Document g49vaLvmjpkmzvEpDGRrbzLG

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 11/08/2024 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 Walker-Gregory #6 & #8 Tank Battery In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.246617, -92.536917. 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 ARU002264 N/A 211111 1311 Personnel participating in inspection: Kerri McCabe (lead) EPA / Region 6 ECDW Inspector / Enforcement Officer EPA Lead Inspector Signature/Date Supervisor Signature/Date KERRI MCCABE Kerri McCabe Digitally signed by KERRI MCCABE Date: 2025.01.07 10:50:44 -06'00' Date JEANNE ECKHART Date: 2025.01.10 08:02:05 -06'00' Digitally signed by JEANNE ECKHART Jeanne Eckhart Date 6ENFORM-019-R8.2 (02/12/2020) 1 SMI Operating Company, LLC / Walker-Gregory #6 & #8 Tank Battery (ARU002264 / CWA) Inspection Date 11/08/2024 Section I - INTRODUCTION PURPOSE OF THE INSPECTION EPA Region 6 inspector Kerri McCabe (lead) arrived at the SMI Operating Company, LLC / WalkerGregory #6 & #8 Tank Battery ("facility") at 1320 on 11/08/2024 for an unannounced inspection. The facility is located from Highway 63 E, then Armer Rd, left onto an oil lease road at 33.246617, 92.536917. 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 / Walker-Gregory #6 & #8 Tank Battery, which contained three (3) storage/separation tanks for crude oil and saltwater. Signage on one of the tanks inside secondary containment was marked with "Jamie Oil, Inc." Communication with Mr. Jimmy Crain with Jamie Oil, Inc. on 11/12/2024 confirmed that the facility had been sold to SMI Operating Company, LLC. Map 1. Aerial imagery (Google Earth dated 03/11/2024) of the SMI Operating Company, LLC / WalkerGregory #6 & #8 Tank Battery. 2 SMI Operating Company, LLC / Walker-Gregory #6 & #8 Tank Battery (ARU002264 / CWA) Inspection Date 11/08/2024 Section II - OBSERVATIONS I observed the SMI Operating Company, LLC / Walker-Gregory #6 & #8 Tank Battery facility and associated secondary containment, storage tanks, and separator/heater treater; see Appendix 1 (Photograph Log), Photo No. 1 and No. 2. For additional GPS location and photo metadata, see Appendix 1. I observed one (1) tank with an open hatch, see Photo No. 3. I observed the drainpipe for secondary containment to be broken and opened outside containment, see Photo No. 4. I observed tank bottom crude oil and solids used on the secondary containment berms, see Photo No. 5. The facility appeared to be out of service; however, there was no labeling on the tanks to indicate the tanks were properly placed out of service. Section III - AREAS OF CONCERN No closing conference was held due to no personnel with SMI Operating Company, LLC being present during the inspection. On 11/12/2024, I contacted Mr. Jacob Agerton, the company contact on file with the Arkansas Oil and Gas Commission ("AOGC"), via email regarding the inspections of related facilities owned/operated by SMI Operating Company, LLC. Areas of concern at the time of the inspection include the following: No updated signage at the facility, Open hatch on one of the tanks, The broken and opened drainpipe outside secondary containment, Tank bottom crude oil and solids used on the berms of the secondary containment, and No indication of the facility being properly placed in "out of service" mode with proper labeling. 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 - 5 photos taken 11/08/2024. 3 SMI Operating Company, LLC / Walker-Gregory #6 & #8 Tank Battery (ARU002264 / CWA) Inspection Date 11/08/2024 Appendix 1 Photograph Log 5 Photos UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.246617, 92.536917. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0366 Orientation: ESE Date of Photo: 11/08/2024 Time of Photo: 1320 Latitude: 33.246483 Longitude: -92.536983 Photographer: Kerri McCabe Description: Looking ESE, this photo shows the signage at the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.246617, 92.536917. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0367 Orientation: SSE Date of Photo: 11/08/2024 Time of Photo: 1321 Latitude: 33.246550 Longitude: -92.536967 Photographer: Kerri McCabe Description: Looking SSE, this photo shows an overview of the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.246617, 92.536917. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0368 Orientation: ESE Date of Photo: 11/08/2024 Time of Photo: 1321 Latitude: 33.246518 Longitude: -92.536983 Photographer: Kerri McCabe Description: Looking ESE, this photo shows an opened hatch on one of the tanks inside secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.246617, 92.536917. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0369 Orientation: NNW Date of Photo: 11/08/2024 Time of Photo: 1321 Latitude: 33.246367 Longitude: -92.536967 Photographer: Kerri McCabe Description: Looking NNW, this photo shows the broken and opened drainpipe outside secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.246617, 92.536917. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0370 Orientation: NNE Date of Photo: 11/08/2024 Time of Photo: 1322 Latitude: 33.246383 Longitude: -92.536900 Photographer: Kerri McCabe Description: Looking NNE, this photo shows tank bottom crude oil and solids applied to the berms for secondary containment.