Document XRk4y2m3odVJoLLyqYY7XKwB4

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 05/09/2024 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: LANXESS Corporation - South Plant SWD Trimble 9S (Class II injection well at 33.105418, -92.710991) 324 Southfield Cutoff El Dorado, AR 71730 2226 Haynesville Hwy El Dorado, AR 71730 Union County 870-862-5141 Rodger Fulco (870-864-1570) Head of Brine Production Rodger.Fulco@lanxess.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: N/A ARU002249; ADEQ AFIN 70-00037 for AR0000680, ARR001376, 5048-WR-2, 5175-WR-1, and 0010-UR-4 N/A 325998 2899 Personnel participating in inspection: Kerri McCabe (lead) EPA / Region 6 ECDW Michael Blaha EPA / Region 6 ECDW Rodger Fulco LANXESS Corporation Kimberly Shurtleff LANXESS Corporation Inspector / Enforcement Officer Inspector / Enforcement Officer Head of Brine Production, South Arkansas Head of Manufacturing, South Arkansas EPA Lead Inspector Signature/Date Supervisor Signature/Date KERRI MCCABE Kerri McCabe Digitally signed by KERRI MCCABE Date: 2024.06.11 08:20:18 -05'00' Date MICHAEL BLAHA Date: 2024.06.11 08:26:54 -05'00' Digitally signed by MICHAEL BLAHA Michael Blaha (acting) Date 6ENFORM-019-R8.2 (02/12/2020) 1 LANXESS Corporation - South Plant / SWD Trimble 9S Release Site (ARU002249 / CWA) Inspection Date 05/09/2024 Section I - INTRODUCTION PURPOSE OF THE INSPECTION EPA Region 6 inspectors Kerri McCabe (lead) and Michael Blaha arrived at the LANXESS Corporation - South Plant / SWD Trimble 9S release site, located off Southfield Cutoff at 33.105418, -92.710991; at 0830 on 05/09/2024 for an announced inspection. Mr. Rodger Fulco, LANXESS Corporation, was 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 LANXESS Corporation - South Plant / SWD Trimble 9S injection well in response to a complaint submitted to the U.S. EPA Office of the Inspector General in August 2023. The SWD Trimble 9S is a Class II injection well utilized for the disposal of tail brine. Section II - OBSERVATIONS I observed the area of the August 2023 tail brine release, see Appendix 1 (Photograph Log), see Photo No. 1. For additional GPS location and photo metadata, see Appendix 1. I observed an earthen berm that had been constructed to contain the tail brine release, see Photo No. 2. I observed an area on private property with standing dead trees, see Photo No. 3. I observed the injection well pad, see Photo No. 4. I observed the repaired section of line for the injection well, see Photo No. 5. I observed a privately-owned utility Right of Way (ROW) that had been cleared of trees, see Photo No. 6. Section III - AREAS OF CONCERN A closing conference was held with Mr. Rodger Fulco with LANXESS Corporation during the inspection. Mr. Fulco explained that LANXESS Corporation had worked with the adjacent property owner regarding the impacted trees. Furthermore, Mr. Fulco explained that a privately-owned utility had removed trees along the ROW, and this activity was not related to the release of tail brine. The ruptured tail brine line had been repaired. There were no areas of concern at the time of the inspection. Section IV - FOLLOW UP There were no areas of concern during the inspection, and a follow-up inspection is not required at this time. 2 LANXESS Corporation - South Plant / SWD Trimble 9S Release Site (ARU002249 / CWA) Inspection Date 05/09/2024 Section V - LIST OF APPENDICES Appendix 1 - Photograph Log - 6 photos taken 05/09/2024. 3 LANXESS Corporation - South Plant / SWD Trimble 9 S (CWA / ARU002249) Inspection Date 05/09/2024 Appendix 1 Photograph Log 6 Photos UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: LANXESS Corporation - South Plant - SWD Trimble 9 S from Hwy 82W, to State Hwy 4 (Haynesville Hwy), to State Hwy 7, to Southfield Cutoff at 33.105418, -92.710991. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: IMG_0002 Orientation: SW Date of Photo: 05/09/2024 Time of Photo: 0912 Latitude: 33.105000 Longitude: -92.712631 Photographer: Kerri McCabe Description: Looking SW, this photo showed the earthen berm built to contain the release of tail brine. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: LANXESS Corporation - South Plant - SWD Trimble 9 S from Hwy 82W, to State Hwy 4 (Haynesville Hwy), to State Hwy 7, to Southfield Cutoff at 33.105418, -92.710991. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: IMG_0003 Orientation: S Date of Photo: 05/09/2024 Time of Photo: 0915 Latitude: 33.105092 Longitude: -92.712669 Photographer: Kerri McCabe Description: Looking S, this photo showed another view of the earthen berm used to collect the tail brine released. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: LANXESS Corporation - South Plant - SWD Trimble 9 S from Hwy 82W, to State Hwy 4 (Haynesville Hwy), to State Hwy 7, to Southfield Cutoff at 33.105418, -92.710991. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: IMG_0004 Orientation: S Date of Photo: 05/09/2024 Time of Photo: 0920 Latitude: 33.105033 Longitude: -92.711481 Photographer: Kerri McCabe Description: Looking S, this photo showed the SWD pad with dead vegetation from the brine release in the background on private property. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: LANXESS Corporation - South Plant - SWD Trimble 9 S from Hwy 82W, to State Hwy 4 (Haynesville Hwy), to State Hwy 7, to Southfield Cutoff at 33.105418, -92.710991. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: IMG_0005 Orientation: NE Date of Photo: 05/09/2024 Time of Photo: 0921 Latitude: 33.105055 Longitude: -92.711444 Photographer: Kerri McCabe Description: Looking NE, this photo showed the overview of the tail brine injection well where the release had occurred. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: LANXESS Corporation - South Plant - SWD Trimble 9 S from Hwy 82W, to State Hwy 4 (Haynesville Hwy), to State Hwy 7, to Southfield Cutoff at 33.105418, -92.710991. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: IMG_0006 Orientation: E Date of Photo: 05/09/2024 Time of Photo: 0923 Latitude: 33.105265 Longitude: -92.711406 Photographer: Kerri McCabe Description: Looking E, this photo showed the section of the line that was replaced after the release. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: LANXESS Corporation - South Plant - SWD Trimble 9 S from Hwy 82W, to State Hwy 4 (Haynesville Hwy), to State Hwy 7, to Southfield Cutoff at 33.105418, -92.710991. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: IMG_0007 Orientation: NE Date of Photo: 05/09/2024 Time of Photo: 0929 Latitude: 33.105553 Longitude: -92.710931 Photographer: Kerri McCabe Description: Looking NE, this photo showed the Right of Way (ROW) cleared by private utility company.