Document a4JvRa2N7g54Z1ZEnXbz8X3Oe

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 3/12/2024 Water Clean Water Act Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: RCP Production, LLC TD Murphy B-3 SWD Tank Battery Latitude: 33.341155, Longitude: -92.690976 Smackover, AR, 71762 134 Daniel Road Smackover, Arkansas, 71762 Union County 870-814-9942 Rod Phillips Rod_phillips2000@yahoo.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: NA ARU002227 NA 211111 1311 Personnel participating in inspection: Michael Blaha EPA/Region 6 ECDW Kerri McCabe EPA/Region 6 ECDW Uma Lad EPA/Region 6 ECDW Enforcement Officer/Inspector Enforcement Officer/Inspector Enforcement Officer/Inspector EPA Lead Inspector Signature/Date Supervisor Signature/Date MICHAEL BLAHA Date: 2024.05.10 20:39:17 -05'00' Digitally signed by MICHAEL BLAHA Michael Blaha Date JEANNE ECKHART Date: 2024.05.10 20:54:41 -05'00' Digitally signed by JEANNE ECKHART Jeanne Eckhart Date 6ENFORM-019-R8.2 (02/12/2020) 1 Section I - INTRODUCTION RCP Production, LLC/ARU002227(CWA) Inspection Date 3/12/2024 - 3/13/2024 PURPOSE OF THE INSPECTION EPA Region 6 inspectors Michael Blaha, Kerri McCabe, and Uma Lad arrived at the RCP Production, LLC, TD Murphy B-3 SWD Tank Battery, located off All Gulf Road in Smackover (33.341485, -92.686930) at 5:30 PM on 3/12/2024 - 3/13/2024 for an unannounced inspection. Rod Phillips 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. On 3/13/2024 Glen Owens with Arkansas Oil and Gas Commission (AOGC) was present. FACILITY DESCRIPTION EPA conducted an inspection on the RCP Production, LLC, TD Murphy B-3 SWD Tank Battery which contained one tank and an injection well. Section II - OBSERVATIONS I observed the facility sign at the facility, see Appendix 1 (photo log), photo No. 1. For additional GPS location information and photo metadata, see Appendix 1. I observed a spill of oil and produced water from the tank inside secondary containment, see photo No. 2. I observed the spill releasing from the open secondary containment drainage valve behind the facility, see photo No. 3 and Appendix 2, video No. 1 and 2. Approximately 19 minutes from the time we started the inspection, John Tarver arrived to shut the secondary containment valve stopping the release, see photo No. 4. Behind the facility, I observed the impacted flowpath with produced water and oil in the wetland, see photo No. 5 and photo No. 6. I observed a Total Dissolved Solids (TDS) reading of 9,258 mg/L in the wetland as well as upstream and downstream characteristics, see photo No. 7 and photo No. 9. Working downstream in the wetland, I observed oil and sheen, see photo No. 10 and photo No. 11. I observed a TDS reading of 30,329 mg/L in the main flowpath in the wetland as well as upstream and downstream characteristics, see photo No. 12 and photo No. 14. Further downstream in the wetland, I observed oil gathering and sheen, see photo No. 15 and photo No. 16. I observed a TDS reading of 25,635 mg/L further downstream in the main flowpath in the wetland, see photo No. 17. 2 RCP Production, LLC/ARU002227(CWA) Inspection Date 3/12/2024 - 3/13/2024 I observed oil gathering in the wetland and sheen, see photo No. 18. I observed the background level TDS reading of 547 mg/L upstream from the impacted water in the wetland as well as wetland characteristics, see photo No. 19 through photo No. 21. The day after the release on 3/13/2024, I observed the facility with the updated sign and closed secondary containment valve, see photo No. 22 through photo No. 24. At the oil lease road crossing, I observed a TDS reading of 16,101 mg/L as well as wetland characteristics, see photo No. 25 through photo No. 27. I observed oil gathering in the wetland upstream from the oil lease road crossing, see photo No. 28. Downstream from the oil lease road crossing, I observed a TDS reading of 2,513 mg/L as well as wetland characteristics, see photo No. 29 through photo No. 31. Further downstream, I observed a TDS reading of 2,419 mg/L as well as wetland characteristics, see photo No. 32 through photo No. 34. Working downstream near the Point of Entry into the unnamed tributary, I observed a TDS reading of 2,349 mg/L as well as wetland characteristics, see photo No. 35 through photo No. 37 In the unnamed tributary, I observed a TDS reading of 1,628 mg/L as well as stream characteristics, see photo No. 38 through photo No. 40. Further downstream in the unnamed tributary, I observed a TDS reading of 1,587 mg/L as well as stream characteristics, see photo No. 41 through photo No. 43. Downstream at the bridge crossing at All Guld Road, I observed a TDS reading of 1,554 mg/L as well as stream characteristics, see photo No. 44 through photo No. 46. Downstream near the railroad crossing, I observed a TDS reading of 1,489 mg/L as well as stream characteristics, see photo No 47. through photo No. 49. On 3/14/2024, I observed a boom and sheen at the oil lease road crossing, see photo No. 50. All TDS field readings observed throughout the inspection were taken with a properly calibrated, EPA issued, YSI pro 30 conductivity meter. On 3/12/2024, Rod Phillips flushed and vacuumed 300 barrels of fresh water. On 3/13/2024, Rod Phillips placed a boom at the oil lease road crossing. Section III - AREAS OF CONCERN A closing conference was held with Mr. Rod Phillips, RCP Production, LLC; to discuss the findings of the inspection. Areas of concern at the time of the inspection include the elevated TDS readings from the surface water along the discharge conveyance. 3 RCP Production, LLC/ARU002227(CWA) Inspection Date 3/12/2024 - 3/13/2024 Section IV - FOLLOW UP Inspector will conduct follow-up phone calls with the company representatives over the coming weeks and months to ensure areas of concern are properly addressed. Section V - LIST OF APPENDICES Appendix 1 - Photo Log - 50 photos taken 3/12/2024 - 3/14/2024 Appendix 2 - Video Log - 2 videos taken on 3/12/2024 4 RCP Production, LLC/ARU002227(CWA) Inspection Date 3/12/2024 Appendix 1 Photograph Log 50 Photos UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 1 County/Parish: Union State: Arkansas Photo File Name: R0010236 Orientation: ENE Date of Photo: 3/12/2024 Time of Photo: 5:21 PM Latitude: 33.341133 Longitude: -92.69103 Photographer: Michael Blaha Description: This photo was taken looking ENE showing the facility sign. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 2 County/Parish: Union State: Arkansas Photo File Name: R0010240 Orientation: NE Date of Photo: 3/12/2024 Time of Photo: 5:32 PM Latitude: 33.34111 Longitude: -92.69112 Photographer: Michael Blaha Description: This photo was taken looking NE at the facility showing an overview of the facility and the spill source. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 3 County/Parish: Union State: Arkansas Photo File Name: R0010242 Orientation: NE Date of Photo: 3/12/2024 Time of Photo: 5:33 PM Latitude: 33.341068 Longitude: -92.69092 Photographer: Michael Blaha Description: This photo was taken looking NE showing the secondary containment discharge pipe releasing the produced water and oil from secondary containment into the nearby wetland. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 4 County/Parish: Union State: Arkansas Photo File Name: R0010243 Orientation: N Date of Photo: 3/12/2024 Time of Photo: 5:50 PM Latitude: 33.341341 Longitude: -92.690912 Photographer: Michael Blaha Description: This photo was taken looking N showing the secondary containment valve closed by John Tarver, stopping the release. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 5 County/Parish: Union State: Arkansas Photo File Name: R0010245 Orientation: E Date of Photo: 3/12/2024 Time of Photo: 6:22 PM Latitude: 33.341166 Longitude: -92.690566 Photographer: Michael Blaha Description: This photo was taken looking downstream E showing sheen on the contaminated flowpath entering the wetland behind (E) the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 6 County/Parish: Union State: Arkansas Photo File Name: R0010246 Orientation: SW Date of Photo: 3/12/2024 Time of Photo: 6:22 PM Latitude: 33.341142 Longitude: -92.690525 Photographer: Michael Blaha Description: This photo was taken looking SW showing the impacted flowpath through the wetland. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 7 County/Parish: Union State: Arkansas Photo File Name: R0010248 Orientation: NA Date of Photo: 3/12/2024 Time of Photo: 6:27 PM Latitude: 33.34109 Longitude: -92.690168 Photographer: Michael Blaha Description: This photo was taken showing a Total Dissolved Solids (TDS) reading of 9,256 mg/L in the wetland. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 8 County/Parish: Union State: Arkansas Photo File Name: R0010249 Orientation: ENE Date of Photo: 3/12/2024 Time of Photo: 6:27 PM Latitude: 33.341177 Longitude: -92.690183 Photographer: Michael Blaha Description: This photo was taken at the same location as photo No. 7 looking downstream ENE showing vegetation and topography of the wetland. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 9 County/Parish: Union State: Arkansas Photo File Name: R0010250 Orientation: N Date of Photo: 3/12/2024 Time of Photo: 6:28 PM Latitude: 33.341171 Longitude: -92.690192 Photographer: Michael Blaha Description: This photo was taken at the same location as photo No. 7 looking upstream N showing vegetation and topography of the wetland. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 10 County/Parish: Union State: Arkansas Photo File Name: R0010251 Orientation: NE Date of Photo: 3/12/2024 Time of Photo: 6:29 PM Latitude: 33.34119 Longitude: -92.68998 Photographer: Michael Blaha Description: This photo taken looking NE showing sheen in the wetland. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 11 County/Parish: Union State: Arkansas Photo File Name: R0010256 Orientation: S Date of Photo: 3/12/2024 Time of Photo: 6:31 PM Latitude: 33.341098 Longitude: -92.689872 Photographer: Michael Blaha Description: This photo is looking S showing oil collecting in the wetland. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 12 County/Parish: Union State: Arkansas Photo File Name: R0010258 Orientation: NA Date of Photo: 3/12/2024 Time of Photo: 6:34 PM Latitude: 33.341355 Longitude: -92.68997 Photographer: Michael Blaha Description: This photo was taken showing a TDS reading of 30,329 mg/L in the main flowpath in the wetland. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 13 County/Parish: Union State: Arkansas Photo File Name: R0010263 Orientation: W Date of Photo: 3/12/2024 Time of Photo: 6:34 PM Latitude: 33.341355 Longitude: -92.68997 Photographer: Michael Blaha Description: This photo was taken at the same location as photo No. 12 looking upstream W showing vegetation and topography of the wetland. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 14 County/Parish: Union State: Arkansas Photo File Name: R0010264 Orientation: E Date of Photo: 3/12/2024 Time of Photo: 6:34 PM Latitude: 33.341355 Longitude: -92.68997 Photographer: Michael Blaha Description: This photo was taken at the same location as photo No. 12 looking downstream E showing vegetation, topography, and sheen in the wetland. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 15 County/Parish: Union State: Arkansas Photo File Name: R0010269 Orientation: NE Date of Photo: 3/12/2024 Time of Photo: 6:40 PM Latitude: 33.341408 Longitude: -92.689273 Photographer: Michael Blaha Description: This photo was taken looking NE showing oil in the wetland. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 16 County/Parish: Union State: Arkansas Photo File Name: R00102673 Orientation: SE Date of Photo: 3/12/2024 Time of Photo: 6:41 PM Latitude: 33.341393 Longitude: -92.689091 Photographer: Michael Blaha Description: This photo was taken looking SE showing where oil has collected in the wetland. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 17 County/Parish: Union State: Arkansas Photo File Name: R0010274 Orientation: NA Date of Photo: 3/12/2024 Time of Photo: 6:42 PM Latitude: 33.341466 Longitude: -92.689178 Photographer: Michael Blaha Description: This photo was taken showing a TDS reading of 25,635 mg/L in the main flowpath in the wetland. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 18 County/Parish: Union State: Arkansas Photo File Name: R0010275 Orientation: SSE Date of Photo: 3/12/2024 Time of Photo: 6:47 PM Latitude: 33.341503 Longitude: - 92.688942 Photographer: Michael Blaha Description: This photo was taken looking SSE showing oil collecting on water in the wetland. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 19 County/Parish: Union State: Arkansas Photo File Name: R0010276 Orientation: NA Date of Photo: 3/12/2024 Time of Photo: 6:58 PM Latitude: 33.340966 Longitude: -92.68997 Photographer: Michael Blaha Description: This photo was taken showing the background TDS reading of 547 mg/L in the main flowpath upstream from the impacted segment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 20 County/Parish: Union State: Arkansas Photo File Name: R0010277 Orientation: NE Date of Photo: 3/12/2024 Time of Photo: 6:58 PM Latitude: 33.340966 Longitude: -92.68997 Photographer: Michael Blaha Description: This photo was taken at the same location as photo No. 19 looking upstream NE showing vegetation and topography of the wetland. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 21 County/Parish: Union State: Arkansas Photo File Name: R0010278 Orientation: SW Date of Photo: 3/12/2024 Time of Photo: 6:58 PM Latitude: 33.340966 Longitude: -92.68997 Photographer: Michael Blaha Description: This photo was taken at the same location as photo No. 19 looking downstream SW showing vegetation and topography of the wetland. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 22 County/Parish: Union State: Arkansas Photo File Name: R0010280 Orientation: NE Date of Photo: 3/13/2024 Time of Photo: 9:41 AM Latitude: 33.34111 Longitude: -92.69112 Photographer: Michael Blaha Description: This photo was taken looking NE at the facility showing an updated sign on the tankas well as stoppage of release. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 23 County/Parish: Union State: Arkansas Photo File Name: R0010285 Orientation: ENE Date of Photo: 3/13/2024 Time of Photo: 9:43 AM Latitude: 33.34111 Longitude: -92.69096 Photographer: Michael Blaha Description: This photo was taken looking ENE showing the impacted flowpath the day after the release. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 24 County/Parish: Union State: Arkansas Photo File Name: R0010286 Orientation: NE Date of Photo: 3/13/2024 Time of Photo: 9:44 AM Latitude: 33.341068 Longitude: -92.69092 Photographer: Michael Blaha Description: This photo was taken looking NE showing the secondary containment discharge pipe with a new valve and cap. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 25 County/Parish: Union State: Arkansas Photo File Name: R0010292 Orientation: NA Date of Photo: 3/13/2024 Time of Photo: 11:08 AM Latitude: 33.341471 Longitude: -92.687035 Photographer: Michael Blaha Description: This photo was taken showing a TDS reading of 16,101 mg/L at the oil lease road crossing a day after the release. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 26 County/Parish: Union State: Arkansas Photo File Name: R0010290 Orientation: WNW Date of Photo: 3/13/2024 Time of Photo: 11:03 AM Latitude: 33.341471 Longitude: -92.687035 Photographer: Michael Blaha Description: This photo was taken at the same location as photo No. 25 looking upstream WNW showing sheen, vegetation, and topography of the wetland. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 27 County/Parish: Union State: Arkansas Photo File Name: R0010291 Orientation: E Date of Photo: 3/13/2024 Time of Photo: 11:03 AM Latitude: 33.341471 Longitude: -92.687035 Photographer: Michael Blaha Description: This photo was taken at the same location as photo No. 25 looking downstream E showing vegetation and topography of the wetland. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 28 County/Parish: Union State: Arkansas Photo File Name: R0010297 Orientation: NW Date of Photo: 3/13/2024 Time of Photo: 11:22 AM Latitude: 33.341425 Longitude: -92.688535 Photographer: Michael Blaha Description: This photo was taken looking NW showing oil collecting in the wetland. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 29 County/Parish: Union State: Arkansas Photo File Name: R0010312 Orientation: NA Date of Photo: 3/13/2024 Time of Photo: 1:31 PM Latitude: 33.34144 Longitude: -92.68677 Photographer: Michael Blaha Description: This photo was taken showing a TDS reading of 2,513 mg/L downstream from the oil lease road crossing a day after the release. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 30 County/Parish: Union State: Arkansas Photo File Name: R0010313 Orientation: NE Date of Photo: 3/13/2024 Time of Photo: 1:31 PM Latitude: 33.34144 Longitude: -92.68677 Photographer: Michael Blaha Description: This photo was taken at the same location as photo No. 29 looking downstream NE vegetation and topography of the wetland. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 31 County/Parish: Union State: Arkansas Photo File Name: R0010314 Orientation: NW Date of Photo: 3/13/2024 Time of Photo: 1:31 PM Latitude: 33.34144 Longitude: -92.68677 Photographer: Michael Blaha Description: This photo was taken at the same location as photo No. 29 looking upstream NW vegetation and topography of the wetland. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 32 County/Parish: Union State: Arkansas Photo File Name: R0010315 Orientation: NA Date of Photo: 3/13/2024 Time of Photo: 1:38 PM Latitude: 33.341685 Longitude: -92.685821 Photographer: Michael Blaha Description: This photo was taken showing a TDS reading of 2,419 mg/L further downstream from the oil lease road crossing a day after the release. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 33 County/Parish: Union State: Arkansas Photo File Name: R0010316 Orientation: WNW Date of Photo: 3/13/2024 Time of Photo: 1:38 PM Latitude: 33.341685 Longitude: -92.685821 Photographer: Michael Blaha Description: This photo was taken at the same location as photo No. 32 looking upstream WNW vegetation and topography of the wetland. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 34 County/Parish: Union State: Arkansas Photo File Name: R0010317 Orientation: N Date of Photo: 3/13/2024 Time of Photo: 1:39 PM Latitude: 33.341685 Longitude: -92.685821 Photographer: Michael Blaha Description: This photo was taken at the same location as photo No. 32 looking downstream N vegetation and topography of the wetland. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 35 County/Parish: Union State: Arkansas Photo File Name: R0010321 Orientation: NA Date of Photo: 3/13/2024 Time of Photo: 1:57 PM Latitude: 33.341215 Longitude: -92.685412 Photographer: Michael Blaha Description: This photo was taken showing a TDS reading of 2,349 mg/L further downstream near the unnamed tributary a day after the release. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 36 County/Parish: Union State: Arkansas Photo File Name: R0010322 Orientation: WNW Date of Photo: 3/13/2024 Time of Photo: 1:58 PM Latitude: 33.341215 Longitude: -92.685412 Photographer: Michael Blaha Description: This photo was taken at the same location as photo No. 35 looking upstream WNW showing vegetation and topography of the wetland. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 37 County/Parish: Union State: Arkansas Photo File Name: R0010323 Orientation: SE Date of Photo: 3/13/2024 Time of Photo: 1:58 PM Latitude: 33.341215 Longitude: -92.685412 Photographer: Michael Blaha Description: This photo was taken at the same location as photo No. 35 looking downstream SE showing the wetlands POE into the unnamed tributary that connects to Smackover Creek. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 38 County/Parish: Union State: Arkansas Photo File Name: R0010327 Orientation: NA Date of Photo: 3/13/2024 Time of Photo: 2:23 PM Latitude: 33.34229 Longitude: -92.68521 Photographer: Michael Blaha Description: This photo was taken showing a TDS reading of 1,628 mg/L at the point of entry (POE) into the unnamed tributary that connects to Smackover Creek. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 39 County/Parish: Union State: Arkansas Photo File Name: R0010328 Orientation: SE Date of Photo: 3/13/2024 Time of Photo: 2:24 PM Latitude: 33.34229 Longitude: -92.68521 Photographer: Michael Blaha Description: This photo was taken at the same location as photo No. 38 looking upstream SE showing the vegetation and bed and bank features of the unnamed tributary that connects to Smackover Creek. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 40 County/Parish: Union State: Arkansas Photo File Name: R0010329 Orientation: NE Date of Photo: 3/13/2024 Time of Photo: 2:24 PM Latitude: 33.34229 Longitude: -92.68521 Photographer: Michael Blaha Description: This photo was taken at the same location as photo No. 38 looking downstream NE showing the vegetation and bed and bank features of the unnamed tributary that connects to Smackover Creek. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 41 County/Parish: Union State: Arkansas Photo File Name: R0010330 Orientation: NA Date of Photo: 3/13/2024 Time of Photo: 2:28 PM Latitude: 33.34825 Longitude: -92.686472 Photographer: Michael Blaha Description: This photo was taken showing a TDS reading of 1,587 mg/L further downstream from the POE into the unnamed tributary. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 42 County/Parish: Union State: Arkansas Photo File Name: R0010331 Orientation: NE Date of Photo: 3/13/2024 Time of Photo: 2:29 PM Latitude: 33.34825 Longitude: -92.686472 Photographer: Michael Blaha Description: This photo was taken at the same location as photo No. 41 looking downstream NE showing the vegetation and bed and bank features of the unnamed tributary. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 43 County/Parish: Union State: Arkansas Photo File Name: R0010332 Orientation: S Date of Photo: 3/13/2024 Time of Photo: 2:29 PM Latitude: 33.34825 Longitude: -92.686472 Photographer: Michael Blaha Description: This photo was taken at the same location as photo No. 41 looking upstream S showing the vegetation and bed and bank features of the unnamed tributary. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 44 County/Parish: Union State: Arkansas Photo File Name: R0010336 Orientation: NA Date of Photo: 3/13/2024 Time of Photo: 3:46 PM Latitude: 33.345925 Longitude: -92.682257 Photographer: Michael Blaha Description: This photo was taken showing a TDS reading of 1,554 mg/L at the bridge crossing on All Gulf Road in the unnamed tributary. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 45 County/Parish: Union State: Arkansas Photo File Name: R0010337 Orientation: SSW Date of Photo: 3/13/2024 Time of Photo: 3:46 PM Latitude: 33.345925 Longitude: -92.682257 Photographer: Michael Blaha Description: This photo was taken at the same location as photo No. 41 looking upstream SSW showing the vegetation and bed and bank features of the unnamed tributary off All Gulf Road. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 46 County/Parish: Union State: Arkansas Photo File Name: R0010338 Orientation: NNE Date of Photo: 3/13/2024 Time of Photo: 3:46 PM Latitude: 33.345925 Longitude: -92.682257 Photographer: Michael Blaha Description: This photo was taken at the same location as photo No. 41 looking downstream NNE showing the vegetation and bed and bank features of the unnamed tributary off All Gulf Road. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 47 County/Parish: Union State: Arkansas Photo File Name: R0010306 Orientation: NA Date of Photo: 3/13/2024 Time of Photo: 12:25 PM Latitude: 33.348791 Longitude: -92.68093 Photographer: Michael Blaha Description: This photo was taken showing a TDS reading of 1,489 mg/L at the railroad crossing of the unnamed tributary. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 48 County/Parish: Union State: Arkansas Photo File Name: R0010307 Orientation: NNW Date of Photo: 3/13/2024 Time of Photo: 12:25 PM Latitude: 33.348791 Longitude: -92.68093 Photographer: Michael Blaha Description: This photo was taken at the same location as photo No. 47 looking downstream NNW showing the vegetation and bed and bank features of the unnamed tributary off the railroad crossing. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 49 County/Parish: Union State: Arkansas Photo File Name: R0010308 Orientation: NW Date of Photo: 3/13/2024 Time of Photo: 12:25 PM Latitude: 33.348791 Longitude: -92.68093 Photographer: Michael Blaha Description: This photo was taken at the same location as photo No. 47 looking downstream NW showing the vegetation and bed and bank features of the unnamed tributary off the railroad crossing. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 33.341133, -92.69103 City: Smackover Photo No. 50 County/Parish: Union State: Arkansas Photo File Name: R0010403 Orientation: NW Date of Photo: 3/14/2024 Time of Photo: 12:34 PM Latitude: 33.34141 Longitude: -92.68702 Photographer: Michael Blaha Description: This photo was taken looking NW showing the sheen and boom off the oil lease road two days after the release. RCP Production, LLC - SWD / ARU002227 Inspection Date 03/12/2024 Appendix 2 Video Log UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Video Log Appendix 2 Location: 33.341133, -92.69103 City: Smackover Union County State: Arkansas Video File Name: Date of Video: Time of Video: Videographer: Description: R0010237.MOV 03/12/2024 5:21 pm Uma Lad This video was taken looking E showing produced water and oil flowing out of the tank into secondary containment. The secondary containment valve was left open releasing the spill outside of secondary containment. Video File Name: Date of Video: Time of Video: Videographer: Description: R0010239.MOV 03/12/2024 5:27 pm Uma Lad This video was taken looking ENE showing the produced water and oil flowing out of the open secondary containment valve flowing towards a wetland. Page 1 of 1