Document badxzpqaXjj1RevEp9DXq3BN6

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 01/30/2025 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: SMI Operating Company, LLC Gregory, JD (B-5) SWD Tank Battery In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.245615, -92.536701. El Dorado, AR, 71730 190 Vestal Loop Strong, AR 71765 Union County 870-951-0136 Jacob Agerton Owner / Operator agertonjay@icloud.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: N/A ARU002280 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: 2025.04.03 12:45:08 -05'00' Date JEANNE ECKHART Date: 2025.04.03 13:06:11 -05'00' Digitally signed by JEANNE ECKHART Jeanne Eckhart Date 6ENFORM-019-R8.2 (02/12/2020) 1 SMI Operating Company, LLC / Gregory, JD (B-5) SWD Tank Battery (ARU002280 / CWA) Inspection Date 01/30/2025 Section I - INTRODUCTION PURPOSE OF THE INSPECTION EPA Region 6 inspectors Kerri McCabe (lead) and Michael Blaha arrived at the SMI Operating Company, LLC / Gregory, JD (B-5) SWD Tank Battery ("facility"), located from Highway 63 E, then Armer Rd, left onto an oil lease road at 33.245615, -92.536701 at 1000 on 01/30/2025 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. FACILITY DESCRIPTION EPA conducted an inspection on the SMI Operating Company, LLC / Gregory, JD (B-5) Tank Battery facility, which contained one (1) storage tank for saltwater and one (1) Class II saltwater disposal (SWD) injection well. EPA did not observe signage at the facility. Communication with Mr. Glen Owen, Inspector Supervisor with the Arkansas Oil and Gas Commission (AOGC), on 01/30/2025 confirmed that SMI Operating Company, LLC is the owner of the facility. Map 1. Aerial imagery (Google Earth dated 03/11/2024) of the SMI Operating Company, LLC / Gregory, JD (B-5) Tank Battery. 2 SMI Operating Company, LLC / Gregory, JD (B-5) SWD Tank Battery (ARU002280 / CWA) Inspection Date 01/30/2025 Section II - OBSERVATIONS I observed the SMI Operating Company, LLC / Gregory, JD (B-5) Tank Battery facility and associated secondary containment, storage tank, and Class II SWD well; see Appendix 1 (Photographs Log), see Photos No. 1 through No. 3. For additional GPS location and photo metadata, see Appendix 1. I observed the sump area of the secondary containment, see Photos No. 4 and No. 5. I observed the drainpipe and cap for the secondary containment, see Photos No. 6 and No. 7. I observed an elevated total dissolved solid (TDS) reading of 2,065 mg/L (initial) in a pool of water downstream of the secondary containment drainpipe, see Photo No. 8. I observed dead vegetation downstream of the TDS reading from Photo No. 8, see Photos No. 9 and No. 10. I observed an elevated TDS reading of 6,438 mg/L at the point of entry (POE) into a wetland, see Photo No. 11. I observed the conditions of the ephemeral conveyance upstream and downstream of the TDS reading referenced in Photo No. 11, see Photos No. 12 and No. 13. I observed residual or historic loose crude oil along the banks of the ephemeral conveyance leading to the wetland, see Photo No. 14. I observed an elevated TDS reading of 5,908 mg/L (mid-stream) in the ephemeral conveyance upstream of the wetland, see Photo No. 15. I observed the conditions of the ephemeral conveyance upstream and downstream of the TDS reading referenced in Photo No. 15, see Photos No. 16 and No. 17. I observed a new flowline along the discharge flowline with dead vegetation within the area, see Photos No. 18 through No. 20. I observed an elevated TDS reading of 1,847 mg/L (upstream) in a pool of water in the flowpath of the flowline, see Photo No. 21. I observed the conditions of the flowpath upstream and downstream of the TDS reading referenced in Photos No. 22 and No. 23. I observed dead vegetation along the flowpath leading up to the facility, see Photos No. 24 and 25. I observed an elevated TDS reading of 3,395 mg/L in a pool of water in the vicinity of the facility, see Photo No. 26. 3 SMI Operating Company, LLC / Gregory, JD (B-5) SWD Tank Battery (ARU002280 / CWA) Inspection Date 01/30/2025 I observed the conditions of the flowpath upstream and downstream of the TDS reading referenced in Photo No. 26, see Photos No. 27 and No. 28. I observed the new flowline connected to the pump for the SWD injection well, see Photo No. 29. Section III - AREAS OF CONCERN No closing conference was held due to no personnel with SMI Operating Company, LLC being present during the inspection. Areas of concern at the time of the inspection include the following: No updated signage at the facility, Active leak from the drainpipe due to broken/worn cap, Residual or historic loose crude oil along discharge flowpath, and Elevated TDS readings along the discharge flowpath into an ephemeral conveyance and wetlands. Section IV - FOLLOW UP Inspector will conduct follow-up phone calls and emails with the company representative(s) over the coming weeks and months to ensure areas of concern are properly addressed. Section V - LIST OF APPENDICES Appendix 1 - Photograph Log - 29 photos taken 01/30/2025. 4 SMI Operating Company, LLC / Gregory, JD (B-5) SWD Tank Battery (ARU002280 / CWA) Inspection Date 01/30/2025 Appendix 1 Photograph Log 29 Photos UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.245615, 92.536701. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0542 Orientation: 193 SSW Date of Photo: 01/30/2025 Time of Photo: 1014 Latitude: 33.245650 Longitude: -92.536650 Photographer: Kerri McCabe Description: Looking SSW, this photo shows basic identification on the saltwater storage tank. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.245615, 92.536701. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0543 Orientation: 57 ENE Date of Photo: 01/30/2025 Time of Photo: 1014 Latitude: 33.245583 Longitude: -92.536717 Photographer: Kerri McCabe Description: Looking ENE, this photo shows an overview of the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.245615, 92.536701. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0544 Orientation: 53 NE Date of Photo: 01/30/2025 Time of Photo: 1014 Latitude: 33.245617 Longitude: -92.536650 Photographer: Kerri McCabe Description: Looking NE, this photo shows the Class II saltwater disposal (SWD) injection well and pump. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.245615, 92.536701. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0546 Orientation: 14 NNE Date of Photo: 01/30/2025 Time of Photo: 1015 Latitude: 33.245700 Longitude: -92.536600 Photographer: Kerri McCabe Description: Looking NNE, this photo shows the sump area of the secondary containment with tank bottom applied to the berm. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.245615, 92.536701. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0548 Orientation: 106 ESE Date of Photo: 01/30/2025 Time of Photo: 1016 Latitude: 33.245767 Longitude: -92.536650 Photographer: Kerri McCabe Description: Looking ESE, this photo shows an additional view of the sump area of the secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.245615, 92.536701. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0549 Orientation: 73 ENE Date of Photo: 01/30/2025 Time of Photo: 1016 Latitude: 33.245767 Longitude: -92.536622 Photographer: Kerri McCabe Description: Looking ENE, this photo shows the drainpipe for the secondary containment with a pool of water below the pipe. A sheen and rusty color were noted in the pool. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.245615, 92.536701. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0550 Orientation: 81 E Date of Photo: 01/30/2025 Time of Photo: 1016 Latitude: 33.245744 Longitude: -92.536617 Photographer: Kerri McCabe Description: Looking E, this photo shows a closeup of the worn drainpipe cap that was actively leaking during the inspection. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.245615, 92.536701. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0552 Orientation: 0 N Date of Photo: 01/30/2025 Time of Photo: 1017 Latitude: 33.245683 Longitude: -92.536467 Photographer: Kerri McCabe Description: Looking N, this photo shows an elevated Total Dissolved Solid (TDS) reading of 2,065 mg/L (initial) in a pool of water downstream of the drainpipe. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 Location: In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.245615, 92.536701. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0553 Orientation: 68 ENE Date of Photo: 01/30/2025 Time of Photo: 1017 Latitude: 33.245717 Longitude: -92.536550 Photographer: Kerri McCabe Description: Looking ENE, this photo shows the flowpath for the drainpipe and downstream of the TDS reading referenced in No. 8. Directional arrows added for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 10 Location: In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.245615, 92.536701. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0555 Orientation: 85 E Date of Photo: 01/30/2025 Time of Photo: 1017 Latitude: 33.245733 Longitude: -92.536433 Photographer: Kerri McCabe Description: Looking E, this photo shows an additional view of the flowpath from the drainpipe. Dead vegetation was noted along the flowpath. Directional arrows added for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 11 Location: In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.245615, 92.536701. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0556 Orientation: 24 NNE Date of Photo: 01/30/2025 Time of Photo: 1025 Latitude: 33.245000 Longitude: -92.536083 Photographer: Kerri McCabe Description: Looking NNE, this photo shows an elevated TDS reading of 6,438 mg/L at the point of entry (POE) into a wetland. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 12 Location: In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.245615, 92.536701. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0557 Orientation: 48 NE Date of Photo: 01/30/2025 Time of Photo: 1025 Latitude: 33.244967 Longitude: -92.536050 Photographer: Kerri McCabe Description: Looking NE, this photo shows the upstream characteristics of the ephemeral conveyance from Photo No. 11. Directional arrows added for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 13 Location: In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.245615, 92.536701. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0558 Orientation: 142 SE Date of Photo: 01/30/2025 Time of Photo: 1025 Latitude: 33.244976 Longitude: -92.536050 Photographer: Kerri McCabe Description: Looking SE, this photo shows the downstream characteristics of the ephemeral conveyance from Photo No. 11. Directional arrows added for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 14 Location: In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.245615, 92.536701. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0559 Orientation: 41 NE Date of Photo: 01/30/2025 Time of Photo: 1026 Latitude: 33.245150 Longitude: -92.536117 Photographer: Kerri McCabe Description: Looking NE, this photo shows residual or historic loose crude oil along the banks of the ephemeral conveyance. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 15 Location: In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.245615, 92.536701. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0562 Orientation: 44 NE Date of Photo: 01/30/2025 Time of Photo: 1027 Latitude: 33.245249 Longitude: -92.536034 Photographer: Kerri McCabe Description: Looking NE, this photo shows an elevated TDS reading of 5,908 mg/L (mid-stream) for the ephemeral conveyance. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 16 Location: In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.245615, 92.536701. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0563 Orientation: 59 ENE Date of Photo: 01/30/2025 Time of Photo: 1028 Latitude: 33.245267 Longitude: -92.536067 Photographer: Kerri McCabe Description: Looking ENE, this photo shows the upstream characteristics of the ephemeral conveyance from Photo No. 15. Directional arrows added for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 17 Location: In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.245615, 92.536701. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0564 Orientation: 161 SSE Date of Photo: 01/30/2025 Time of Photo: 1028 Latitude: 33.245282 Longitude: -92.536067 Photographer: Kerri McCabe Description: Looking SSE, this photo shows the downstream characteristics of the ephemeral conveyance from Photo No. 15. Directional arrows added for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 18 Location: In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.245615, 92.536701. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0566 Orientation: 165 SSE Date of Photo: 01/30/2025 Time of Photo: 1030 Latitude: 33.245783 Longitude: -92.535967 Photographer: Kerri McCabe Description: Looking SSE, this photo shows a large area of dead vegetation with a new flowline within the area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 19 Location: In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.245615, 92.536701. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0567 Orientation: 331 NNW Date of Photo: 01/30/2025 Time of Photo: 1030 Latitude: 33.245733 Longitude: -92.536033 Photographer: Kerri McCabe Description: Looking NNW, this photo shows an additional view of the flowline in Photo No. 18. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 20 Location: In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.245615, 92.536701. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0568 Orientation: 299 WNW Date of Photo: 01/30/2025 Time of Photo: 1030 Latitude: 33.245783 Longitude: -92.536150 Photographer: Kerri McCabe Description: Looking WNW, this photo shows an additional view of the flowline in Photo No. 18. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 21 Location: In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.245615, 92.536701. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0569 Orientation: 60 ENE Date of Photo: 01/30/2025 Time of Photo: 1030 Latitude: 33.245772 Longitude: -92.536150 Photographer: Kerri McCabe Description: Looking ENE, this photo shows an elevated TDS reading of 1,847 mg/L from a pool of water located within the flowpath. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 22 Location: In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.245615, 92.536701. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0570 Orientation: 295 WNW Date of Photo: 01/30/2025 Time of Photo: 1031 Latitude: 33.245772 Longitude: -92.536150 Photographer: Kerri McCabe Description: Looking WNW, this photo shows the upstream characteristics of the flowpath from Photo No. 21. Directional arrows added for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 23 Location: In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.245615, 92.536701. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0571 Orientation: 91 E Date of Photo: 01/30/2025 Time of Photo: 1031 Latitude: 33.245772 Longitude: -92.536150 Photographer: Kerri McCabe Description: Looking E, this photo shows the downstream characteristics of the flowpath from Photo No. 21. Directional arrows added for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 24 Location: In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.245615, 92.536701. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0572 Orientation: 269 W Date of Photo: 01/30/2025 Time of Photo: 1031 Latitude: 33.245767 Longitude: -92.536173 Photographer: Kerri McCabe Description: Looking W, this photo shows the new flowline and dead vegetation along the flowpath near the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 25 Location: In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.245615, 92.536701. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0574 Orientation: 259 W Date of Photo: 01/30/2025 Time of Photo: 1031 Latitude: 33.245817 Longitude: -92.536467 Photographer: Kerri McCabe Description: Looking W, this photo shows the drainpipe and dead vegetation near the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 26 Location: In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.245615, 92.536701. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0575 Orientation: 43 NE Date of Photo: 01/30/2025 Time of Photo: 1032 Latitude: 33.245830 Longitude: -92.536467 Photographer: Kerri McCabe Description: Looking NE, this photo shows an elevated TDS reading of 3,395 mg/L in a pool of water directly downstream of the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 27 Location: In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.245615, 92.536701. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0576 Orientation: 307 NW Date of Photo: 01/30/2025 Time of Photo: 1032 Latitude: 33.245817 Longitude: -92.536450 Photographer: Kerri McCabe Description: Looking NW, this photo shows the upstream characteristics of the flowpath from Photo No. 26. Directional arrows added for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 28 Location: In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.245615, 92.536701. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0577 Orientation: 72 ENE Date of Photo: 01/30/2025 Time of Photo: 1032 Latitude: 33.245767 Longitude: -92.536533 Photographer: Kerri McCabe Description: Looking ENE, this photo shows the downstream characteristics of the flowpath from Photo No. 26. Directional arrows added for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 29 Location: In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.245615, 92.536701. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0578 Orientation: 315 NW Date of Photo: 01/30/2025 Time of Photo: 1033 Latitude: 33.245633 Longitude: -92.536667 Photographer: Kerri McCabe Description: Looking NW, this photo shows the new flowline connected to the pump for the SWD injection well.