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Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 07/06/2022 Water Clean Water Act - National Pollution Discharge Elimination System (Brine) Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: McCann Resources, Inc Bowring Lease Latitude: 36.871074, Longitude: -96.125656 Bowring, Oklahoma, 74056 2300 N Lincoln Blvd Rm 101 Oklahoma City, Oklahoma, 73105 Osage County (918) 798-4365 Mark McCann Owner/Operator mccanncompanies@yahoo.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: n/a OKU000848 n/a 211111 1311 Personnel participating in inspection: Matthew Allen EPA, Region 6ECDW Inspector EPA Lead Inspector Signature/Date Supervisor Signature/Date MATTHEW ALLEN Date: 2022.07.14 16:41:20 -05'00' Digitally signed by MATTHEW ALLEN Matthew Allen Date ANTHONY LOSTON Digitally signed by ANTHONY LOSTON DN: c=US, o=U.S. Government, ou=Environmental Protection Agency, cn=ANTHONY LOSTON, 0.9.2342.19200300.100.1.1=68001003655738 Date: 2022.07.19 11:23:27 -05'00' Anthony Loston (acting) Date 6ENFORM-019-R8.2 (02/12/2020) 1 Section I - INTRODUCTION McCann Resources, Inc / Bowring Lease Inspection Date 07/06/2022 PURPOSE OF THE INSPECTION EPA Region 6 inspector, Matthew Allen, arrived at the McCann Resources Inc, Bowring Lease, (EPA ID No. OKU000848) at 08:50 AM on 07/06/2022 for an unannounced inspection. There was no company representative present during the inspection. This was an EPA follow-up inspection in response to a National Response Center Spill Report (NRC# 1339940) which was received by EPA Region 6. EPA Inspector, Matthew Allen, previously conducted a spill inspection at the same location on 06/27/2022. The inspection was conducted by the authority of the Clean Water Act to determine compliance with Environmental Protection Agency (EPA) regulations. There was no other federal, state, or local agency representative present at the time of the inspection FACILITY DESCRIPTION EPA conducted a follow-up inspection beginning on the McCann Resources Inc, Bowring Lease, (GPS 36.871074, -96.125656) where a 2-inch diameter poly flowline carrying produced water (brine) and oil crossed an unnamed tributary. The flowline had pulled apart at a collar joint and spilled produced fluids directly into the main channel of an unnamed tributary of Mission Creek. The flowline carried fluids from the production well to the separation/storage facility (Bowring Lease tank battery). The Bowring Lease was located South of Bowring, Oklahoma, in Osage County. Section II - OBSERVATIONS During the inspection, I observed a "background" Total Dissolved Solids (TDS) field reading of 154 mg/L (GPS 36.875613, -96.129601) approximately 2,650 feet upstream from the Point of Entry POE, this field reading was documented in Photo No. 27 of Appendix 1 / photo log which is included in this report. The background TDS field reading, and all other field readings observed and documented during the inspection were taken with a properly calibrated YSI Pro 30 conductivity meter. I observed the highest elevated TDS field reading of the inspection, 45,486 mg/L, in the main channel of the unnamed tributary at the POE, the field reading was documented in Photo No. 1. The POE and receiving pool of water were documented in Photo No. 2. I observed oil absorbent pads along the bank of the tributary as well as floating on the surface of the tributary. The oil absorbent pads were located approximately 25 feet downstream from the POE and were documented in Photo No. 3. I observed an elevated TDS field reading of 3,450 mg/L in the main channel of the impacted tributary, approximately 75 feet downstream (GPS 36.870960, -96.125361) from the POE, this was documented in Photo No. 4. I observed an elevated TDS field reading of 2,851 mg/L approximately 150 feet downstream (GPS 36.871103, -96.125060). I also observed oil absorbent pads and a floating, oil absorbent containment boom on the impacted tributary at the same location, observations from this location were documented in Photos No. 5 & 6. 2 McCann Resources, Inc / Bowring Lease Inspection Date 07/06/2022 Approximately 550 feet downstream (GPS 36.871013, -96.123746) from the POE, I observed an elevated TDS field reading of 1,696 mg/L, which was documented in Photo No. 7. Approximately 1,650 feet downstream (GPS 36.870223, -96.122420) from the POE, I observed an elevated TDS field reading of 1,820 mg/L, which was documented in Photo No. 9. I observed an elevated TDS field reading of 1,002 mg/L approximately 3,000 feet downstream (GPS 36.868564, -96.121399) which was documented in Photo No. 12. I observed an elevated TDS field reading of 640 mg/L approximately 3,950 feet downstream (36.867486, -96.119518) from the POE, which is documented in Photo No. 15. Approximately 4,550 feet downstream (GPS 36.866729, -96.119610) from the POE, I observed an elevated TDS field reading of 543 mg/L, which was documented in Photo No. 17. I observed a TDS field reading of 231.4 mg/L in Mission Creek at the confluence with the impacted tributary, which is documented in Photo No. 20. I observed the confluence of the impacted tributary and Mission Creek, a detailed description of the confluence was documented in the photo log, Photos No. 19, 21, 22, 23, and 24. I observed a "background" TDS field reading of 216.0 mg/L in Mission Creek approximately 50 feet upstream and prior to the confluence with the impacted tributary, which is documented in Photo No. 25. Section III - AREAS OF CONCERN EPA Region 6 inspector conducted a conference call with Mark McCann which began at 1:52 PM on 07/06/2022. I conveyed my primary area of concern which was the removal of all water from the pool of water at the Point of Entry into the unnamed tributary which measured 45,486 mg/L during the inspection. I also conveyed the need to continue removing waters with elevated TDS from areas downstream from the POE. I requested Mr. McCann remove a small pool of trapped oil which was located near the POE on a small gravel bar and continue to clean areas of oil staining around the POE. Section IV - FOLLOW UP EPA Inspector received no additional information from McCann Resources, Inc after the conclusion of the phone conference on 07/06/2022. EPA Inspector will continue conducting follow-up inspections as needed until satisfactory results are achieved. Section V - LIST OF APPENDICES Appendix 1 - Photo Log - 20 photos taken 07/06/2022 3 McCann Resources, Inc / Bowring Lease (CWA) Inspection Date: 07/06/2022 Appendix 1 Photograph Log 28 Phot UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.871074, -96.125656 City: Bowring Photo No. 1 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0626 Orientation: n/a Date of Photo: 07/06/2022 Time of Photo: 08:56 AM Latitude: 36.871067 Longitude: -96.125678 Photographer: Matthew Allen Description: This was an elevated Total Dissolved Solids (TDS) field reading of 45,486 mg/L taken at the Release Point / Point of Entry (POE) in the pool where the produced water (brine and oil) entered the unnamed tributary of Mission Creek. This field reading and all others included in this report/photo log were taken with a properly calibrated YSI Pro 30 conductivity meter. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.871074, -96.125656 City: Bowring Photo No. 2 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0627 Orientation: W Date of Photo: 07/06/2022 Time of Photo: 9:01 AM Latitude: 36.871067 Longitude: -96.125678 Photographer: Matthew Allen Description: This was a photo taken at the Release Point / POE, with a view looking toward the west (upstream). The pool of water pictured above was the location of the highest observed TDS field reading measuring 45,486 mg/L. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.871074, -96.125656 City: Bowring Photo No. 3 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0628 Orientation: E Date of Photo: 07/06/2022 Time of Photo: 9:02 AM Latitude: 36.36.871067 Longitude: -96.125678 Photographer: Matthew Allen Description: This was a photo taken from the Release Point/POE, with a view looking downstream. Oil absorbent pads were observed on the water and bank. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.871074, -96.125656 City: Bowring Photo No. 4 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0629 Orientation: n/a Date of Photo: 07/06/2022 Time of Photo: 9:06 AM Latitude: 36.870960 Longitude: -96.125361 Photographer: Matthew Allen Description: This was an elevated TDS field reading of 3,450 mg/L taken in the main channel of the impacted tributary approximately 75 feet downstream from the POE. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.871074, -96.125656 City: Bowring Photo No. 5 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0630 Orientation: n/a Date of Photo: 07/06/2022 Time of Photo: 9:11 AM Latitude: 36.871103 Longitude: -96.125060 Photographer: Matthew Allen Description: This was an elevated TDS field reading of 2,851 mg/L taken in the main channel of the impacted tributary approximately 150 feet downstream from the POE. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.871074, -96.125656 City: Bowring Photo No. 6 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0631 Orientation: E Date of Photo: 07/06/2022 Time of Photo: 9:12 AM Latitude: 36.871103 Longitude: -96.125060 Photographer: Matthew Allen Description: This was a photo of oil absorbent pads floating on the surface of the impacted tributary. A floating, oil absorbent containment boom was also present at the location. There was no oil present in the pictured area at the time of the inspection. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.871074, -96.125656 City: Bowring Photo No. 7 County/Parish: Osage State: Oklahoma Photo File Name: DSCN Orientation: n/a Date of Photo: 07/06/2022 Time of Photo: 9:17 AM Latitude: 36.871013 Longitude: -96.123746 Photographer: Matthew Allen Description: This was an elevated TDS field readings of 1,696 mg/L taken in the main channel of the tributary approximately 550 feet downstream from the POE. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.871074, -96.125656 City: Bowring Photo No. 8 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0633 Orientation: NE Date of Photo: 07/06/2022 Time of Photo: 9:19 AM Latitude: 36.871013 Longitude: -96.123746 Photographer: Matthew Allen Description: This was the location where the TDS field reading from Photo No. 7 was taken. This photo provided an accurate representation of the bed and bank features along this section of the impacted tributary. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.871074, -96.125656 City: Bowring Photo No. 9 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0634 Orientation: n/a Date of Photo: 07/06/2022 Time of Photo: 9:24 AM Latitude: 36.870223 Longitude: -96.122420 Photographer: Matthew Allen Description: This was an elevated TDS field reading taken in the main channel of the impacted tributary approximately 1,650 feet downstream from the POE measuring 1,820 mg/L. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.871074, -96.125656 City: Bowring Photo No. 10 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0635 Orientation: NW Date of Photo: 07/06/2022 Time of Photo: 9:25 AM Latitude: 36.870223 Longitude: -96.122420 Photographer: Matthew Allen Description: This was a photo documenting the bed and bank characteristics of the impacted tributary with a view looking NW/upstream from the location. This photo was taken at the same location as Photo No. 9. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.871074, -96.125656 City: Bowring Photo No. 11 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0636 Orientation: SE Date of Photo: 07/06/2022 Time of Photo: 9:26 AM Latitude: 36.870223 Longitude: -96.122420 Photographer: Matthew Allen Description: This was a photo documenting the bed and bank characteristics of the impacted tributary with a view looking SE/downstream from the location. This photo was taken at the same location as Photo No. 9. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.871074, -96.125656 City: Bowring Photo No. 12 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0637 Orientation: n/a Date of Photo: 07/06/2022 Time of Photo: 9:35 AM Latitude: 36.868564 Longitude: -96.121399 Photographer: Matthew Allen Description: This was an elevated TDS field reading of 1,002 mg/L, taken in the main channel of the impacted tributary approximately 3,000 feet downstream from the POE. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.871074, -96.125656 City: Bowring Photo No. 13 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0638 Orientation: SE Date of Photo: 07/06/2022 Time of Photo: 9:37 AM Latitude: 36.868564 Longitude: -96.121399 Photographer: Matthew Allen Description: This was a photo documenting the bed and bank features where the TDS field reading from No. 12 was taken. This photo was taken with a view to the southeast/downstream. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.871074, -96.125656 City: Bowring Photo No. 14 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0639 Orientation: SW Date of Photo: 07/06/2022 Time of Photo: 9:37 AM Latitude: 36.868564 Longitude: -96.121399 Photographer: Matthew Allen Description: This was a photo documenting the bed and bank features where the TDS field reading from No. 12 was taken. This photo was taken with a view to the southwest/upstream. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.871074, -96.125656 City: Bowring Photo No. 15 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0640 Orientation: n/a Date of Photo: 07/06/2022 Time of Photo: 9:46 AM Latitude: 36.867486 Longitude: -96.119518 Photographer: Matthew Allen Description: This was an elevated TDS field reading of 640 mg/L taken approximately 3,950 feet downstream from the POE in the main channel of the impacted tributary. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.871074, -96.125656 City: Bowring Photo No. 16 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0641 Orientation: SE Date of Photo: 07/06/2022 Time of Photo: 9:48 AM Latitude: 36.867486 Longitude: -96.119518 Photographer: Matthew Allen Description: This was a photo documenting the bed and bank features where the TDS field reading from No. 15 was taken. This photo was taken with a view to the southeast/downstream. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.871074, -96.125656 City: Bowring Photo No. 17 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0642 Orientation: n/a Date of Photo: 07/06/2022 Time of Photo: 9:55 AM Latitude: 36.866729 Longitude: -96.119610 Photographer: Matthew Allen Description: This was an elevated TDS field reading of 543 mg/L taken approximately 4,550 feet downstream from the POE in the main channel of the impacted tributary. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.871074, -96.125656 City: Bowring Photo No. 18 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0643 Orientation: SE Date of Photo: 07/06/2022 Time of Photo: 9:56 AM Latitude: 36.866729 Longitude: -96.119610 Photographer: Matthew Allen Description: This was a photo showing the bed and bank features of the impacted tributary, this photo was taken approximately 150 feet upstream along the impacted tributary, prior to the confluence with Mission Creek. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.871074, -96.125656 City: Bowring Photo No. 19 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0644 Orientation: S Date of Photo: 07/06/2022 Time of Photo: 9:59 AM Latitude: 36.866551 Longitude: -96.119366 Photographer: Matthew Allen Description: This was a photo of the main channel of the impacted channel as it connected to Mission Creek. Mission Creek was flowing from right to left or west to east in the photo. At the time of the inspection, there was no surface flow from the impacted tributary into Mission Creek. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.871074, -96.125656 City: Bowring Photo No. 20 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0645 Orientation: n/a Date of Photo: 07/06/2022 Time of Photo: 10:03 AM Latitude: 36.866414 Longitude: -96.119422 Photographer: Matthew Allen Description: This was a TDS field reading of 231.4 mg/L taken in Mission Creek at the mouth/confluence of the impacted tributary. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.871074, -96.125656 City: Bowring Photo No. 21 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0646 Orientation: SW Date of Photo: 07/06/2022 Time of Photo: 10:07 AM Latitude: 36.866414 Longitude: -96.119422 Photographer: Matthew Allen Description: This is a view to the southwest, which looked upstream along Mission Creek from the confluence of Mission Creek and the impacted tributary. The mouth of the impacted tributary was in the lower right-hand corner of the photo. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.871074, -96.125656 City: Bowring Photo No. 22 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0647 Orientation: SE Date of Photo: 07/06/2022 Time of Photo: 10:08 AM Latitude: 36.866414 Longitude: -96.119422 Photographer: Matthew Allen Description: This is a view to the southeast, which looked downstream along Mission Creek from the confluence of Mission Creek and the impacted tributary. The mouth of the impacted tributary was immediately behind the photographer at the time of the photo. Mission Creek flowed from the lower right corner toward the upper left corner in the photo, or generally toward the east. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.871074, -96.125656 City: Bowring Photo No. 23 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0648 Orientation: W Date of Photo: 07/06/2022 Time of Photo: 10:12 AM Latitude: 36.865997 Longitude: -96.118819 Photographer: Matthew Allen Description: This was a photo taken approximately 250 feet downstream from the confluence of Mission Creek and the impacted tributary. The photo was taken from the south bank of Mission Creek looking west toward the mouth of the impacted tributary. The mouth of the impacted tributary was located below the arrow in the photo. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.871074, -96.125656 City: Bowring Photo No. 24 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0649 Orientation: NW Date of Photo: 07/06/2022 Time of Photo: 10:16 AM Latitude: 36.866333 Estimated Longitude: -96.119494 Estimated Photographer: Matthew Allen Description: This was a photo taken from the south bank of Mission Creek with a view looking to the northwest. This was a photo showing the confluence of the impacted tributary and Mission Creek. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.871074, -96.125656 City: Bowring Photo No. 25 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0650 Orientation: n/a Date of Photo: 07/06/2022 Time of Photo: 10:18 AM Latitude: 36.866373 Longitude: -96.119613 Photographer: Matthew Allen Description: This was a TDS field reading of 216.0 mg/L taken in the main channel of Mission Creek, approximately 50 feet upstream, prior to the confluence with the impacted tributary. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.871074, -96.125656 City: Bowring Photo No. 26 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0651 Orientation: SW Date of Photo: 07/06/2022 Time of Photo: 10:19 AM Latitude: 36.866373 Longitude: -96.119613 Photographer: Matthew Allen Description: This was the upstream pool along Mission Creek where Photo No. 25 and a TDS field reading of 216.0 mg/L were taken. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.871074, -96.125656 City: Bowring Photo No. 27 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0652 Orientation: n/a Date of Photo: 07/06/2022 Time of Photo: 10:40 AM Latitude: 36.875613 Longitude: -96.129601 Photographer: Matthew Allen Description: This was a TDS field reading taken approximately 2,650 feet upstream from the POE along the impacted tributary, where the impacted tributary crossed under Highway 10. This TDS reading should be used to assess "background" TDS levels for the impacted tributary. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.871074, -96.125656 City: Bowring Photo No. 28 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0653 Orientation: W Date of Photo: 07/06/2022 Time of Photo: 10:42 Latitude: 36.875613 Longitude: -96.129601 Photographer: Matthew Allen Description: This was a photo documenting the location of Photo No. 27. This was the location where the impacted tributary crossed through a culver under Highway 10, approximately 2,650 feet upstream from the POE.