Document jdmZG2vdNBB1Z8VYrdVOeB25

Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date(s): Media : Regulatory Program(s) November 17, 2017 Water CWA) NPDES- Oil and Gas BRINE Company Name: Facility Name : Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish : Facility Contact: Trinity Operating, LLC Roxy No. 4-20/29H 35.075407N, -96.167297W Lamar, Oklahoma 74850 601 Travis Street, 19111 floor Houston, Texas 77002 Hughes Blayne Gunderman I 713-374-1526; cell : 281-725-8267 Blayne.gunderman @trinityoperating.com FRS Number: Identification/Permit Number: Media Number: NAICS: SIC: N/A OKU000864 N/A 21111 1311 Personnel participating in inspection: Kent W. Sanborn EPA Region 6, 6EN-WR Environmental Engineer 918-557-1615 EPA Lead Inspector Signature/Date Supervisor Signature/D ate Sanborn, Kent Digitally signed by Sanborn, Kent ON: cn=Sanborn, Kent, emaii=Sanborn.Kent@epa.gov Oatc:o: 2018.01.11 09:43:32 06'00' Kent W. Sanbor~ / ( / ~i.~ Jerry}4und~rP ...""" (} / Date t/II /:Jo 1)( D ~te 6ENFORM-019- R7 (2/15/2017) 1 Section I - INTRODUCTION Trinity Operating, LLC/Roxy No. 4-20/29H Inspection Date: 11/17/2017 PURPOSE OF THE INSPECTION EPA Region 6 inspector Kent W. Sanborn arrived at the Trinity Operating, LLC, Roxy Lease at 1:00 PM on November 17, 2017 for an inspection. The inspection was initiated by a reported discharge of fluids into a nearby creek by Trinity Operating, LLC to the NRC/EPA. It was initially reported that the discharge did not reach an established tributary. I met with Blayne Gunderman of Trinity Operating, LLC toward the end of the inspection. Crews were at work cleaning the pad site where the discharge had originated. The inspection was conducted under the authority of Section 308 of the CWA. The scope of the inspection was to determine if the facility was in compliance with Clean Water Act, including Section 301, and to identify and document discharges of produced wastewater (brine) to waters of the United States. Several contractors were already present and assisting with cleanup. An Oklahoma Corporation Commission inspector was not present, but was at the discharge site a day earlier. FACILITY DESCRIPTION The discharge site was a tank battery enclosed by a steel secondary containment system. There are several wells on the site. There was no power run to the facility, so all power was generated at the facility. That generator failed causing the bine tanks to overflow. The secondary containment then overflowed to a nearby ravine or tributary of Coal Creek. Section II - OBSERVATIONS I initially arrived at the Trinity Operating, LLC, Roxy lease and pad site at about 1:00 pm on November 17, 2017. Photo 1 shows the tank battery location where a power failure caused at least 1,200 barrels of produced water, or brine to enter a small drainage ravine and a tributary of Coal Creek. Photos 2 and 3 show the Roxy pad site. The facility had 3 wells and brine storage tanks. The tanks were enclosed by a steel berm or firewall secondary containment system. Brine and some oil ran over the steel containment and traveled over the pad (Photo 4) to the northwest edge (Photo 5). The discharge then ran down the hill northwest (Photos 6 and 7) towards a drainage ravine. The ravine runs on the west side of the Roxy pad site. Oil staining was evident on the rocks as shown in Photo 8. The discharge entered the ravine at the point shown in Photo 9. There was both oil and brine in pools and around the rocks. The ravine was a dry downslope from the Roxy pad. With a calibrated YSI 30 Pro Conductivity Meter, I took a Total Dissolved Solids (TDS) reading of 78,700 mg/L of the brine in the ravine, which was along the flow path from the pad site (Photo 10). Photo 11 shows the proximity of the pad to the ravine. The ravine flows south toward the tributary of Coal Creek. Oil was present in the ravine portion of the drainage (Photo 12). The ravine enters the tributary of Coal Creek (Photo 13) that originates west of this location. TDS of the entry point was 89,977 mg/L (Photo 14). The tributary continues south and east (Photo 15), but I observed no oil present in this location. TDS at the location shown in Photo 15 was 74,428 mg/L (Photo 16). The tributary was shown again downstream (Photo 17) near where a temporary dam will be constructed for flushing operations of the drainage path. Currently the TDS at this point was 91,360 mg/L (Photo 18). The tributary of Coal Creek enters the main branch of Coal Creek near the point shown in Photo 19. This point was downstream of the proposed temporary dam. I did not 2 Trinity Operating, LLC/Roxy No. 4-20/29H Inspection Date: 11/17/2017 observe that this portion of Coal Creek was effected by the spill. I observed that all of the TDS field measurements ranged from 150 to 250 mg/L in the area near the confluence of the tributary of Coal Creek and Coal Creek downstream from the discharge. Photo 20 shows Coal Creek about a half a mile downstream of the point shown in Photo 19. Coal Creek as this location had TDS readings that ranged from 150-250 mg/L. Section III - AREAS OF CONCERN The tributary of Coal Creek had brine and oil in tributary and along the flow path from the Roxy pad site. The overflowing tank battery and secondary containment area did not stop brine fluids from discharging to the tributary of Coal Creek. Section IV - FOLLOW UP A follow up inspection will be conducted as needed. Section V - LIST OF APPENDICES Appendix 1 - Photo Log - 20 photos take on 11/17/2017 3 Trinity Operating/Roxy Inspection Date: 11/17/2017 Appendix 1 Photographic Log (20 photos) UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: 35.075407N, -96.167297W City: Lamar County: Hughes State: Oklahoma Photo File Name: Photo 1 (DSC_0060) Orientation: East Date of Photo: 11/17/2017 Time of Photo: 4:56 pm Latitude: 35.086784N Longitude: -96.172373W Photographer: K.W. Sanborn Description: This image shows the sign on at the Trinity Operating, LLC - Roxy No. 4-20/29H pad site. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: 35.075407N, -96.167297W City: Lamar County: Hughes State: Oklahoma Photo File Name: Photo 2 (DSC_0059) Orientation: Northwest Date of Photo: 11/17/2017 Time of Photo: 3:55 pm Latitude: 35.07520N Longitude: -96.16690W Photographer: K.W. Sanborn Description: The Roxy pad site is shown here. up. I observed that contaminated gravel and dirt were piled UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: 35.075407N, -96.167297W City: Lamar County: Hughes State: Oklahoma Photo File Name: Photo 3 (DSC_0027) Orientation: Southeast Date of Photo: 11/17/2017 Time of Photo: 1:11 pm Latitude: 35.075407N Longitude: -96.167297W Photographer: K.W. Sanborn Description: The tank battery was the source of the brine and oil discharge. Power failure led to the tanks overflowing into the secondary containment area. The containment then overflowed to a nearby drainage ravine. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: 35.075407N, -96.167297W City: Lamar County: Hughes State: Oklahoma Photo File Name: Photo 4 (DSC_0004) Orientation: West Date of Photo: 11/17/2017 Time of Photo: 1:11 pm Latitude: 35.075407N Longitude: -96.167297W Photographer: K.W. Sanborn Description: The oil and brine ran northwest across the pad site location to a drainage ravine that passes on the west side of the site. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: 35.075407N, -96.167297W City: Lamar County: Hughes State: Oklahoma Photo File Name: Photo 5 (DSC_0030) Orientation: West Date of Photo: 11/17/2017 Time of Photo: 1:14 pm Latitude: 35.075407N Longitude: -96.167297W Photographer: K.W. Sanborn Description: The discharge ran over the edge of the pad here. The area was saturated with brine and some oil. A berm and hole were dug in this area to prevent further runoff. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: 35.075407N, -96.167297W City: Lamar County: Hughes State: Oklahoma Photo File Name: Photo 6 (DSC_0031) Orientation: West Date of Photo: 11/17/2017 Time of Photo: 1:15 pm Latitude: 35.075407N Longitude: -96.167297W Photographer: K.W. Sanborn Description: The discharge traveled down the hill here toward the drainage ravine. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: 35.075407N, -96.167297W City: Lamar County: Hughes State: Oklahoma Photo File Name: Photo 7 (DSC_0035) Orientation: Northwest Date of Photo: 11/17/2017 Time of Photo: 3:09 pm Latitude: 35.0760N Longitude: -96.1673W Photographer: K.W. Sanborn Description: The discharge ran down the hill here toward the drainage ravine. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: 35.075407N, -96.167297W City: Lamar County: Hughes State: Oklahoma Photo File Name: Photo 8 (DSC_0036) Orientation: Northwest Date of Photo: 11/17/2017 Time of Photo: 3:10 pm Latitude: 35.0760N Longitude: -96.1673W Photographer: K.W. Sanborn Description: I observed oil staining on the rocks along the discharge path at this location. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 Location: 35.075407N, -96.167297W City: Lamar County: Hughes State: Oklahoma Photo File Name: Photo 9 (DSC_0044) Orientation: South Date of Photo: 11/17/2017 Time of Photo: 3:13 pm Latitude: 35.0762N Longitude: -96.1681W Photographer: K.W. Sanborn Description: This is near the point of entry to the drainage ravine. I observed that brine and oil were pooled up at this location. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 10 Location: 35.075407N, -96.167297W City: Lamar County: Hughes State: Oklahoma Photo File Name: Photo 10 (DSC_0045) Orientation: South Date of Photo: 11/17/2017 Time of Photo: 3:14 pm Latitude: 35.0762N Longitude: -96.1681W Photographer: K.W. Sanborn Description: With a calibrated YSI 30 Pro Conductivity meter, I took a Total Dissolved Solids (TDS) reading of 78,700 mg/L along the flow path in the drainage ravine. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 11 Location: 35.075407N, -96.167297W City: Lamar County: Hughes State: Oklahoma Photo File Name: Photo 11 (DSC_0042) Orientation: Southeast Date of Photo: 11/17/2017 Time of Photo: 3:12 pm Latitude: 35.0762N Longitude: -96.1681W Photographer: K.W. Sanborn Description: This is a view of the west side of the pad from the drainage ravine. the tributary of Coal Creek. Flow was south toward UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 12 Location: 35.075407N, -96.167297W City: Lamar County: Hughes State: Oklahoma Photo File Name: Photo 12 (DSC_0043) Orientation: East Date of Photo: 11/17/2017 Time of Photo: 3:13 pm Latitude: 35.0762N Longitude: -96.1681W Photographer: K.W. Sanborn Description: I observed that oil and brine fluids were pooled in the ravine below the pad site. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 13 Location: 35.075407N, -96.167297W City: Lamar County: Hughes State: Oklahoma Photo File Name: Photo 13 (DSC_0049) Orientation: South Date of Photo: 11/17/2017 Time of Photo: 3:20 pm Latitude: 35.0742N Longitude: -96.1692W Photographer: K.W. Sanborn Description: This was the point where the drainage ravine meets the tributary of Coal Creek. That tributary joins the ravine from the northwest and then flows south and east toward the main branch of Coal Creek. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 14 Location: 35.075407N, -96.167297W City: Lamar County: Hughes State: Oklahoma Photo File Name: Photo 14 (DSC_0051) Orientation: South Date of Photo: 11/17/2017 Time of Photo: 3:23 pm Latitude: 35.0742N Longitude: -96.1692W Photographer: K.W. Sanborn Description: The TDS at the point of entry to the tributary of Coal Creek was 89,977 mg/L. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 15 Location: 35.075407N, -96.167297W City: Lamar County: Hughes State: Oklahoma Photo File Name: Photo 15 (DSC_0053) Orientation: South Date of Photo: 11/17/2017 Time of Photo: 3:27 pm Latitude: 35.0722N Longitude: -96.1680W Photographer: K.W. Sanborn Description: The brine traveled south in the tributary. I did not observe oil or oil sheen at this location. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 16 Location: 35.075407N, -96.167297W City: Lamar County: Hughes State: Oklahoma Photo File Name: Photo 16 (DSC_0054) Orientation: South Date of Photo: 11/17/2017 Time of Photo: 3:27 pm Latitude: 35.0722N Longitude: -96.1680W Photographer: K.W. Sanborn Description: TDS was 74,428 mg/L at the location shown in photo 15. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 17 Location: 35.075407N, -96.167297W City: Lamar County: Hughes State: Oklahoma Photo File Name: Photo 17 (DSC_0057) Orientation: South Date of Photo: 11/17/2017 Time of Photo: 4:14 PM Latitude: 35.0710N Longitude: -96.1699W Photographer: K.W. Sanborn Description: A temporary dam will be built near this location and flushing operations will begin on the tributary. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 18 Location: 35.075407N, -96.167297W City: Lamar County: Hughes State: Oklahoma Photo File Name: Photo 18 (DSC_0055) Orientation: South Date of Photo: 11/17/2017 Time of Photo: 3:30 pm Latitude: 35.0710N Longitude: -96.1699W Photographer: K.W. Sanborn Description: TDS of the location shown in photo 17 was 91,360 mg/L. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 19 Location: 35.075407N, -96.167297W City: Lamar County: Hughes State: Oklahoma Photo File Name: Photo 19 (DSC_0033) Orientation: West Date of Photo: 11/17/2017 Time of Photo: 1:51 pm Latitude: 33.0653N Longitude: -96.1658W Photographer: K.W. Sanborn Description: This photo shows the location where the tributary enters Coal Creek. I observed that no brine or oil has reached this point during the inspection. TDS ranged from 150-250 mg/L (background TDS readings for this area). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 20 Location: 35.075407N, -96.167297W City: Lamar County: Hughes State: Oklahoma Photo File Name: Photo 20 (DSC_0032) Orientation: West Date of Photo: 11/17/2017 Time of Photo: 1:37 pm Latitude: 35.07028N Longitude: -96.15806W Photographer: K.W. Sanborn Description: This was the main part of Coal Creek even farther east of the location shown in Photo 19. TDS ranged from 150-250 mg/L (background).