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Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) February 26, 2020 Water - Produced Water (Brine) Clean Water Act, National Pollution Discharge Elimination System Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: Cantrell Energy Corporation SW Ardmore Tulip Creek Sand Unit (SWAT) 34.0934583 N, -97.1701522 W Ardmore, Oklahoma 73401 522 East 12th St. (Alternative: 12273 CR 1560) Ada, Oklahoma 74820 (Alternative: Ada, Oklahoma 74820) Carter County 580-332-2243 Blake Cantrell Owner bcantr@aol.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: N/A OKU000882 N/A 211111 1311 Personnel participating in inspection: Jeanne Eckhart EPA Region 6 / 6ECDWE Kayla Woods EPA Region 6 / 6ECDWE Richard Welch Oklahoma Corp. Comm. (OCC) Clayton Christian OCC Ferrella March Ok. Dept. of Enviro. Qual. (ODEQ) Brian Magott ODEQ Debbie Taylor ODEQ - Ardmore Jayme Jones ODEQ Stephanie Hacker Citizen Steve Martin Citizen Inspector Inspector Inspector Inspector Enviro. Programs Manager DEQ Representative DEQ Representative DEQ Representative Landowner Representative Landowner Representative EPA Lead Inspector Signature/Date Supervisor Signature/Date JEANNE ECKHART Digitally signed by JEANNE ECKHART DN: c=US, o=U.S. Government, ou=Environmental Protection Agency, cn=JEANNE ECKHART, 0.9.2342.19200300.100.1.1=68001003655845 Date: 2020.04.13 12:54:24 -05'00' Jeanne Eckhart Date 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: 2020.04.13 15:43:15 -05'00' 13 APR 2020 Guy Tidmore Date 6ENFORM-020-R8.2 (02/12/2020) 1 Section I - INTRODUCTION Cantrell Energy Corporation / SW Ardmore Tulip Creek Sand Unit (SWAT) Inspection Date: 02/26/2020 PURPOSE OF THE INSPECTION EPA Region 6 inspectors Jeanne Eckhart and Kayla Woods visited the Cantrell Energy Corporation oil and gas facility located near Plainview, Oklahoma on 02/26/2020 at about 8:30 AM for an unannounced inspection. There were no representatives of Cantrell Energy Corporation present for the inspection. There were several landowner and state representatives present during the inspection, including Oklahoma Department of Quality (ODEQ) and Oklahoma Corporation Commission (OCC). The inspection was conducted by authority of the Clean Water Act and the Safe Drinking Water Act to determine compliance with the Environmental Protection Agency (EPA) regulations. FACILITY DESCRIPTION EPA conducted a joint inspection with ODEQ and OCC at this oil and gas lease, or "facility", in response to referral from ODEQ of an ongoing issue of contamination identified in Hickory Creek. During the inspection, there was no identified source of contamination that was seen released into Hickory Creek. According to the initial meeting EPA had with landowner representatives and the state on site, there were multiple observed bubbling locations (purges) within Hickory Creek in an approximate 0.5 mile stretch of the creek that had been occurring for multiple years. I indicated to the landowner representatives that the authority of the CWA and that there was not an identified source of the contamination coming into Hickory Creek at this time. The landowner representatives identified to me ongoing contamination observed bubbling up into Hickory Creek and indicated ongoing oil and gas hydraulic fracturing activity nearby when they first observed the bubbling into Hickory Creek. Additionally, the landowner representatives expressed concerns of smelling hydrogen sulfide over time approximately 0.5 miles downstream from the initial bubbling location documented in this inspection report on Hickory Creek. To assess the contamination coming into Hickory Creek, I conducted a creek survey of Hickory Creek across approximately 3 miles of creek near Plainview, Oklahoma with Kayla Woods. Section II - OBSERVATIONS Prior to arriving at the site, Kayla and I successfully calibrated our field equipment and the YSI Pro 30 conductivity meter. We initially arrived at the facility at approximately 8:30 AM on 02/26/2020. Photo 1 identified the lease as the SW Ardmore Tulip Creek Sand Unit ("SWAT") Unit. The initial point of bubbling identified was seen in Photo 2 and measured 34,185 milligrams per liter (mg/L) Total Dissolved Solids (TDS), seen in Photo 3. Livestock were observed on the site during the inspection in this area as well. Photos 4-14 document stream conditions at Hickory Creek during the inspection in approximately 0.5 miles of stream segment where most of the contamination was seen. I observed in this stream segment water discoloration (red and orange tint), sheen on the water surface not related to vegetation, and continuous bubbling from approximately 3 locations in Hickory Creek that were bubbling up into the creek (purges). The creek was flowing at the time of the inspection. I also saw seeping fluids from both banks in Hickory Creek (west and east sides) during the inspection throughout this area. I observed elevated TDS levels throughout Hickory Creek in this mile stream segment that ranged between 22,017 mg/L to 2 Cantrell Energy Corporation / SW Ardmore Tulip Creek Sand Unit (SWAT) Inspection Date: 02/26/2020 34,184 mg/L. Please see Table 1 for all TDS readings taken during the inspection and the exact locations these readings were taken. Additionally, sheen was observed throughout this portion of the creek, that was not vegetative related. This sheen was mainly seen in the seepage along the western bank of the creek. I was not able to inspect the eastern bank of Hickory Creek closely due to high water conditions, but seepage was observed from there from in the bed of the creek. I observed elevated water temperature throughout this portion of the stream as well. Photos 15 and 16 were taken approximately 0.5 miles downstream from the initial bubbling point observed in Hickory Creek. I observed the creek conditions here and took a TDS measurement (Table 1). In this location, I smelled a slight and brief rotten egg smell while observing the creek here. Over 2.5 miles downstream from the initially observed purge point, I observed a dam in Hickory Creek and measured TDS as well just upstream from the dam (Photos 17 & 18). The creek conditions downstream from the first half mile stream segment was similar at the 0.5 miles downstream location and 2.5 miles downstream location. Hickory Creek was flowing, had bed, bank, and ordinary high-water marks observed. Additionally, I saw a lot of flooded debris in the stream area at each location. I observed background, or upstream conditions in Photos 19 and 20. I measured TDS at this location and documented that the creek was flowing south at this location during the inspection. I saw bed, bank, ordinary high-water marks, a defined creek channel, and facultative vegetation at this location. I measured TDS in Hickory Creek throughout the inspection as indicated below in Table 1. Table 1. Total Dissolved Solids (TDS) in Hickory Creek Photo No.* Latitude Longitude TDS (mg/L) Temp (C ) Position in Hickory Creek 3 34.0954085 -97.1705656 34,184 mg/L 17.2 Initial bubbling identified 9 34.0947063 -97.1696044 22,017 mg/L 11.5 Downstream from Photo 3 (~300 yards) 14 34.0944229 -97.1693117 31,224 mg/L 9.8 Downstream from Photo 3 (~315 yards) 16 34.0910835 -97.1705113 987 mg/L 9.8 Downstream from Photo 3 (~0.5 miles) 18 34.0766271 -97.1699346 913 mg/L 10.5 Downstream from Photo 3 (~2.5 miles) 20 34.0999706 -97.1660551 518 mg/L 8.3 Upstream from Photo 3 (~0.6 miles) *Photo No. references the Photo No. that documents that reading in Appendix 1, the Photographic Log. Section III - AREAS OF CONCERN There were elevated levels of TDS in Hickory Creek over background near observed purging/bubbling in Hickory Creek throughout an approximate mile of creek segment. I observe seepage from the banks of the creek in this location as well that was discolored and had sheen. I observed sheen, discolored (red and orange tinted) fluids in Hickory Creek. The source of the containments into Hickory Creek was not known during the inspection. The contamination had been ongoing for a long period of time according to state representatives and landowner representatives I met with on site. The temperature was elevated in this area as well during the field readings taken. 3 Cantrell Energy Corporation / SW Ardmore Tulip Creek Sand Unit (SWAT) Inspection Date: 02/26/2020 Section IV - FOLLOW UP During a follow up discussion with Cantrell Energy Corporation representatives on 3/2/2020 and 3/12/2020, I documented information related to this matter on the SWAT lease from the representatives, Mr. Anthony Prince, Mr. Daniel Sellers, and Mr. Blake Cantrell (Owner). These representatives are following up with EPA and providing historical information, studies, and lease operations and maintenance measures taken over time related to the SWAT lease and this contamination event. Currently, this lease is not injecting into the injection wells maintained on the lease and removing produced water products to an offsite location as determined appropriate by the company. I will continue to follow up with the company representatives to gather information they indicated they could provide to EPA. Additionally, EPA will continue to work jointly with both ODEQ and OCC to monitor and investigate this matter, as determined appropriate. EPA will provide the inspection report copy to all representatives identified during the inspection, including Cantrell Energy Corporation. Section V - LIST OF APPENDICES Appendix 1 - Photographic Log (20 Photos) taken 2/26/2020. 4 Cantrell Energy Corporation / SWAT Unit Inspection Date: 02/26/2020 Appendix 1 Photographic Log (20 photos) UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 34.0934583 N, -97.1701522 W City: Ardmore Photo No. 1 County: Carter State: Oklahoma Photo File Name: Photo 1 (DSCN5255.JPG) Orientation: North Date of Photo: 02/26/2020 Time of Photo: 11:27 AM Latitude: 34.0934583 Longitude: -97.1701522 Photographer: Kayla Woods Description: The area of concern is located on and near the S.W. Ardmore Tulip Creek Sand Unit, shown on the sign pictured here. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 34.0934583 N, -97.1701522 W City: Ardmore Photo No. 2 County: Carter State: Oklahoma Photo File Name: Photo 2 (DSCN5273.JPG) Orientation: East Date of Photo: 02/26/2020 Time of Photo: 1:05 pm Latitude: 34.0954085 Longitude: -97.1705656 Photographer: Jeanne Eckhart Description: Hickory Creek was observed during the inspection with constant and consistent bubbling seen on the surface (green arrow added to image to show the bubbling seen). Contaminants were identified by Oklahoma Department of Quality (ODEQ) representatives and were sampled at the bottom of the water column during the EPA inspection (sampling efforts seen here). The water was discolored with a red tint at this initial bubbling location. Downstream (within ~500 yards of this bubbling point), there were other bubbling points identified during the inspection in Hickory Creek. The depth of the stream here is approximately 3-5 feet. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 34.0934583 N, -97.1701522 W City: Ardmore Photo No. 3 County: Carter State: Oklahoma Photo File Name: Photo 3 (DSCN5272.JPG) Orientation: East Date of Photo: 02/26/2020 Time of Photo: 1:05 pm Latitude: 34.0954085 Longitude: -97.1705656 Photographer: Jeanne Eckhart Description: Hickory Creek was observed during the inspection with constant and consistent bubbling seen on the surface. At the identified furthest upstream bubbling location, with a calibrated YSI Pro 30 conductivity meter, I measured 34,185 milligrams per liter (mg/L) Total Dissolved Solids (TDS) in the stream at 17.2 degrees Celsius. Downstream (within ~500 yards of this bubbling point), there were other bubbling points identified during the inspection in Hickory Creek and significant discoloration in the stream from these bubbling points. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 34.0934583 N, -97.1701522 W City: Ardmore Photo No. 4 County: Carter State: Oklahoma Photo File Name: Photo 4 (DSCN5274.JPG) Orientation: East Date of Photo: 02/26/2020 Time of Photo: 1:06 pm Latitude: 34.0954085 Longitude: -97.1705656 Photographer: Jeanne Eckhart Description: Hickory Creek was observed during the inspection with constant and consistent bubbling seen on the surface, here. This image shows an upstream view of Hickory Creek from the initial bubbling location, where creek conditions can be observed. There was bed, bank, eroded features and active flowing conditions towards the south during the inspection. The creek was approximately 20-30 feet in width during the inspection. I observed facultative vegetation at this location along the banks, seen here. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 34.0934583 N, -97.1701522 W City: Ardmore Photo No. 5 County: Carter State: Oklahoma Photo File Name: Photo 5 (DSCN5275.JPG) Orientation: East Date of Photo: 02/26/2020 Time of Photo: 1:06 pm Latitude: 34.0954085 Longitude: -97.1705656 Photographer: Jeanne Eckhart Description: Hickory Creek was observed during the inspection with constant and consistent bubbling seen on the surface, here. This image shows a downstream view of Hickory Creek from the initial bubbling location, where creek conditions can be observed. There was bed, bank, eroded features and active flowing conditions towards the south during the inspection. The creek was approximately 20-30 feet in width during the inspection. I observed facultative vegetation at this location along the banks, seen here. Some slight discoloration of the water can be seen here, and further downstream was observed as well. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 34.0934583 N, -97.1701522 W City: Ardmore Photo No. 6 County: Carter State: Oklahoma Photo File Name: Photo 6 (DSCN5277.JPG) Orientation: North Date of Photo: 02/26/2020 Time of Photo: 9:24 AM Latitude: 34.0954085 Longitude: -97.1705656 Photographer: Jeanne Eckhart Description: Further downstream from the initial bubbling location (approximately 300 yards), this photo shows an upstream view of Hickory Creek where additional bubbling was observed during the inspection. A sand bar can be seen in the middle of the shallower portion of Hickory Creek at this main point of identified contamination. The water was discolored (orange and red tints) and had sheen in this area. There was bed, bank, and active flowing conditions towards the south during the inspection. The creek was approximately 20-30 feet in width and approximately 1-2 feet deep. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 34.0934583 N, -97.1701522 W City: Ardmore Photo No. 7 County: Carter State: Oklahoma Photo File Name: Photo 7 (DSCN5278.JPG) Orientation: North Date of Photo: 02/26/2020 Time of Photo: 9:24 AM Latitude: 34.0954085 Longitude: -97.1705656 Photographer: Jeanne Eckhart Description: Further downstream from the initial bubbling location (approximately 300 yards) seen in Photo 2, this photo shows a downstream view of Hickory Creek where additional bubbling was observed during the inspection. A sand bar can be seen in the middle of the shallower portion of Hickory Creek at this main point of identified contamination. The water was discolored (orange and red tints) and had sheen in this area. Seeping from the side of the creek beds were also observed at this location. There was bed, bank, and active flowing conditions towards the south in Hickory Creek during the inspection. The creek was approximately 20-30 feet in width and approximately 1-2 feet deep. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 34.0934583 N, -97.1701522 W City: Ardmore Photo No. 8 County: Carter State: Oklahoma Photo File Name: Photo 8 (DSCN5230.JPG) Orientation: North Date of Photo: 02/26/2020 Time of Photo: 9:29 AM Latitude: 34.0947063 Longitude: -97.1696044 Photographer: Jeanne Eckhart Description: At the same location Photos 6 & 7 were taken from higher up on the creek bank, this photo shows an upstream view of Hickory Creek where additional bubbling was observed. A sand bar can be seen in the middle of the shallower portion of Hickory Creek at this main point of identified contamination. The water was discolored (orange and red tints) and had sheen in this area. Seeping from the side of the creek beds were also observed at this location (western bank here). There was bed, bank, and active flowing conditions towards the south in Hickory Creek during the inspection. The creek was approximately 20-30 feet in width and approximately 1-2 feet deep. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 34.0934583 N, -97.1701522 W City: Ardmore Photo No. 9 County: Carter State: Oklahoma Photo File Name: Photo 9 (DSCN5229.JPG) Orientation: North Date of Photo: 02/26/2020 Time of Photo: 9:29 AM Latitude: 34.0947063 Longitude: -97.1696044 Photographer: Jeanne Eckhart Description: A TDS reading was taken at Photo 8's location during the inspection and measured 22,017 mg/L at 11.5 degrees Celsius. Hickory Creek was flowing south during the inspection and red coloration was affecting this portion of the stream from unidentified contaminants. I observed elevated TDS levels and a difference in water temperature here from upstream readings with elevated TDS levels. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 34.0934583 N, -97.1701522 W City: Ardmore Photo No. 10 County: Carter State: Oklahoma Photo File Name: Photo 10 (DSCN5235.JPG) Orientation: Northwest Date of Photo: 02/26/2020 Time of Photo: 9:32 AM Latitude: 34.0947063 Longitude: -97.1696044 Photographer: Jeanne Eckhart Description: Approximately 5 yards downstream from photos 8 & 9, this photo shows the western bank of Hickory Creek, where seepage and discolored fluids were observed. Sheen was observed at this location that was not vegetatively associated. No aquatic life or vegetation was observed where the contaminated fluids were present. Although, higher up on the banks of Hickory Creek, some facultative vegetation was observed. Evidence of cattle tracks can be seen here, in the creek at this point where discolored fluids and elevated TDS were observed. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 34.0934583 N, -97.1701522 W City: Ardmore Photo No. 11 County: Carter State: Oklahoma Photo File Name: Photo 11 (DSCN5241.JPG) Orientation: North Date of Photo: 02/26/2020 Time of Photo: 9:42 AM Latitude: 34.0944229 Longitude: -97.1693117 Photographer: Jeanne Eckhart Description: Approximately 10 yards downstream from Photo 10, this photo shows Hickory Creek downstream from the sand bar observed previously. I observed some bubbling at this location. The water depth was over 3 feet here and flow had merged on the backside of the sand bar, flowing south. Some fluid discoloration was also observed here. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 34.0934583 N, -97.1701522 W City: Ardmore Photo No. 12 County: Carter State: Oklahoma Photo File Name: Photo 12 (DSCN5239.JPG) Orientation: East Date of Photo: 02/26/2020 Time of Photo: 9:41 AM Latitude: 34.0944229 Longitude: -97.1693117 Photographer: Jeanne Eckhart Description: In the same portion of Hickory Creek as shown in Photo 11, the eastern bank of Hickory Creek can be seen in this image. I observed some bubbling at this location. The water depth was over 3 feet here and flow had merged on the backside of the sand bar, flowing south. Some fluid discoloration was also observed here, including on the eastern bank of Hickory Creek. Additionally, seeping from the eastern bank was observed here as well. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 34.0934583 N, -97.1701522 W City: Ardmore Photo No. 13 County: Carter State: Oklahoma Photo File Name: Photo 13 (DSCN5240.JPG) Orientation: South Date of Photo: 02/26/2020 Time of Photo: 9:41 AM Latitude: 34.0944229 Longitude: -97.1693117 Photographer: Jeanne Eckhart Description: In the same portion of Hickory Creek as shown in Photo 11, downstream on Hickory Creek can be seen in this image. I observed some bubbling at this location. The water depth was over 3 feet here and flow had merged on the backside of the sand bar, flowing south. Some fluid discoloration was also observed here. High banks, creek bed, flooding debris, and ordinary high-water marks were observed in Hickory Creek at this location. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 34.0934583 N, -97.1701522 W City: Ardmore Photo No. 14 County: Carter State: Oklahoma Photo File Name: Photo 14 (DSCN5238.JPG) Orientation: East Date of Photo: 02/26/2020 Time of Photo: 9:41 AM Latitude: 34.0944229 Longitude: -97.1693117 Photographer: Jeanne Eckhart Description: In the same portion of Hickory Creek as shown in Photos 11 - 13. With a calibrated YSI Pro 30 conductivity meter, TDS measured 31,224 mg/L at 9.8 degrees Celsius. I observed some bubbling at this location. The water depth was over 3 feet here and flow had merged on the backside of the sand bar, flowing south. Some fluid discoloration was also observed here. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 34.0934583 N, -97.1701522 W City: Ardmore Photo No. 15 County: Carter State: Oklahoma Photo File Name: Photo 15 (DSCN5257.JPG) Orientation: North Date of Photo: 02/26/2020 Time of Photo: 11:45 AM Latitude: 34.0910835 Longitude: -97.1705113 Photographer: Jeanne Eckhart Description: Approximately 0.46 miles downstream in Hickory Creek from Photo 14, an additional Hickory Creek was observed. The water was flowing north in this part of the creek (bend of creek) and then turned south. I observed large amounts of flooded debris at this location. Bed rock, ordinary highwater marks, and facultative vegetation through out the creek area was observed. I observed a slight rotten egg odor while at this location. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 34.0934583 N, -97.1701522 W City: Ardmore Photo No. 16 County: Carter State: Oklahoma Photo File Name: Photo 16 (DSCN5256.JPG) Orientation: North Date of Photo: 02/26/2020 Time of Photo: 11:45 AM Latitude: 34.0910835 Longitude: -97.1705113 Photographer: Jeanne Eckhart Description: At the same location as Photo 15, TDS measured 987 mg/L at 9.8 degrees Celsius with a calibrated YSI Pro 30 conductivity meter. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 34.0934583 N, -97.1701522 W City: Ardmore Photo No. 17 County: Carter State: Oklahoma Photo File Name: Photo 17 (DSCN5246.JPG) Orientation: North Date of Photo: 02/26/2020 Time of Photo: 10:10 AM Latitude: 34.0769717 Longitude: -97.1693446 Photographer: Jeanne Eckhart Description: Approximately 2 miles downstream in Hickory Creek from Photos 15 & 16 (approximately 2.5 miles downstream from first observed bubbling location) the creek was observed here. The water was flowing south and had a strong current. This upstream view shows a dam in place in Hickory Creek and bed rock on the downstream side of the dam. The water depth was over 5 feet deep on the upstream side of the dam and the creek was over 60 feet wide. I observed large amounts of flooded debris at this location. Bed rock, ordinary high-water marks, and facultative vegetation throughout the creek area were also observed. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 34.0934583 N, -97.1701522 W City: Ardmore Photo No. 18 County: Carter State: Oklahoma Photo File Name: Photo 18 (DSCN5250.JPG) Orientation: North Date of Photo: 02/26/2020 Time of Photo: 10:54 AM Latitude: 34.0766271 Longitude: -97.1699346 Photographer: Jeanne Eckhart Description: Upstream from the dam in Photo 17, TDS measured 913 mg/L at 10.5 degrees Celsius with a calibrated YSI Pro 30 conductivity meter. EPA also observed ODEQ take water quality grab samples from this location. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 34.0934583 N, -97.1701522 W City: Ardmore Photo No. 19 County: Carter State: Oklahoma Photo File Name: Photo 19 (DSCN5214.JPG) Orientation: North Date of Photo: 02/26/2020 Time of Photo: 8:34 AM Latitude: 34.0999706 Longitude: -97.1660551 Photographer: Jeanne Eckhart Description: This at a location upstream from the initial bubbling identified in Hickory Creek approximately 0.6 miles. This location was observed to document background, or non-affected stream conditions in Hickory Creek. There was visible bed, bank, and ordinary high-water marks seen at this location. Facultative vegetation and a defined channel were also observed here at Hickory Creek. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 34.0934583 N, -97.1701522 W City: Ardmore Photo No. 20 County: Carter State: Oklahoma Photo File Name: Photo 20 (DSCN5213.JPG) Orientation: North Date of Photo: 02/26/2020 Time of Photo: 8:32 AM Latitude: 34.0999706 Longitude: -97.1660551 Photographer: Jeanne Eckhart Description: At the same location as Photo 19, TDS measured 518 mg/L at 8.3 degrees Celsius (background).