No. 1 and No. 2. I observed loose oil inside secondary containment, see Photo No. 3. I also observed two (2) tanks labeled "not in use" but did not include the date that they were no longer in use, see Photo No. 3. The third tank at the facility was missing both a "not in use" label and a date, see Photo No. 2. Section III - AREAS OF CONCERN No closing conference was held due to no personnel from Enerco Operating Corporation present during the inspection. The areas of concern include: the woody vegetation on the secondary containment berm, the loose oil inside secondary containment, and the tanks missing the "not in use" label with a date. The "not-in-use" tanks are subject to the SPCC rule unless the facility meets the requirements for a permanently closed tank. According to 112.2, a container or facility is permanently closed if "(1) all liquid and sludge has been removed from each container and connecting line; and (2) all connecting lines and piping have been disconnected from the container and blanked off, all valves (except ventilation valves) have been closed and locked, and conspicuous signs have been posted on each container stating that it is a permanently closed container and noting the date of closure." Section IV - FOLLOW UP Inspector will provide the completed inspection report to company representative(s). Section V - LIST OF APPENDICES Appendix 1 - Photograph Log* - 3 photos taken 04/15/2025. *The photos were captured in HEIC format and converted to JPG format for the purpose of drafting the Photograph Log. The original photos are retained with their metadata. 2 Enerco Operating Corporation / Clark Tank Battery (ARU002311 / CWA) Inspection Date 04/15/2025 Appendix 1 Photograph Log 3 Photos UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: Off County Road 249 at 33.320769, -93.813836 City: Genoa County/Parish: Miller State: AR Photo File Name: 20250415_223716714_iOS Orientation: North Date of Photo: 04/15/2025 Time of Photo: 5:37 PM Latitude: 33.320769 Longitude: -93.813836 Photographer: Uma Lad Description: Looking north, this photo shows the sign at the facility and loose oil inside secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: Off County Road 249 at 33.320769, -93.813836 City: Genoa County/Parish: Miller State: AR Photo File Name: 20250415_223242311_iOS Orientation: North Date of Photo: 04/15/2025 Time of Photo: 5:32 PM Latitude: 33.320769 Longitude: -93.813836 Photographer: Uma lad Description: Looking north, this photo shows an overview of the facility, with woody vegetation on the secondary containment berm. The tank on the far right of the photo is missing a "not in use" label and date. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: Off County Road 249 at 33.320769, -93.813836 City: Genoa County/Parish: Miller State: AR Photo File Name: 20250415_223302850_iOS Orientation: Northwest Date of Photo: 04/15/2025 Time of Photo: 5:33 PM Latitude: 33.320878 Longitude: -93.813758 Photographer: Uma Lad Description: Looking northwest, this photo shows loose oil inside secondary containment. The two (2) tanks marked "not in use" are missing dates and proper close out of tanks according to 112.2.