Document RN4dVO3gpxbYrXv5X080r46a

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) February 20, 2020 Water (CWA) NPDES - 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: Perdure Petroleum, LLC NBU 16 South Satellite 36.826056N, -96.734118W Shidler, Oklahoma 74652 12012 Wickchester Lane Houston, Texas 77079 Osage County 918-793-2881 Carl Thunem cthunem@perdurepetro.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: N/A OKU000881 N/A 211111 1311 Personnel participating in inspection: Kent W. Sanborn EPA Region 6 / 6ECDWE HSE Director Environmental Engineer EPA Lead Inspector Signature/Date Supervisor Signature/Date Kent W. Sanborn Digitally signed by Kent W. Sanborn DN: cn=Kent W. Sanborn, o, ou=6EN-WR, email=sanborn.kent@epa.gov, c=US Date: 2020.03.23 10:29:38 -05'00' Kent W. Sanborn GUY TIDMORE Digitally signed by GUY TIDMORE DN: c=US, o=U.S. Government, ou=Environmental Protection Agency, cn=GUY TIDMORE, 0.9.2342.19200300.100.1.1=68001003655426 Date: 2020.03.27 13:42:28 -05'00' Guy Tidmore Date 27 MAR 2020 Date 6ENFORM-020-R8.2 (02/12/2020) 1 Section I - INTRODUCTION Perdure Petroleum, LLC / NBU 16 Inspection Date: 02/20/2020 PURPOSE OF THE INSPECTION EPA Region 6 inspector Kent W. Sanborn arrived at the Perdure Petroleum, LLC NBU 16 Satellite Lease located west of Shidler, Oklahoma at about 3:00 pm on February 20, 2020 for an inspection. The inspection was initiated by a call received from the operator of a discharge. There were several company representatives at the site during the inspection. The discharge had reached the tributary of Beaver Creek located west of the area, which flows to Kaw Lake. Cleanup activity was underway with several trucks hauling water out of the tributary during the inspection. The inspection was conducted under the authority of Section 308 of the CWA. The scope of the inspection was to determine if the facility was in compliance with The Clean Water Act, including Section 301, and to identify and document discharges of produced wastewater (brine) to waters of the United States. FACILITY DESCRIPTION The discharge originated from an injection line near the tank battery known as NBU 16 Satellite. Section II - OBSERVATIONS I initially arrived at the Perdure Petroleum NBU 16 Satellite Lease at about 3 pm February 20, 2020. Photo 1 identified the lease as the NBU 16 Satellite Lease. The leak site shown in Photo 2 had been excavated and repaired. Photo 3 showed the direction the discharge followed to the tributary of Beaver Creek which flows to Kaw Lake. The discharge entered the tributary of Beaver Creek at the point shown in Photo 4. A boom to collect residual oil was present in the tributary. Photo 5 showed a view of the discharge point from the tributary entry point. The creek flowed northwest toward Beaver Creek and then towards Kaw Lake (Photo 6). With a calibrated YSI Pro 30 Conductivity Meter, the total dissolved solids (TDS) measurement at the point of entry to the tributary was 6,765 milligrams per liter (mg/L) (Photo 7). The tributary was tested farther downstream (Photo 8). The water was rust colored here with an oil sheen. An oil boom was also present. The TDS here was 17,185 mg/L (Photo (9). The tributary was being pumped out to a series of frac tanks (Photo 10). The tributary shown in Photo 11 near the pump had a TDS of 6,373 mg/L (Photo 12). A dam was constructed in the tributary as shown in Photo 13. TDS near the dam location was 1,239 mg/L (Photo 14). I observed some seepage past the dam was occurring and most of the brine, however, was contained by the dam. I took more downstream measurements northwest of the dam. Photo 15 showed the location of the sample point I took just northwest of the dam. TDS was 1,050 mg/L at this location (Photo 16). Photo 17 was another sample point farther downstream. TDS was 854 mg/L (Photo 18). The last measurement in the tributary was taken downstream at the point farthest from the discharge entry point to the tributary (Photo 19). I took a TDS measurement at that location that was 754 mg/L (Photo 20). A representative background sample of the tributary was measured in a small creek located at the point shown in Photo 21. The background tributary measured 542 mg/L (Photo 22). Photo 23 shows the series of frac tanks being used to store the contaminated creek water until it can be hauled away. 2 Perdure Petroleum, LLC / NBU 16 Inspection Date: 02/20/2020 Section III - AREAS OF CONCERN I observed elevated levels of TDS in the tributary of Beaver Creek due to a flow line leak near the facility tank battery. Remedial activities were underway during the inspection. Section IV - FOLLOW UP A follow up inspection will be conducted as needed. Section V - LIST OF APPENDICES Appendix 1 - Photo Log - 23 photos taken 2/20/2020. 3 Perdure Petroleum, LLC /NBU 16 Inspection Date: 02/20/2020 Appendix 1 Photographic Log (23 photos) UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Perdure Petroleum NBU 16 Satellite City: Shidler County: Osage State: Oklahoma Photo File Name: Photo 1 (DSC_0036) Orientation: South Date of Photo: 02/20/2020 Time of Photo: 3:49 pm Latitude: 36.826056N Longitude: -96.734118W Photographer: K.W. Sanborn Description: The discharge occurred on the southwest side of this facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Perdure Petroleum NBU 16 Satellite City: Shidler County: Osage State: Oklahoma Photo File Name: Photo 2 (DSC_0022) Orientation: Southeast Date of Photo: 02/20/2020 Time of Photo: 3:25 pm Latitude: 36.826056N Longitude: -96.734860W Photographer: K.W. Sanborn Description: The discharge occurred from a now repaired injection line. The line has been reburied. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Perdure Petroleum NBU 16 Satellite City: Shidler County: Osage State: Oklahoma Photo File Name: Photo 3 (DSC_0023) Orientation: East Date of Photo: 02/20/2020 Time of Photo: 3:25 pm Latitude: 36.826056N Longitude: -96.734118W Photographer: K.W. Sanborn Description: The brine ran west down the hill to the tributary of Beaver Creek. northwest. The tributary flowed UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Perdure Petroleum NBU 16 Satellite City: Shidler County: Osage State: Oklahoma Photo File Name: Photo 4 (DSC_0024) Orientation: South Date of Photo: 02/20/2020 Time of Photo: 3:27 pm Latitude: 36.826191N Longitude: -96.734860W Photographer: K.W. Sanborn Description: The brine entered the tributary of Beaver Creek here. small amount of oil. A small boom was present to catch a UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Perdure Petroleum NBU 16 Satellite City: Shidler County: Osage State: Oklahoma Photo File Name: Photo 5 (DSC_0025) Orientation: East Date of Photo: 02/20/2020 Time of Photo: 3:27 pm Latitude: 36.826191N Longitude: -96.734860W Photographer: K.W. Sanborn Description: Reverse angle photo from the tributary entry point to the discharge point at the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Perdure Petroleum NBU 16 Satellite City: Shidler County: Osage State: Oklahoma Photo File Name: Photo 6 (DSC_0028) Orientation: Northwest Date of Photo: 02/20/2020 Time of Photo: 3:29 pm Latitude: 36.826191N Longitude: -96.734860W Photographer: K.W. Sanborn Description: This was the view of the tributary of Beaver Creek flowing northwest from the discharge entry point. I observed a defined channel. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Perdure Petroleum NBU 16 Satellite City: Shidler County: Osage State: Oklahoma Photo File Name: Photo 7 (DSC_0030) Orientation: Northwest Date of Photo: 02/20/2020 Time of Photo: 3:30 pm Latitude: 36.826191N Longitude: -96.734860W Photographer: K.W. Sanborn Description: With a calibrated YSI Pro 30 conductivity meter, total dissolved solids (TDS) of the tributary of Beaver Creek at the point of entry was 6,765 milligrams per liter (mg/l). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Perdure Petroleum NBU 16 Satellite City: Shidler County: Osage State: Oklahoma Photo File Name: Photo 8 (DSC_0031) Orientation: East Date of Photo: 02/20/2020 Time of Photo: 3:33 pm Latitude: 36.8271N Longitude: -96.7349 Photographer: K.W. Sanborn Description: This showed a location just northwest of the brine entry point. A boom was present to catch some residual oil. I observed only a sheen was seen along with the brine. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 Perdure Petroleum NBU 16 Satellite City: Shidler County: Osage State: Oklahoma Photo File Name: Photo 9 (DSC_0032) Orientation: East Date of Photo: 02/20/2020 Time of Photo: 3:34 pm Latitude: 36.8271N Longitude: -96.7349W Photographer: K.W. Sanborn Description: The TDS at the tributary of Beaver Creek shown in Photo 8 was 17,175 mg/L. flowed northwest during the inspection. The tributary UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 10 Perdure Petroleum NBU 16 Satellite City: Shidler County: Osage State: Oklahoma Photo File Name: Photo 10 (DSC_0007) Orientation: Northwest Date of Photo: 02/20/2020 Time of Photo: 2:59 pm Latitude: 36.827687N Longitude: -96.735710W Photographer: K.W. Sanborn Description: The operator was pumping out a section of the tributary downstream of the discharge point. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 11 Perdure Petroleum NBU 16 Satellite City: Shidler County: Osage State: Oklahoma Photo File Name: Photo 11 (DSC_0011) Orientation: Southeast Date of Photo: 02/20/2020 Time of Photo: 3:00 pm Latitude: 36.827687N Longitude: -96.735710W Photographer: K.W. Sanborn Description: The tributary of Beaver Creek shown here was near the pumping site shown in Photo 10. The point of discharge at the facility was shown in the far background. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 12 Perdure Petroleum NBU 16 Satellite City: Shidler County: Osage State: Oklahoma Photo File Name: Photo 12 (DSC_0016) Orientation: South Date of Photo: 02/20/2020 Time of Photo: 3:00 pm Latitude: 36.827687N Longitude: -96.735710W Photographer: K.W. Sanborn Description: TDS at the tributary shown in Photo 11 was 6,373 mg/L. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 13 Perdure Petroleum NBU 16 Satellite City: Shidler County: Osage State: Oklahoma Photo File Name: Photo 13 (DSC_0017) Orientation: West Date of Photo: 02/20/2020 Time of Photo: 3:12 pm Latitude: 36.827569N Longitude: -96.736215W Photographer: K.W. Sanborn Description: This was the last dam downstream of the discharge constructed by the operator. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 14 Perdure Petroleum NBU 16 Satellite City: Shidler County: Osage State: Oklahoma Photo File Name: Photo 14 (DSC_0018) Orientation: South Date of Photo: 02/20/2020 Time of Photo: 3:12 pm Latitude: 36.827569N Longitude: -96.736215W Photographer: K.W. Sanborn Description: TDS near the last dam was 1,239 mg/L. A slight flow seeping past the dam was observed. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 15 Perdure Petroleum NBU 16 Satellite City: Shidler County: Osage State: Oklahoma Photo File Name: Photo 15 (DSC_0020) Orientation: Southeast Date of Photo: 02/20/2020 Time of Photo: 3:16 pm Latitude: 36.828031N Longitude: -96.736497W Photographer: K.W. Sanborn Description: This was a view of the tributary of Beaver Creek downstream of the dam, which flows towards Beaver Creek and then Kaw Lake. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 16 Perdure Petroleum NBU 16 Satellite City: Shidler County: Osage State: Oklahoma Photo File Name: Photo 16 (DSC_0021) Orientation: South Date of Photo: 02/20/2020 Time of Photo: 3:17 pm Latitude: 36.828031N Longitude: -96.736497W Photographer: K.W. Sanborn Description: TDS of the tributary at the point shown in Photo 15 was 1,050 mg/L. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 17 Perdure Petroleum NBU 16 Satellite City: Shidler County: Osage State: Oklahoma Photo File Name: Photo 17 (DSC_0038) Orientation: Northeast Date of Photo: 02/20/2020 Time of Photo: 4:22 pm Latitude: 36.83168N Longitude: -96.741498W Photographer: K.W. Sanborn Description: The tributary shown here was northwest and downstream of the location shown in Photo 15. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 18 Perdure Petroleum NBU 16 Satellite City: Shidler County: Osage State: Oklahoma Photo File Name: Photo 18 (DSC_0037) Orientation: Northeast Date of Photo: 02/20/2020 Time of Photo: 4:22 pm Latitude: 36.83168N Longitude: -96.741498W Photographer: K.W. Sanborn Description: TDS of the tributary shown in Photo 17 was 854 mg/L. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 19 Perdure Petroleum NBU 16 Satellite City: Shidler County: Osage State: Oklahoma Photo File Name: Photo 19 (DSC_0042) Orientation: Southeast Date of Photo: 02/20/2020 Time of Photo: 4:33 pm Latitude: 36.833467N Longitude: -96.743212W Photographer: K.W. Sanborn Description: This was the farthest point measured downstream (northwest) of the discharge entry point. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 20 Perdure Petroleum NBU 16 Satellite City: Shidler County: Osage State: Oklahoma Photo File Name: Photo 20 (DSC_0043) Orientation: South Date of Photo: 02/20/2020 Time of Photo: 4:33 pm Latitude: 36.833467N Longitude: -96.743212W Photographer: K.W. Sanborn Description: TDS of the tributary of Beaver Creek shown in Photo 19 was 754 mg/L. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 21 Perdure Petroleum NBU 16 Satellite City: Shidler County: Osage State: Oklahoma Photo File Name: Photo 21 (DSC_0039) Orientation: Southeast Date of Photo: 02/20/2020 Time of Photo: 4:26 pm Latitude: 36.8299N Longitude: -96.7428W Photographer: K.W. Sanborn Description: This was another tributary in the nearby area measured for background TDS readings. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 22 Perdure Petroleum NBU 16 Satellite City: Shidler County: Osage State: Oklahoma Photo File Name: Photo 22 (DSC_0041) Orientation: Southeast Date of Photo: 02/20/2020 Time of Photo: 4:27 pm Latitude: 36.8299N Longitude: -96.7428W Photographer: K.W. Sanborn Description: TDS of the tributary water considered background for the area was 542 mg/L. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 23 Perdure Petroleum NBU 16 Satellite City: Shidler County: Osage State: Oklahoma Photo File Name: Photo 23 (DSC_0010) Orientation: Northwest Date of Photo: 02/20/2020 Time of Photo: 2:59 pm Latitude: 36.827687N Longitude: 735710W Photographer: K.W. Sanborn Description: Frac tanks were being used to store brine contaminated fluids until trucks could remove them from the location.