Document mBXZgjN4jQwoekvnaxqLE2RqZ

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 E Gregory #4 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 ARU002263 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: 2025.01.13 11:12:24 -06'00' Date JEANNE ECKHART Date: 2025.01.14 09:15:14 -06'00' Digitally signed by JEANNE ECKHART Jeanne Eckhart Date 6ENFORM-019-R8.2 (02/12/2020) 1 Section I - INTRODUCTION SMI Operating Company, LLC / E Gregory #4 Tank Battery (ARU002263 / CWA) Inspection Date 11/08/2024 PURPOSE OF THE INSPECTION EPA Region 6 inspector Kerri McCabe (lead) arrived at the SMI Operating Company, LLC / E Gregory #4 Tank Battery, located from Highway 63 E, then Armer Rd, left onto an oil lease road at 33.247317, 92.536617; at 1300 on 11/08/2024 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 / E Gregory #4 Tank Battery, which contained five (5) storage/separation tanks for crude oil and saltwater. Signage on one of the tanks inside secondary containment was marked with "Pacific-Atlantic Oil Company." Communication with Mr. Glen Owen, Inspector Supervisor with AOGC, 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 / E Gregory #4 Tank Battery. 2 SMI Operating Company, LLC / E Gregory #4 Tank Battery (ARU002263 / CWA) Inspection Date 11/08/2024 Section II - OBSERVATIONS I observed the SMI Operating Company, LLC / E Gregory #4 Tank Battery facility and associated signage, secondary containment, storage tanks, and treaters/separators; see Appendix 1 (Photographs Log), see Photos No. 1 and No. 2. For additional GPS location and photo metadata, see Appendix 1. I observed a miscellaneous pipe outside secondary containment without a catchment bucket, see Photo No. 3. I observed an active leak of crude oil from a valve inside secondary containment, loose oil inside secondary containment, and residual oil applied to the containment berm, see Photos No. 4; No. 6 and No. 7. I observed a transfer line through secondary containment with a catchment bucket, see Photo No. 5. I observed two (2) tanks that appeared to be out of service without proper labeling, see Photo No. 8 and No. 9. I observed loose crude oil and pooled saltwater inside secondary containment, see Photos No. 10 through No. 14. I observed an active leak of crude oil and saltwater from the partially opened drainpipe for secondary containment, see Photos No. 15 and No. 16. I observed the downstream flowpath of the active leak of crude oil and saltwater from the drainpipe for secondary containment, see Photos No. 17 through No. 20. Dead vegetation was noted along the downstream flowpath. Section III - AREAS OF CONCERN No closing conference was held due to no personnel with SMI Operating Company, LLC being present during the inspection. Mr. Jacob Agerton, contact on file with AOGC, was contacted via email on 11/12/2024 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, A miscellaneous pipe outside secondary containment without a catchment bucket, An active leak of crude oil from a valve, loose oil and pooled saltwater inside secondary containment, and residual oil applied to the secondary containment berm, Two (2) tanks inside secondary containment that appeared to be out of service without proper labeling, An active leak of crude oil and saltwater from the partially opened drainpipe for secondary containment, Releases of crude oil and saltwater from the drainpipe for secondary containment into the surrounding environment, and 3 SMI Operating Company, LLC / E Gregory #4 Tank Battery (ARU002263 / CWA) Inspection Date 11/08/2024 Dead vegetation along the downstream flowpath from releases from the drainpipe for the secondary containment. 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 - 20 photos taken 11/08/2024. 4 SMI Operating Company, LLC / E Gregory #4 Tank Battery (CWA / ARU002263) Inspection Date 11/08/2024 Appendix 1 Photograph Log 20 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 33.246617, 92.536917. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0346 Orientation: SE Date of Photo: 11/08/2024 Time of Photo: 1313 Latitude: 33.246617 Longitude: -92.536917 Photographer: Kerri McCabe Description: Looking SE, this photo shows the signage located at the facility. 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 33.246617, 92.536917. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0347 Orientation: NNE Date of Photo: 11/08/2024 Time of Photo: 1313 Latitude: 33.246550 Longitude: -92.537000 Photographer: Kerri McCabe Description: Looking NNE, 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 33.246617, 92.536917. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0348 Orientation: NNE Date of Photo: 11/08/2024 Time of Photo: 1313 Latitude: 33.246561 Longitude: -92.537022 Photographer: Kerri McCabe Description: Looking NNE, this photo shows miscellaneous pipe extended outside secondary containment without a catchment bucket. 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 33.246617, 92.536917. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0349 Orientation: NNE Date of Photo: 11/08/2024 Time of Photo: 1313 Latitude: 33.246556 Longitude: -92.537044 Photographer: Kerri McCabe Description: Looking NNE, this photo shows an active leak of crude oil, loose oil inside secondary containment, and residual crude oil applied to the secondary containment 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 33.246617, 92.536917. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0350 Orientation: NE Date of Photo: 11/08/2024 Time of Photo: 1314 Latitude: 33.246533 Longitude: -92.537017 Photographer: Kerri McCabe Description: Looking NE, this photo shows a transfer pipe through secondary containment with a catchment bucket. 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 33.246617, 92.536917. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0351 Orientation: SW Date of Photo: 11/08/2024 Time of Photo: 1314 Latitude: 33.246650 Longitude: -92.536967 Photographer: Kerri McCabe Description: Looking SW, this photo shows loose oil inside secondary containment. 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 33.246617, 92.536917. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0352 Orientation: NW Date of Photo: 11/08/2024 Time of Photo: 1314 Latitude: 33.246659 Longitude: -92.536967 Photographer: Kerri McCabe Description: Looking NW, this photo shows loose oil inside secondary containment. 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 33.246617, 92.536917. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0353 Orientation: NNE Date of Photo: 11/08/2024 Time of Photo: 1314 Latitude: 33.246750 Longitude: -92.536917 Photographer: Kerri McCabe Description: Looking NNE, this photo shows two (2) tanks that appeared to be out of service without proper labeling; front view. 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 33.246617, 92.536917. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0354 Orientation: SW Date of Photo: 11/08/2024 Time of Photo: 1315 Latitude: 33.246867 Longitude: -92.536900 Photographer: Kerri McCabe Description: Looking SW, this photo shows two (2) tanks that appeared to be out of service without proper labeling; back view. 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 33.246617, 92.536917. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0355 Orientation: SSE Date of Photo: 11/08/2024 Time of Photo: 1315 Latitude: 33.246967 Longitude: -92.536950 Photographer: Kerri McCabe Description: Looking SSE, this photo shows loose crude oil and pooled saltwater inside secondary containment. 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 33.246617, 92.536917. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0356 Orientation: SE Date of Photo: 11/08/2024 Time of Photo: 1315 Latitude: 33.246833 Longitude: -92.537050 Photographer: Kerri McCabe Description: Looking SE, this photo shows loose crude oil and pooled saltwater inside secondary containment. 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 33.246617, 92.536917. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0357 Orientation: SE Date of Photo: 11/08/2024 Time of Photo: 1315 Latitude: 33.246803 Longitude: -92.537050 Photographer: Kerri McCabe Description: Looking SE, this photo shows loose crude oil and pooled saltwater inside secondary containment. 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 33.246617, 92.536917. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0358 Orientation: E Date of Photo: 11/08/2024 Time of Photo: 1316 Latitude: 33.246583 Longitude: -92.537133 Photographer: Kerri McCabe Description: Looking E, this photo shows loose crude oil and pooled saltwater inside secondary containment. 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 33.246617, 92.536917. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0359 Orientation: ENE Date of Photo: 11/08/2024 Time of Photo: 1316 Latitude: 33.246567 Longitude: -92.537100 Photographer: Kerri McCabe Description: Looking ENE, this photo shows loose crude oil and pooled saltwater inside secondary containment. 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 33.246617, 92.536917. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0360 Orientation: NNE Date of Photo: 11/08/2024 Time of Photo: 1316 Latitude: 33.246567 Longitude: -92.537050 Photographer: Kerri McCabe Description: Looking NNE, this photo shows an active leak of crude oil and saltwater from the drainpipe for secondary containment. 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 33.246617, 92.536917. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0361 Orientation: NNE Date of Photo: 11/08/2024 Time of Photo: 1316 Latitude: 33.246567 Longitude: -92.537033 Photographer: Kerri McCabe Description: Looking NNE, this photo shows an active leak of crude oil and saltwater from the drainpipe for secondary containment. 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 33.246617, 92.536917. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0362 Orientation: NNW Date of Photo: 11/08/2024 Time of Photo: 1316 Latitude: 33.246600 Longitude: -92.537017 Photographer: Kerri McCabe Description: Looking NNW, this photo shows the downstream flowpath from the active leak of crude oil and saltwater from the drainpipe for secondary containment. Dead and stressed vegetation was noted during the inspection. 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 33.246617, 92.536917. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0363 Orientation: NNW Date of Photo: 11/08/2024 Time of Photo: 1317 Latitude: 33.246667 Longitude: -92.537167 Photographer: Kerri McCabe Description: Looking NNW, this photo shows the downstream flowpath from the active leak of crude oil and saltwater from the drainpipe for secondary containment. Dead and stressed vegetation was noted during the inspection. 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 33.246617, 92.536917. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0364 Orientation: WNW Date of Photo: 11/08/2024 Time of Photo: 1317 Latitude: 33.246683 Longitude: -92.537267 Photographer: Kerri McCabe Description: Looking WNW, this photo shows the downstream flowpath from the active leak of crude oil and saltwater from the drainpipe for secondary containment. Dead and stressed vegetation was noted during the inspection. 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 33.246617, 92.536917. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0365 Orientation: NW Date of Photo: 11/08/2024 Time of Photo: 1317 Latitude: 33.246667 Longitude: -92.537333 Photographer: Kerri McCabe Description: Looking NW, this photo shows the downstream flowpath from the active leak of crude oil and saltwater from the drainpipe for secondary containment. Dead and stressed vegetation was noted during the inspection.