Document V3ndrMmnvVebD5zeer12wb36g

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 10/08/2024 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: Eubanks, James and Mike (J&M) Patterson 2 and 3 SWD Tank Battery From Highway 7B in Sandy Land, then left onto Union Co Rd 459, off an oil lease road at 33.341667, -92.712500 Smackover, AR, 71762 615 Broadway Smackover, AR, 71762 Union County 870-725-2907 James Eubanks Person Responsible for Operation rick@jrmorgancpa.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: N/A ARU002253 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 Kerri McCabe Digitally signed by KERRI MCCABE Date: 2024.10.22 11:26:48 -05'00' Date JEANNE ECKHART Date: 2024.10.29 15:44:17 -05'00' Digitally signed by JEANNE ECKHART Jeanne Eckhart Date 6ENFORM-019-R8.2 (02/12/2020) 1 Eubanks, James and Mike (J&M) / Patterson 2 and 3 SWD Tank Battery (ARU002253 / CWA) Inspection Date 10/08/2024 Section I - INTRODUCTION PURPOSE OF THE INSPECTION EPA Region 6 inspectors Kerri McCabe (lead), Michael Blaha, and Uma Lad arrived at the Eubanks, James and Mike (J&M) / Patterson 2 and 3 SWD Tank Battery, located from Highway 7B in Sandy Land, then left onto Union Co Rd 459, off an oil lease road at 33.341667, -92.712500; at 1130 on 10/08/2024 for an unannounced inspection. No facility representatives were present 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 Eubanks, James and Mike (J&M) / Patterson 2 and 3 SWD Tank Battery, which contained one (1) tank battery, six (6) storage/separator tanks for crude oil and saltwater, and two (2) Saltwater Disposal (SWD) wells. Map 1. Aerial imagery (Google Earth dated 09/26/2023) of the James and Mike (J&M) Eubanks - Patterson 2 and 3 SWD Tank Battery. 2 Eubanks, James and Mike (J&M) / Patterson 2 and 3 SWD Tank Battery (ARU002253 / CWA) Inspection Date 10/08/2024 Section II - OBSERVATIONS I observed the Eubanks, James and Mike (J&M) / Patterson 2 and 3 SWD Tank Battery and associated secondary containment, storage tanks, and saltwater disposal (SWD) wells; see Appendix 1 (Photographs Log), see Photo No. 1. For additional GPS location and photo metadata, see Appendix 1. I observed production/transfer lines outside secondary containment without catchment buckets, see Photo No. 2 and No. 3. I observed loose oil around tanks and active leaks of crude oil from tanks/valves inside secondary containment, see Photo No. 4, No. 11, No. 12, and No. 19. I observed the drainpipe, cap, and flowpath from the secondary containment; see Photo No. 5 through No. 9. I observed active leaks of saltwater, saltwater staining, salt crystals, and saltwater corrosion of a storage tank inside secondary containment; see Photo No. 10, and No. 13 through No. 18. I observed one of two SWD wells located in the area, see Photo No. 20. Section III - AREAS OF CONCERN No closing conference was held due to no personnel with James and Mike (J&M) Eubanks being present during the inspection. Areas of concern at the time of the inspection include the following: No signage at the tank battery, Transfer pipes and residual oil staining outside secondary containment without catchment buckets, Loose oil and active leaks of crude oil inside the secondary containment for the facility, Minor leak of crude oil from the cap on the drainpipe for secondary containment, and Active leaks of saltwater, saltwater staining, salt crystals, and saltwater corrosion inside secondary containment. 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 - 20 photos taken 10/08/2024. 3 J & M Eubanks / Patterson 2 and 3 SWD Tank Battery (CWA / ARU002253) Inspection Date 10/08/2024 Appendix 1 Photograph Log 20 Photos Note: date/time stamp programmed incorrectly; metadata provided with field notes UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: J & M Eubanks - Patterson 2 and 3 SWD Tank Battery in Sandy Land at 33.341667, -92.712500. City: Smackover County/Parish: Union State: Arkansas Photo File Name: P909-0065 Orientation: N Date of Photo: 10/08/2024 Time of Photo: 1145 Latitude: 33.341992 Longitude: -92.712389 Photographer: Kerri McCabe Description: Looking N, this photo shows an overview of the Patterson 2 and 3 SWD Tank Battery; no signage onsite. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: J & M Eubanks - Patterson 2 and 3 SWD Tank Battery in Sandy Land at 33.341667, -92.712500. City: Smackover County/Parish: Union State: Arkansas Photo File Name: P909-0066 Orientation: NW Date of Photo: 10/08/2024 Time of Photo: 1145 Latitude: 33.342021 Longitude: -92.712368 Photographer: Kerri McCabe Description: Looking NW, this photo shows a production/transfer pipe without a catch bucket. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: J & M Eubanks - Patterson 2 and 3 SWD Tank Battery in Sandy Land at 33.341667, -92.712500. City: Smackover County/Parish: Union State: Arkansas Photo File Name: P909-0067 Orientation: NW Date of Photo: 10/08/2024 Time of Photo: 1146 Latitude: 33.342107 Longitude: -92.712322 Photographer: Kerri McCabe Description: Looking NW, this photo shows a second production/transfer pipe without a catch bucket and loose oil outside of secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: J & M Eubanks - Patterson 2 and 3 SWD Tank Battery in Sandy Land at 33.341667, -92.712500. City: Smackover County/Parish: Union State: Arkansas Photo File Name: P909-0068 Orientation: NW Date of Photo: 10/08/2024 Time of Photo: 1146 Latitude: 33.342073 Longitude: -92.712376 Photographer: Kerri McCabe Description: Looking NW, this photo shows loose oil inside the secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: J & M Eubanks - Patterson 2 and 3 SWD Tank Battery in Sandy Land at 33.341667, -92.712500. City: Smackover County/Parish: Union State: Arkansas Photo File Name: P909-0069 Orientation: NW Date of Photo: 10/08/2024 Time of Photo: 1146 Latitude: 33.342141 Longitude: -92.712383 Photographer: Kerri McCabe Description: Looking NW, this photo shows produced water inside the secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: J & M Eubanks - Patterson 2 and 3 SWD Tank Battery in Sandy Land at 33.341667, -92.712500. City: Smackover County/Parish: Union State: Arkansas Photo File Name: P909-0070 Orientation: NW Date of Photo: 10/08/2024 Time of Photo: 1146 Latitude: 33.342141 Longitude: -92.712383 Photographer: Kerri McCabe Description: Looking NW, this photo shows produced water collected at the drainpipe for secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: J & M Eubanks - Patterson 2 and 3 SWD Tank Battery in Sandy Land at 33.341667, -92.712500. City: Smackover County/Parish: Union State: Arkansas Photo File Name: P909-0071 Orientation: W Date of Photo: 10/08/2024 Time of Photo: 1146 Latitude: 33.342193 Longitude: -92.712421 Photographer: Kerri McCabe Description: Looking W, this photo shows the cap on the drainpipe for secondary containment; minor leak of crude oil was noted at the drainpipe. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: J & M Eubanks - Patterson 2 and 3 SWD Tank Battery in Sandy Land at 33.341667, -92.712500. City: Smackover County/Parish: Union State: Arkansas Photo File Name: P909-0072 Orientation: SE Date of Photo: 10/08/2024 Time of Photo: 1147 Latitude: 33.342193 Longitude: -92.712421 Photographer: Kerri McCabe Description: Looking SE, this photo shows the flowpath from the drainpipe for secondary containment leading to Holmes Creek. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 Location: J & M Eubanks - Patterson 2 and 3 SWD Tank Battery in Sandy Land at 33.341667, -92.712500. City: Smackover County/Parish: Union State: Arkansas Photo File Name: P909-0073 Orientation: SW Date of Photo: 10/08/2024 Time of Photo: 1147 Latitude: 33.342094 Longitude: -92.712555 Photographer: Kerri McCabe Description: Looking SW, this photo shows additional view of the produced water inside secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 10 Location: J & M Eubanks - Patterson 2 and 3 SWD Tank Battery in Sandy Land at 33.341667, -92.712500. City: Smackover County/Parish: Union State: Arkansas Photo File Name: P909-0074 Orientation: W-SW Date of Photo: 10/08/2024 Time of Photo: 1147 Latitude: 33.342094 Longitude: -92.712555 Photographer: Kerri McCabe Description: Looking W-SW, this photo shows saltwater and salt crystals inside secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 11 Location: J & M Eubanks - Patterson 2 and 3 SWD Tank Battery in Sandy Land at 33.341667, -92.712500. City: Smackover County/Parish: Union State: Arkansas Photo File Name: P909-0075 Orientation: NW Date of Photo: 10/08/2024 Time of Photo: 1148 Latitude: 33.342094 Longitude: -92.712555 Photographer: Kerri McCabe Description: Looking NW, this photo shows a crude oil leak and loose oil inside secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 12 Location: J & M Eubanks - Patterson 2 and 3 SWD Tank Battery in Sandy Land at 33.341667, -92.712500. City: Smackover County/Parish: Union State: Arkansas Photo File Name: P909-0076 Orientation: NW Date of Photo: 10/08/2024 Time of Photo: 1148 Latitude: 33.342094 Longitude: -92.712555 Photographer: Kerri McCabe Description: Looking NW, this photo shows the flowpath of crude oil from a storage tank inside secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 13 Location: J & M Eubanks - Patterson 2 and 3 SWD Tank Battery in Sandy Land at 33.341667, -92.712500. City: Smackover County/Parish: Union State: Arkansas Photo File Name: P909-0077 Orientation: NE Date of Photo: 10/08/2024 Time of Photo: 1148 Latitude: 33.342094 Longitude: -92.712555 Photographer: Kerri McCabe Description: Looking NE, this photo shows an additional view of saltwater and salt crystals inside secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 14 Location: J & M Eubanks - Patterson 2 and 3 SWD Tank Battery in Sandy Land at 33.341667, -92.712500. City: Smackover County/Parish: Union State: Arkansas Photo File Name: P909-0078 Orientation: NW Date of Photo: 10/08/2024 Time of Photo: 1148 Latitude: 33.342063 Longitude: -92.712468 Photographer: Kerri McCabe Description: Looking NW, this photo shows an overview of the storage tanks inside secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 15 Location: J & M Eubanks - Patterson 2 and 3 SWD Tank Battery in Sandy Land at 33.341667, -92.712500. City: Smackover County/Parish: Union State: Arkansas Photo File Name: P909-0079 Orientation: NW Date of Photo: 10/08/2024 Time of Photo: 1149 Latitude: 33.342063 Longitude: -92.712468 Photographer: Kerri McCabe Description: Looking NW, this photo shows a corroded tank with loose oil and salt crystals. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 16 Location: J & M Eubanks - Patterson 2 and 3 SWD Tank Battery in Sandy Land at 33.341667, -92.712500. City: Smackover County/Parish: Union State: Arkansas Photo File Name: P909-0080 Orientation: NW Date of Photo: 10/08/2024 Time of Photo: 1149 Latitude: 33.342063 Longitude: -92.712468 Photographer: Kerri McCabe Description: Looking NW, this photo shows an additional view of the loose oil and salt crystals from Photo No. 15. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 17 Location: J & M Eubanks - Patterson 2 and 3 SWD Tank Battery in Sandy Land at 33.341667, -92.712500. City: Smackover County/Parish: Union State: Arkansas Photo File Name: P909-0081 Orientation: W-NW Date of Photo: 10/08/2024 Time of Photo: 1149 Latitude: 33.342063 Longitude: -92.712468 Photographer: Kerri McCabe Description: Looking W-NW, this photo shows a closeup of the corroded tank inside secondary containment from Photo No. 15 and 16. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 18 Location: J & M Eubanks - Patterson 2 and 3 SWD Tank Battery in Sandy Land at 33.341667, -92.712500. City: Smackover County/Parish: Union State: Arkansas Photo File Name: P909-0082 Orientation: NE Date of Photo: 10/08/2024 Time of Photo: 1149 Latitude: 33.342063 Longitude: -92.712468 Photographer: Kerri McCabe Description: Looking NE, this photo shows an active leak in the corroded storage tank from Photo No. 15 through 17. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 19 Location: J & M Eubanks - Patterson 2 and 3 SWD Tank Battery in Sandy Land at 33.341667, -92.712500. City: Smackover County/Parish: Union State: Arkansas Photo File Name: P909-0083 Orientation: W-NW Date of Photo: 10/08/2024 Time of Photo: 1150 Latitude: 33.342063 Longitude: -92.712468 Photographer: Kerri McCabe Description: Looking W-NW, this photo shows an overview from the backside of the secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 20 Location: J & M Eubanks - Patterson 2 and 3 SWD Tank Battery in Sandy Land at 33.341667, -92.712500. City: Smackover County/Parish: Union State: Arkansas Photo File Name: P909-0084 Orientation: N-NE Date of Photo: 10/08/2024 Time of Photo: 1151 Latitude: 33.341667 Longitude: -92.712500 Photographer: Kerri McCabe Description: Looking N-NE, this photo shows one of two Saltwater Disposal (SWD) wells located in the area.