Document nNa3Z9yx0y8qRG6JjDKMavV7w

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 03/05/2025 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: Nevada Oil, LLC Irma Nacatoch (Sand) Unit Tank Battery From Willisville, State Highway 371 North, right on Hwy 76, and then right onto an oilfield lease road at 33.545952, -93.218989. Willisville, AR 71730 451 North Washington El Dorado, AR 71864 Nevada County 870-862-9950 Michael L. Burns Person Responsible for Operation (870-310-1501) hrowan@ecgcpa.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: N/A ARU002289 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: 2025.04.10 15:43:35 -05'00' Date JEANNE ECKHART Date: 2025.04.14 07:33:37 -05'00' Digitally signed by JEANNE ECKHART Jeanne Eckhart Date 6ENFORM-019-R8.2 (02/12/2020) 1 Section I - INTRODUCTION Nevada Oil, LLC / Irma Nacatoch (Sand) Unit Tank Battery (ARU002289 / CWA) Inspection Date 03/05/2025 PURPOSE OF THE INSPECTION EPA Region 6 inspectors Kerri McCabe (lead) and Michael Blaha arrived at the Nevada Oil, LLC / Irma Nacatoch (Sand) Unit Tank Battery ("facility") located from State Highway 371 North, right on Hwy 76, and then right onto an oilfield lease road at 33.545952, -93.218989 in Willisville, Nevada County, Arkansas; at 1305 on 03/05/2025 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 Nevada Oil, LLC / Irma Nacatoch (Sand) Unit Tank Battery facility, which contains two (2) tanks for crude oil and saltwater storage, one (1) treater, one (1) separator, and one (1) open-top tank for oil skimming. Map 1. Aerial imagery (Google Earth dated 08/03/2023) of the Nevada Oil, LLC / Irma Nacatoch (Sand) Unit Tank Battery facility. 2 Section II - OBSERVATIONS Nevada Oil, LLC / Irma Nacatoch (Sand) Unit Tank Battery (ARU002289 / CWA) Inspection Date 03/05/2025 I observed the facility signage, secondary containment, treater/separator, pipes and valves, storage tanks, and an open-top skimmer for the facility; see Appendix 1 (Photographs Log), Photos No. 1 through No. 3, Photo No. 6, and Photo No. 9. For additional GPS location and photo metadata, see Appendix 1. I observed product transfer lines without catchment buckets outside secondary containment, see Photos No. 2 and No. 3. I observed loose crude oil and saltwater inside secondary containment, see Photos No. 4 through No. 7 and Photo No. 11. I observed pits and a drainage channel excavated inside secondary containment, see Photos No. 7 and No. 8. I observed an open-top tank used to skim or separate crude oil from saltwater, see Photos No. 5 and No. 6 and Photos No. 8 and No. 9. I observed PVC piping connected to the open-top tank passing through the berm of the secondary containment directed towards the offsite saltwater disposal (SWD) injection well, see Photos No. 9 and No. 10. Section III - AREAS OF CONCERN No closing conference was held due to no personnel with Nevada Oil, LLC being present during the inspection. Areas of concern at the time of the inspection include the following: The product transfer lines outside secondary containment without catchment buckets (Photos No. 2 and No. 3), Loose crude oil and saltwater inside secondary containment (Photos No. 4 through No. 7, and No. 11), and Pit and conveyance excavated inside the secondary containment acting as storage (Photos No. 7 and No. 8). Section IV - FOLLOW UP Inspector will conduct follow-up phone calls 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 - 11 photos taken 03/05/2025. 3 Nevada Oil, LLC / Irma Nacatoch Unit Tank Battery (ARU002289 / CWA) Inspection Date 03/05/2025 Appendix 1 Photograph Log 11 Photos UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: From Willisville (Waterloo Community), State Hwy 371, right on Hwy 76, then right onto oilfield lease road at 33.545952, -93.218989. City: Willisville (Waterloo) County/Parish: Nevada State: Arkansas Photo File Name: 100-0727 Orientation: 41 NE Date of Photo: 03/05/2025 Time of Photo: 1312 Latitude: 33.546133 Longitude: -93.219000 Photographer: Kerri McCabe Description: Looking NE, this photo shows identification for the Irma Nacatoch (Sand) Unit Tank Battery ("facility"). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: From Willisville (Waterloo Community), State Hwy 371, right on Hwy 76, then right onto oilfield lease road at 33.545952, -93.218989. City: Willisville (Waterloo) County/Parish: Nevada State: Arkansas Photo File Name: 100-0728 Orientation: 60 ENE Date of Photo: 03/05/2025 Time of Photo: 1313 Latitude: 33.545950 Longitude: -93.219017 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: From Willisville (Waterloo Community), State Hwy 371, right on Hwy 76, then right onto oilfield lease road at 33.545952, -93.218989. City: Willisville (Waterloo) County/Parish: Nevada State: Arkansas Photo File Name: 100-0729 Orientation: 80 E Date of Photo: 03/05/2025 Time of Photo: 1313 Latitude: 33.546017 Longitude: -93.219117 Photographer: Kerri McCabe Description: Looking E, this photo shows a front view of the outside of the secondary containment with transfer lines through the berm. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: From Willisville (Waterloo Community), State Hwy 371, right on Hwy 76, then right onto oilfield lease road at 33.545952, -93.218989. City: Willisville (Waterloo) County/Parish: Nevada State: Arkansas Photo File Name: 100-0730 Orientation: 82 E Date of Photo: 03/05/2025 Time of Photo: 1313 Latitude: 33.546083 Longitude: -93.219117 Photographer: Kerri McCabe Description: Looking E, this photo shows a front view of the inside of the secondary containment with loose crude oil present. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: From Willisville (Waterloo Community), State Hwy 371, right on Hwy 76, then right onto oilfield lease road at 33.545952, -93.218989. City: Willisville (Waterloo) County/Parish: Nevada State: Arkansas Photo File Name: 100-0731 Orientation: 72 ENE Date of Photo: 03/05/2025 Time of Photo: 1313 Latitude: 33.546117 Longitude: -93.219117 Photographer: Kerri McCabe Description: Looking ENE, this photo shows a sideview of the inside of the secondary containment with loose crude oil and saltwater present. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: From Willisville (Waterloo Community), State Hwy 371, right on Hwy 76, then right onto oilfield lease road at 33.545952, -93.218989. City: Willisville (Waterloo) County/Parish: Nevada State: Arkansas Photo File Name: 100-0732 Orientation: 124 SE Date of Photo: 03/05/2025 Time of Photo: 1314 Latitude: 33.546233 Longitude: -93.219067 Photographer: Kerri McCabe Description: Looking SE, this photo shows a view of the backside of the inside of the secondary containment with loose crude oil and saltwater present. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: From Willisville (Waterloo Community), State Hwy 371, right on Hwy 76, then right onto oilfield lease road at 33.545952, -93.218989. City: Willisville (Waterloo) County/Parish: Nevada State: Arkansas Photo File Name: 100-0733 Orientation: 117 ESE Date of Photo: 03/05/2025 Time of Photo: 1314 Latitude: 33.546233 Longitude: -93.218817 Photographer: Kerri McCabe Description: Looking ESE, this photo shows a pit or sump area excavated inside the secondary containment holding crude oil. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: From Willisville (Waterloo Community), State Hwy 371, right on Hwy 76, then right onto oilfield lease road at 33.545952, -93.218989. City: Willisville (Waterloo) County/Parish: Nevada State: Arkansas Photo File Name: 100-0734 Orientation: 185 S Date of Photo: 03/05/2025 Time of Photo: 1315 Latitude: 33.546217 Longitude: -93.218750 Photographer: Kerri McCabe Description: Looking S, this photo shows an excavated drainage for the pit or sump area inside the secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 Location: From Willisville (Waterloo Community), State Hwy 371, right on Hwy 76, then right onto oilfield lease road at 33.545952, -93.218989. City: Willisville (Waterloo) County/Parish: Nevada State: Arkansas Photo File Name: 100-0735 Orientation: 59 ENE Date of Photo: 03/05/2025 Time of Photo: 1315 Latitude: 33.546133 Longitude: -93.218867 Photographer: Kerri McCabe Description: Looking ENE, this photo shows an open-top tank used as skimmer inside secondary containment. The white PVC piping is directed towards the Irma Nacatoch Unit saltwater disposal (SWD) inject well or an Enhanced Oil Recovery (EOR) well. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 10 Location: From Willisville (Waterloo Community), State Hwy 371, right on Hwy 76, then right onto oilfield lease road at 33.545952, -93.218989. City: Willisville (Waterloo) County/Parish: Nevada State: Arkansas Photo File Name: 100-0736 Orientation: 82 E Date of Photo: 03/05/2025 Time of Photo: 1316 Latitude: 33.546133 Longitude: -93.218867 Photographer: Kerri McCabe Description: Looking E, this photo shows the white PVC piping from Photo No. 9 directed towards the Irma Nacatoch Unit SWD/EOR well downgradient. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 11 Location: From Willisville (Waterloo Community), State Hwy 371, right on Hwy 76, then right onto oilfield lease road at 33.545952, -93.218989. City: Willisville (Waterloo) County/Parish: Nevada State: Arkansas Photo File Name: 100-0737 Orientation: 321 NW Date of Photo: 03/05/2025 Time of Photo: 1316 Latitude: 33.546067 Longitude: -93.218867 Photographer: Kerri McCabe Description: Looking NW, this photo shows a front view of the inside of the secondary containment with loose crude oil and saltwater present.