Document emqXG6DOoka9qexGgYQyMVwpG

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 09/08/2022 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: Northcote Cleveland LLC Osage B Lease Latitude: 36.259597, Longitude: -96.225672 Prue, Oklahoma, 74060 701 S Eighth St Ponca City, Oklahoma, 74601 Osage County 580-304-1193 Cody Mather Owner/Operator Cody_mather@hotmail.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: n/a OKU000856 n/a 211111 1311 Personnel participating in inspection: Matthew Allen EPA, Region 6ECDW Chris Laviolette Osage Nation DNR Cody Mather Northcote Cleveland, LLC Inspector Inspector Owner/Operator EPA Lead Inspector Signature/Date Supervisor Signature/Date MATTHEW ALLEN Digitally signed by MATTHEW ALLEN DN: c=US, o=U.S. Government, ou=Environmental Protection Agency, cn=MATTHEW ALLEN, 0.9.2342.19200300.100.1.1=68001004162907 Date: 2022.09.28 14:45:19 -05'00' Matthew Allen Date JEANNE ECKHART Date: 2022.10.05 09:06:45 -05'00' Digitally signed by JEANNE ECKHART Jeanne Eckhart (acting) Date 6ENFORM-019-R8.2 (02/12/2020) 1 Section I - INTRODUCTION Northcote Cleveland, LLC/ Osage B Lease Inspection Date 09/08/2022 PURPOSE OF THE INSPECTION EPA Region 6 inspector Matthew Allen arrived at the Northcote Cleveland, LLC, Osage B Lease (EPA ID No. OKU000856), at 12:05 PM on 09/08/2022 for an announced follow up inspection. Cody Mather, owner/operator representing Northcote Cleveland, LLC was present and participated during the inspection. This was a follow up inspection, the original spill inspection was conducted by EPA Inspector, Matthew Allen on 09/03/2022 in response to a spill notification (NRC# 1346621) received from Bureau of Indian Affairs (BIA), Osage Agency, inspector, Jeff McGuire. The inspection was conducted by the authority of the Clean Water Act to determine compliance with Environmental Protection Agency (EPA) regulations. Osage Nation Department of Natural Resources (Osage DNR), Spill Prevention Control and Countermeasure (SPCC) inspector, Chris Laviolette, accepted an invitation to participate during the inspection. There were no other federal, tribal, state, or local agency representatives present at the time of the inspection. FACILITY DESCRIPTION EPA conducted a follow up inspection on the Northcote Cleveland, LLC, Osage B Lease. The spill originated from a 2-inch diameter poly production flowline which transported produced water (oil and saltwater) from the producing well to the oil separation/storage facility (tank battery). The Osage B Lease was located north of New Prue Road, east of the confluence of Mud Creek into Keystone Lake, in Osage County, Oklahoma. Section II - OBSERVATIONS Initial observations confirmed there had been no cleanup or remediation efforts completed at or near the release point of the spill, there was also no change observed along the flowpath from the release point to the Point of Entry (POE) from the initial spill inspection. During the inspection I observed an elevated TDS field reading of 80,852 mg/L at the POE into the impacted tributary which is documented in Appendix 1 (photo log) photo No. 1 (GPS 36.259417, -96.226174). A few minutes after observing the elevated TDS reading at the POE, I observed cleanup crews use a vacuum truck to remove the impacted water from the tributary, the start of that operation is evidenced in photo No. 3. I observed floating, oil absorbent booms on the impacted tributary. These booms were located on a pool of water which was covered with oil at the time of the initial inspection, the operator had made significant progress in removing oil from the impacted tributary at this location. Oil staining on the vegetation and along the banks of the tributary was still prominent at the time of the inspection. I also observed an elevated TDS field reading of 10,145 mg/L TDS at the same location. I conveyed the need to remove the impacted water from the tributary to the operator. All these impacts were documented in photos 4, 5, 6, and 7. 2 Northcote Cleveland, LLC/ Osage B Lease Inspection Date 09/08/2022 I observed oil floating on the surface of the tributary, oil staining on the rocks, vegetation, and banks. The white powdery substance observed was identified by the operator as "Clean B" an industrial absorbent. These impacts were documented in photo No. 8. I observed high water marks in the form of oil-stained vegetation as the inspection moved downstream. I also observed significant sections of the tributary where the impacted water and free-floating oil had been removed from the tributary. These observations are documented in photos 9, 10, 11, and 12. I observed a temporary containment dam at (GPS 36.261170, -96.229526) which is documented in photo 14. This dam was not present during the initial inspection conducted 09/03/2022. I observed an ACME Environmental employee power washing oil stains from the streambed and rocks along the impacted tributary (see photo 15). At the same location I observed a partial bag of "Clean B", the industrial absorbent which was observed having been applied at another location along the impacted tributary (photo 16). I also observed the power washing rig which was being used to clean oil stains from the impacted tributary (photo 17). I observed a section of the impacted tributary where power washing had already occurred, there was no oil staining present in this area at the time of the inspection. This area had been sufficiently cleaned. I observed an elevated TDS field reading of 2,299 mg/L (photo 19) taken along the impacted tributary. While this was an elevated reading, it shows significant improvement over the initial readings observed on 09/03/2022. The operator was instructed to empty this pool of water from the impacted tributary. I observed an elevated TDS field reading of 854 mg/L taken in the last pool of water along the impacted tributary before it entered the waters of Mud Creek/Keystone Lake. I observed oil on the pool of water as well as oil staining on the rocks and vegetation around the pool. At the time of the inspection, this area had not been impacted by cleanup activities. These observations were documented in photos 20 and 21. I observed floating oil containment booms and oil absorbent booms installed on Mud Creek/Keystone Lake. At the time of the inspection the booms had the oil captured primarily along the rip rap at the base of the earthen bridge which carried New Prue Road across Mud Creek/Keystone Lake. (See photos 22 and 23). I observed trash sacks containing oil-soaked debris and oil-soaked cleanup materials near the shoreline along Mud Creek/Keystone Lake (photo 26). I observed oil trapped against the shore by the containment and absorbent booms (photo 27). This area had not yet been cleaned. ACME Environmental cleanup personnel can also be seen working in the photo. The rip rap along the right side of the picture is located at the base of the earthen bridge which carried New Prue Road across Mud Creek/Keystone Lake. I observed additional booms and cleanup materials available for use at the cleanup area (photo 28). (GPS 36.258135, -96.233195). 3 Northcote Cleveland, LLC/ Osage B Lease Inspection Date 09/08/2022 Each of the TDS field readings taken throughout the inspection were taken with a properly calibrated YSI Pro 30 conductivity meter. All photos referenced in this narrative were included as part of Appendix 1 (photo log) which is attached to this report. Additional photos, GPS location information, time and narrative information are also included in the 28 photos of Appendix 1. Section III - AREAS OF CONCERN The primary areas of concern included oil and saltwater impacted waters which still need to be removed from the impacted tributary. Additional areas of concern include oil impacted streambed, rocks, and vegetation along the impacted tributary. The final area of concern was the need to clean the flowpath from the release point to the POE into the impacted tributary. Section IV - FOLLOW UP No additional information was received by EPA after exiting the Facility on 09/08/2022. Section V - LIST OF APPENDICES Appendix 1 - Photo Log - 28 photos taken 09/08/2022 4 Northcote Cleveland LLC/ Osage B Lease (CWA) Inspection Date: 09/08/2022 Appendix 1 Photograph Log 28 Photos UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 1 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0736 Orientation: n/a Date of Photo: 09/08/2022 Time of Photo: 12:13 PM Latitude: 36.259417 Longitude: -96.226174 Photographer: Matthew Allen Description: This was an elevated TDS field reading of 80,852 mg/L taken at the Point of Entry (POE) into the impacted, unnamed tributary. Cleanup crews removed this water from the tributary immediately after this reading was observed. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 2 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0737 Orientation: SW Date of Photo: 09/08/2022 Time of Photo: 12:14 PM Latitude: 36.259417 Longitude: -96.226174 Photographer: Matthew Allen Description: This was a view looking from the POE downstream or southwest. The high-water mark is evidenced by the dark brown band of oil stained vegetation along the right hand bank of the tributary. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 3 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0738 Orientation: N Date of Photo: 09/08/2022 Time of Photo: 12:20 PM Latitude: 36.259417 Longitude: -96.226174 Photographer: Matthew Allen Description: This was the vacuum truck that emptied the impacted water from the pool of water in the main channel of the tributary at the POE. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 4 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0739 Orientation: S Date of Photo: 09/08/2022 Time of Photo: 12:26 PM Latitude: 36.259536 Longitude: -96.226392 Photographer: Matthew Allen Description: This was a photo showing oil absorbent floating booms floating on the surface of the impacted tributary. This location had been 99% covered with oil at the time of the initial inspection on 09/03/2022. Significant cleanup progress was observed. Oil-stained vegetation can still be seen along the banks of the tributary. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 5 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0740 Orientation: W Date of Photo: 09/08/2022 Time of Photo: 12:26 PM Latitude: 36.259536 Longitude: -96.226392 Photographer: Matthew Allen Description: This is the same pool of water as shown is photo No. 4, just a wider view. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 6 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0741 Orientation: W Date of Photo: 09/08/2022 Time of Photo: 12:26 PM Latitude: 36.259536 Longitude: -96.226392 Photographer: Matthew Allen Description: This photo showed the impacted vegetation along the banks of the tributary as well as the high-water mark as indicated by the dark brown/black ring along the bank. The dark colored soil/vegetation is a result of oil staining. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 7 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0742 Orientation: n/a Date of Photo: 09/08/2022 Time of Photo: 12:30 PM Latitude: 36.259536 Longitude: -96.226392 Photographer: Matthew Allen Description: This was an elevated TDS field reading of 10,145 mg/L taken from the same pool of water shown in photos No. 4, 5, and 6. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 8 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0743 Orientation: E Date of Photo: 09/08/2022 Time of Photo: 12:33 PM Latitude: 36.259638 Longitude: -96.22600 Photographer: Matthew Allen Description: Oil floating on the surface of the tributary, oil staining on the rocks, vegetation, and banks. The white powdery substance was identified by the operator as "Clean B" an industrial absorbent. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 9 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0744 Orientation: S Date of Photo: 09/08/2022 Time of Photo: 12:35 PM Latitude: 36.259638 Longitude: -96.22600 Photographer: Matthew Allen Description: This was a photo of the high-water mark and oil-stained rocks and vegetation along the impacted tributary, with a view looking downstream or south. The operator had removed the freefloating oil and impacted water from this section of the tributary. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 10 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0745 Orientation: NE Date of Photo: 09/08/2022 Time of Photo: 12:38 PM Latitude: 36.260081 Longitude: -96.227198 Photographer: Matthew Allen Description: This photo shows the oil and brine impacted vegetation as well as the bed and bank features of the impacted tributary. The operator has removed the free-floating oil and impacted water from this portion of the tributary. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 11 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0746 Orientation: SW Date of Photo: 09/08/2022 Time of Photo: 12:38 PM Latitude: 36.26081 Longitude: -96.227198 Photographer: Matthew Allen Description: This was a photo showing impacted vegetation along the tributary and the bed and bank features of the impacted tributary. As with the majority of the impacted tributary, the operator has removed the impacted water along with most of the free floating oil. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 12 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0747 Orientation: SW Date of Photo: 09/08/2022 Time of Photo: 12:41 PM Latitude: 36.260312 Longitude: -96.228050 Photographer: Matthew Allen Description: This photo showed the impacted vegetation along the tributary's banks, as well as oilstained rocks along the streambed. The operator has removed the free floating oil and impacted water from the tributary. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 13 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0748 Orientation: SW Date of Photo: 09/08/2022 Time of Photo: 12:44 PM Latitude: 36.260498 Longitude: -96.228557 Photographer: Matthew Allen Description: This was a photo of oil-stained natural debris in the bed of the tributary. This should be removed as part of the cleanup operation. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 14 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0749 Orientation: N Date of Photo: 09/08/2022 Time of Photo: 12:48 PM Latitude: 36.261170 Longitude: -96.229526 Photographer: Matthew Allen Description: This was a temporary containment dam installed by the operator to prevent further downstream migration of impacted waters and oil. This dam was not present during the initial inspection which was conducted on 09/03/2022. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 15 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0750 Orientation: SW Date of Photo: 09/08/2022 Time of Photo: 12:51 PM Latitude: 36.261573 Longitude: -96.230012 Photographer: Matthew Allen Description: This was a photo of an ACME Environmental employee power washing the oil stains from the streambed and rocks along the impacted tributary. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 16 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0751 Orientation: n/a Date of Photo: 09/08/2022 Time of Photo: 12:52 Latitude: 36.261573 Longitude: -96.230012 Photographer: Matthew Allen Description: This was the bag of "Clean B' industrial absorbent which had been applied to the oil in the tributary in photo No. 8 of this photo log. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 17 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0752 Orientation: NW Date of Photo: 09/08/2022 Time of Photo: 12:53 PM Latitude: 36.261573 Longitude: -96.230012 Photographer: Matthew Allen Description: This was the power washing rig used to power was oil stains from the impacted tributary. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 18 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0753 Orientation: SW Date of Photo: 09/08/2022 Time of Photo: 12:55 PM Latitude: 36.262048 Longitude: -96.230790 Photographer: Matthew Allen Description: This was a section of the impacted tributary where power washing had already occurred, there was no oil staining present in this area at the time of the inspection. This area had been sufficiently cleaned. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 19 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0754 Orientation: n/a Date of Photo: 09/08/2022 Time of Photo: 12:57 PM Latitude: 36.262085 Longitude: -96.230875 Photographer: Matthew Allen Description: This was an elevated TDS field reading of 2,299 mg/L taken along the impacted tributary. While this was an elevated reading, it shows significant improvement over the initial readings observed on 09/03/2022. The operator was instructed to empty this pool of water from the impacted tributary. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 20 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0755 Orientation: n/a Date of Photo: 09/08/2022 Time of Photo: 1:02 PM Latitude: 36.262086 Longitude: -96.231868 Photographer: Matthew Allen Description: This was an elevated TDS field reading of 854 mg/L taken in the last pool of water along the impacted tributary before it entered the waters of Mud Creek/Keystone Lake. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 21 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0756 Orientation: S Date of Photo: 09/08/2022 Time of Photo: 1:03 PM Latitude: 36.262086 Longitude: -96.231868 Photographer: Matthew Allen Description: This was the pool of water where the TDS field reading of 854 mg/L was taken. There was a small amount of oil on the pool and oil-stained rocks and vegetation we present around the pool. Cleanup efforts had not yet reached this portion of the tributary at the time of the inspection. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 22 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0760 Orientation: W Date of Photo: 09/08/2022 Time of Photo: 2:26 PM Latitude: 36.258040 Longitude: -96.232234 Photographer: Matthew Allen Description: This was a wide-angle view of the containment and absorbent booms installed on Mud Creek/Keystone Lake. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 23 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0761 Orientation: N Date of Photo: 09/08/2022 Time of Photo: 2:26 PM Latitude: 36.258040 Longitude: -96.232234 Photographer: Matthew Allen Description: This was a wide angle view of the containment and absorbent booms installed on Mud Creek/Keystone Lake. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 24 County/Parish: Osage State: Oklahoma File Name: DSCN0762 Orientation: SW Date of Photo: 09/08/2022 Time of Photo: 2:28 PM Latitude: 36.258040 Longitude: -96.232234 Photographer: Matthew Allen Description: This was a photo of the floating oil containment boom, floating oil absorbent boom and a gasoline powered wash pump floating on Mud Creek/Keystone Lake. The oil, sheen and contaminated area was located between the booms and rip rap (rocks). This is the area where ACME Environmental had trapped the oil and was conducting cleanup and removal operations. At the time of the inspection, Cody Mather stated 11 gallons of oil had been removed from Mud Creek/Keystone Lake. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 25 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0763 Orientation: n/a Date of Photo: 09/08/2022 Time of Photo: 2:29 PM Latitude: 36.258040 Longitude: -96.232234 Photographer: Matthew Allen Description: This was an area that was being clean by ACME Environmental. There were a few rocks which still had oil staining present but most of the rocks had been cleaned at the time of the inspection. ACME Environmental was using a pressure wash pump to clean the oil from the rocks. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 26 County/Parish: Osage State: Oklahoma File Name: DSCN0764 Orientation: SW Date of Photo: 09/08/2022 Time of Photo: 2:30 PM Latitude: 36.258154 Longitude: -96.231893 Photographer: Matthew Allen Description: This was a photo of trash sacks which contained oil soaked debris and oil soaked cleanup materials. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 27 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0765 Orientation: NE Date of Photo: 09/08/2022 Time of Photo: 2:34 PM Latitude: 36.258135 Longitude: -96.233195 Photographer: Matthew Allen Description: This was a photo showing the oil trapped against the shore by the containment and absorbent booms. This area had not yet been cleaned. ACME Environmental cleanup personnel can also be seen working in the photo. The rip rap along the right side of the picture is located at the base of the earthen bridge which carried New Prue Road across Mud Creek/Keystone Lake. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.259597, -96.225672 City: Prue Photo No. 28 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0766 Orientation: NW Date of Photo: 09/08/2022 Time of Photo: 2:34 PM Latitude: 36.258135 Longitude: -96.233195 Photographer: Matthew Allen Description: This was a photo of additional booms and cleanup materials available for use at the cleanup area. The boat pictured was used to set the containment booms and transport workers to and from the location.