Document ZgadzpMGy5DpKYvmVgvvRzdL

DownloadSearchable PDFRandom document
Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 07/16/2024 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: B Pharr Operating, LLC Stylite Townsend Tank Battery From Highway 63 E, then Armer Rd, at the intersection of Lockner Rd at 33.256110, -92.534660 Old Union, AR, 71730 P.O. Box 130 Emerson, AR, 71740 Union County 870-904-5573 Billy Pharr Owner / Operator bp@hydrooil.net FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: N/A ARU002211 N/A 211111 1311 Personnel participating in inspection: Kerri McCabe (lead) EPA / Region 6 ECDW Michael Blaha EPA / Region 6 ECDW Inspector / Enforcement Officer Inspector / Enforcement Officer EPA Lead Inspector Signature/Date Supervisor Signature/Date KERRI MCCABE Kerri McCabe Digitally signed by KERRI MCCABE Date: 2024.08.02 14:03:03 -05'00' Date JEANNE ECKHART Date: 2024.08.15 07:00:46 -05'00' Digitally signed by JEANNE ECKHART Jeanne Eckhart Date 6ENFORM-019-R8.2 (02/12/2020) 1 Section I - INTRODUCTION B Pharr Operating, LLC / Stylite Townsend Tank Battery (ARU002211 / CWA) Inspection Date 07/16/2024 PURPOSE OF THE INSPECTION EPA Region 6 inspectors Kerri McCabe (lead) and Michael Blaha arrived at the B Pharr Operating, LLC / Stylite Townsend Tank Battery, located from Highway 63 E, then Armer Rd, at the intersection of Lockner Rd at 33.256110, -92.534660; at 1000 on 07/16/2024 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. This facility was last inspected on 12/14/2023 by Inspector Michael Blaha. FACILITY DESCRIPTION EPA conducted a follow-up inspection on the B Pharr Operating, LLC / Stylite Townsend facility, which contained two (2) tank batteries, three (3) storage tanks for crude oil and saltwater, two (2) oil-water separators, and one (1) Saltwater Disposal (SWD) well. Map 1. Aerial imagery (Google Earth dated 03/11/2024) of the B Pharr Operating, LLC - Stylite Townsend Tank Battery. 2 Section II - OBSERVATIONS B Pharr Operating, LLC / Stylite Townsend Tank Battery (ARU002211 / CWA) Inspection Date 07/16/2024 I observed the B Pharr Operating, LLC - Stylite Townsend Tank Battery, signage, and associated secondary containment, storage tanks, separators/treaters, and saltwater disposal (SWD) well; see Appendix 1 (Photographs Log), Photo No. 1 and No. 2. For additional GPS location and photo metadata, see Appendix 1. I observed loose oil around the drainpipe for the secondary containment for the main tank battery and a transfer pipe without a catchment bucket, see Photo No. 1 and No. 3. I observed loose oil floating on top of stormwater commingled with saltwater inside the secondary containment for the main tank battery, see Photo No. 4 through No. 6. I observed an active leak from a valve for piping inside the secondary containment for the main tank battery, see Photo No. 6. I observed oil seeping from the secondary containment structure for the main tank battery, see Photo No. 7 and No. 8. I observed an additional secondary containment structure and a drainpipe for an oil-water separator adjacent to the main tank battery, see Photo No. 9, No. 10, and No. 12. I observed loose oil inside the secondary containment for the oil-water separator, see Photo No. 10. I observed the stormwater and discharge flowpath for the secondary containments for the main tank battery and the oil-water separator tank battery, see Photo No. 11, No. 13, and No. 14. I observed erodible soils denuded of vegetation and a grouping of dead trees from a previous saltwater discharge that was downstream of the tank batteries and SWD well, see Photo No. 14, No. 15, No. 17, and No. 19. I observed a dry ephemeral stream that receives stormwater and discharges from the B Pharr Operating, LLC - Stylite Townsend Tank Battery and Stylite Townsend #1 SWD, see Photo No. 16. This is the point of entry (POE) for stormwater and discharges. I observed the Stylite Townsend #1 SWD well and associated flowlines, see Photo No. 18 and No. 19. Section III - AREAS OF CONCERN No closing conference was held due to no personnel with B Pharr Operating, LLC being present during the inspection. Areas of concern at the time of the inspection include the following: Loose, residual oil on the ground outside the secondary containment drainpipe for the main tank battery, A transfer pipe outside secondary containment without a catchment bucket, 3 B Pharr Operating, LLC / Stylite Townsend Tank Battery (ARU002211 / CWA) Inspection Date 07/16/2024 Loose oil on top of stormwater commingled with saltwater inside the secondary containment for the main tank battery, An active leak from a valve on the transfer pipe inside the secondary containment for the main tank battery, Oil actively seeping from the secondary containment structure for the main tank battery indicating inadequate permeable secondary containment, Loose oil inside the secondary containment for the individual oil-water separator, The drainpipe for the oil-water separator tank battery without a cap or shutoff valve, and Erodible soils denuded of vegetation and dead trees from previous saltwater discharge(s). 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. Similar areas of concern were noted in the 12/14/2023 inspection conducted by Inspector Michael Blaha. Section V - LIST OF APPENDICES Appendix 1 - Photograph Log - 19 photos taken 07/16/2024. 4 B Pharr Operating, LLC / Stylite Townsend Tank Battery (ARU002211 / CWA) Inspection Date 07/16/2024 Appendix 1 Photograph Log 19 Photos UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: B Pharr Operating, LLC - Stylite Townsend Tank Battery from Highway 63 E, then Armer Rd, at the intersection of Lockner Rd at 33.256110, -92.534660. City: Old Union County/Parish: Union County State: Arkansas Photo File Name: 100-0252 Orientation: W Date of Photo: 07/16/2024 Time of Photo: 1002 Latitude: 33.256033 Longitude: -92.534700 Photographer: Kerri McCabe Description: Looking W, this photo shows an overview of the Stylite Townsend Tank Battery. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: B Pharr Operating, LLC - Stylite Townsend Tank Battery from Highway 63 E, then Armer Rd, at the intersection of Lockner Rd at 33.256110, -92.534660. City: Old Union County/Parish: Union County State: Arkansas Photo File Name: 100-0253 Orientation: W Date of Photo: 07/16/2024 Time of Photo: 1002 Latitude: 33.256078 Longitude: -92.534685 Photographer: Kerri McCabe Description: Looking W, this photo shows the signage at the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: B Pharr Operating, LLC - Stylite Townsend Tank Battery from Highway 63 E, then Armer Rd, at the intersection of Lockner Rd at 33.256110, -92.534660. City: Old Union County/Parish: Union County State: Arkansas Photo File Name: 100-0254 Orientation: NNW Date of Photo: 07/16/2024 Time of Photo: 1002 Latitude: 33.256089 Longitude: -92.534689 Photographer: Kerri McCabe Description: Looking NNW, this photo shows loose oil around the drainpipe for the secondary containment for the main tank battery and a transfer pipe without a catchment bucket. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: B Pharr Operating, LLC - Stylite Townsend Tank Battery from Highway 63 E, then Armer Rd, at the intersection of Lockner Rd at 33.256110, -92.534660. City: Old Union County/Parish: Union County State: Arkansas Photo File Name: 100-0255 Orientation: NNW Date of Photo: 07/16/2024 Time of Photo: 1002 Latitude: 33.256093 Longitude: -92.534707 Photographer: Kerri McCabe Description: Looking NNW, this photo shows loose oil, saltwater, and stormwater inside the secondary containment for the main tank battery. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: B Pharr Operating, LLC - Stylite Townsend Tank Battery from Highway 63 E, then Armer Rd, at the intersection of Lockner Rd at 33.256110, -92.534660. City: Old Union County/Parish: Union County State: Arkansas Photo File Name: 100-0256 Orientation: WNW Date of Photo: 07/16/2024 Time of Photo: 1003 Latitude: 33.256091 Longitude: -92.534717 Photographer: Kerri McCabe Description: Looking WNW, this photo shows an additional view of the loose oil, saltwater, and stormwater inside the secondary containment for the main tank battery. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: B Pharr Operating, LLC - Stylite Townsend Tank Battery from Highway 63 E, then Armer Rd, at the intersection of Lockner Rd at 33.256110, -92.534660. City: Old Union County/Parish: Union County State: Arkansas Photo File Name: 100-0257 Orientation: NW Date of Photo: 07/16/2024 Time of Photo: 1003 Latitude: 33.256100 Longitude: -92.534709 Photographer: Kerri McCabe Description: Looking NW, this photo shows an active leak at valve and pipe within secondary containment for the main tank battery. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: B Pharr Operating, LLC - Stylite Townsend Tank Battery from Highway 63 E, then Armer Rd, at the intersection of Lockner Rd at 33.256110, -92.534660. City: Old Union County/Parish: Union County State: Arkansas Photo File Name: 100-0258 Orientation: WNW Date of Photo: 07/16/2024 Time of Photo: 1003 Latitude: 33.256120 Longitude: -92.534700 Photographer: Kerri McCabe Description: Looking WNW, this photo shows oil actively seeping through the secondary containment for the main tank battery. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: B Pharr Operating, LLC - Stylite Townsend Tank Battery from Highway 63 E, then Armer Rd, at the intersection of Lockner Rd at 33.256110, -92.534660. City: Old Union County/Parish: Union County State: Arkansas Photo File Name: 100-0259 Orientation: NW Date of Photo: 07/16/2024 Time of Photo: 1003 Latitude: 33.256156 Longitude: -92.534711 Photographer: Kerri McCabe Description: Looking NW, this photo shows a closeup of crude oil the actively leaking from the secondary containment for the main tank battery. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 Location: B Pharr Operating, LLC - Stylite Townsend Tank Battery from Highway 63 E, then Armer Rd, at the intersection of Lockner Rd at 33.256110, -92.534660. City: Old Union County/Parish: Union County State: Arkansas Photo File Name: 100-0260 Orientation: N Date of Photo: 07/16/2024 Time of Photo: 1003 Latitude: 33.256267 Longitude: -92.534667 Photographer: Kerri McCabe Description: Looking N, this photo shows an additional secondary containment for an oil-water separator at the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 10 Location: B Pharr Operating, LLC - Stylite Townsend Tank Battery from Highway 63 E, then Armer Rd, at the intersection of Lockner Rd at 33.256110, -92.534660. City: Old Union County/Parish: Union County State: Arkansas Photo File Name: 100-0261 Orientation: NNW Date of Photo: 07/16/2024 Time of Photo: 1003 Latitude: 33.256300 Longitude: -92.534667 Photographer: Kerri McCabe Description: Looking NNW, this photo shows a closer view of the additional secondary containment for the oil-water separator with loose oil inside the containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 11 Location: B Pharr Operating, LLC - Stylite Townsend Tank Battery from Highway 63 E, then Armer Rd, at the intersection of Lockner Rd at 33.256110, -92.534660. City: Old Union County/Parish: Union County State: Arkansas Photo File Name: 100-0262 Orientation: NNE Date of Photo: 07/16/2024 Time of Photo: 1004 Latitude: 33.256268 Longitude: -92.534626 Photographer: Kerri McCabe Description: Looking NNE, this photo shows the drainage path for the main tank battery in Photos No. 1 through 8. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 12 Location: B Pharr Operating, LLC - Stylite Townsend Tank Battery from Highway 63 E, then Armer Rd, at the intersection of Lockner Rd at 33.256110, -92.534660. City: Old Union County/Parish: Union County State: Arkansas Photo File Name: 100-0263 Orientation: NNW Date of Photo: 07/16/2024 Time of Photo: 1004 Latitude: 33.256280 Longitude: -92.534577 Photographer: Kerri McCabe Description: Looking NNW, this photo shows the drainpipe for the secondary containment for the oilwater separator in Photos No. 9 through 11 without a cap or shutoff valve. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 13 Location: B Pharr Operating, LLC - Stylite Townsend Tank Battery from Highway 63 E, then Armer Rd, at the intersection of Lockner Rd at 33.256110, -92.534660. City: Old Union County/Parish: Union County State: Arkansas Photo File Name: 100-0264 Orientation: NNW Date of Photo: 07/16/2024 Time of Photo: 1004 Latitude: 33.256369 Longitude: -92.534557 Photographer: Kerri McCabe Description: Looking NNW, this photo shows the combined drainage path for both secondary containments at the Stylite Townsend facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 14 Location: B Pharr Operating, LLC - Stylite Townsend Tank Battery from Highway 63 E, then Armer Rd, at the intersection of Lockner Rd at 33.256110, -92.534660. City: Old Union County/Parish: Union County State: Arkansas Photo File Name: 100-0265 Orientation: NNE Date of Photo: 07/16/2024 Time of Photo: 1004 Latitude: 33.256500 Longitude: -92.534633 Photographer: Kerri McCabe Description: Looking NNE, this photo shows erodible soils denuded of vegetation from a previous saltwater discharge to the area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 15 Location: B Pharr Operating, LLC - Stylite Townsend Tank Battery from Highway 63 E, then Armer Rd, at the intersection of Lockner Rd at 33.256110, -92.534660. City: Old Union County/Parish: Union County State: Arkansas Photo File Name: 100-0266 Orientation: NNE Date of Photo: 07/16/2024 Time of Photo: 1005 Latitude: 33.256567 Longitude: -92.534583 Photographer: Kerri McCabe Description: Looking NNE, this photo shows a grouping of dead trees from a previous discharge of saltwater to the area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 16 Location: B Pharr Operating, LLC - Stylite Townsend Tank Battery from Highway 63 E, then Armer Rd, at the intersection of Lockner Rd at 33.256110, -92.534660. City: Old Union County/Parish: Union County State: Arkansas Photo File Name: 100-0267 Orientation: N Date of Photo: 07/16/2024 Time of Photo: 1005 Latitude: 33.256667 Longitude: -92.534300 Photographer: Kerri McCabe Description: Looking N, this photo shows the point of entry from the drainage paths of the tank batteries into the ephemeral stream adjacent to the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 17 Location: B Pharr Operating, LLC - Stylite Townsend Tank Battery from Highway 63 E, then Armer Rd, at the intersection of Lockner Rd at 33.256110, -92.534660. City: Old Union County/Parish: Union County State: Arkansas Photo File Name: 100-0268 Orientation: NW Date of Photo: 07/16/2024 Time of Photo: 1005 Latitude: 33.256667 Longitude: -92.534300 Photographer: Kerri McCabe Description: Looking NW, this photo shows a closer view of the grouping of dead trees in Photo No. 15. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 18 Location: B Pharr Operating, LLC - Stylite Townsend Tank Battery from Highway 63 E, then Armer Rd, at the intersection of Lockner Rd at 33.256110, -92.534660. City: Old Union County/Parish: Union County State: Arkansas Photo File Name: 100-0269 Orientation: N Date of Photo: 07/16/2024 Time of Photo: 1007 Latitude: 33.256550 Longitude: -92.534833 Photographer: Kerri McCabe Description: Looking N, this photo shows the signage for the Stylite Townsend #1 SWD well located onsite. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 19 Location: B Pharr Operating, LLC - Stylite Townsend Tank Battery from Highway 63 E, then Armer Rd, at the intersection of Lockner Rd at 33.256110, -92.534660. City: Old Union County/Parish: Union County State: Arkansas Photo File Name: 100-0270 Orientation: ENE Date of Photo: 07/16/2024 Time of Photo: 1007 Latitude: 33.256554 Longitude: -92.534833 Photographer: Kerri McCabe Description: Looking ENE, this photo shows the drainage path for the SWD in Photo No. 18. Note erodible soils denuded of vegetation from a previous saltwater discharge.