Document nkXVy48EQkG998kgpoDeoZN0z

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 5/22/2024 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: MidAmerica Environmental Holdings, LLC USA Disposal - El Dorado 101 Warehouse Drive El Dorado, AR 71730 4101 Old Oak Drive Little Rock, AR 72212 Union County 501-404-2020 Kirk Brown (318-773-3852) Director of Operations Kirk.brown@trekkerenergy.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: N/A ARU002251; ADEQ permit 5077-WR-7 (administratively extended) for AFIN 70-01210 N/A 213112 1389 Personnel participating in inspection: Kerri McCabe EPA / Region 6 ECDW Michael Young ADEQ / Office of Water Quality Kirk Brown Trekker Energy Services Cody Eubanks MidAmerica Environ. Holdings, LLC Inspector / Enforcement Officer Inspector Supervisor Director of Operations Site Manager EPA Lead Inspector Signature/Date Supervisor Signature/Date KERRI MCCABE Kerri McCabe Digitally signed by KERRI MCCABE Date: 2024.06.05 08:32:08 -05'00' Date JEANNE ECKHART Date: 2024.06.10 16:08:48 -05'00' Digitally signed by JEANNE ECKHART Jeanne Eckhart Date 6ENFORM-019-R8.2 (02/12/2020) 1 MidAmerica Environmental Holdings, LLC / USA Disposal - El Dorado (ARU002251 / CWA) Inspection Date 05/22/2024 Section I - INTRODUCTION PURPOSE OF THE INSPECTION EPA Region 6 inspector Kerri McCabe (lead) arrived at MidAmerica Environmental Holdings, LLC / USA Disposal - El Dorado, located at 101 Warehouse Drive, El Dorado, Arkansas, 71730 at 33.204359, 92.613940; at 1050 on 5/22/2024 for an announced inspection. Mr. Kirk Brown, Trekker Energy Services, was 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. Mr. Micheal Young with Arkansas Department of Energy and Environment - Division of Environmental Quality - Office of Water Quality - Compliance Branch (hereafter "ADEQ"), was present at the time of the inspection. FACILITY DESCRIPTION EPA conducted an inspection on the MidAmerica Environmental Holdings, LLC / USA Disposal - El Dorado site, which is a drilling mud bulking facility for oil-based and water-based drilling fluids, Exploration and Production (E&P) wastes, and additional liquid wastes listed in the State No-Discharge (SND) permit issued by the State of Arkansas. There are five (5) concrete holding pits, 23 frac tanks, one (1) storage building for bulking material (sawdust), one (1) concrete slab for stockpiling bulked material (sawdust blended with liquid wastes), one (1) stormwater pond, and several outbuildings used as storage and office space. Approximately 6.5 acres of the active property have been used for land filling and land application of bulked material. The facility was formally a mining site and borrow pit for clay soil. Information regarding the SND permit issued by ADEQ can be found at the following hyperlink: https://www.adeq.state.ar.us/downloads/WebDatabases/PermitsOnline/NPDES/Permits/5077-WR7.pdf Section II - OBSERVATIONS I observed the signage and an overview of the facility, see Appendix 1 (Photograph Log), Photo No. 1 and No. 2. For additional GPS location and photo metadata, see Appendix 1. I observed eight (8) frac tanks with no secondary containment and heavy equipment, such as a bulldozer and an excavator, used for material handling. There was no labeling on the frac tanks, and black liquid and staining were observed on the ground. See Photo No. 3 through No. 5. I observed bulked material (sawdust blended with liquid wastes) stockpiled on the property. Some stockpiles contained solid waste. See Photo No. 6 and No. 14. 2 MidAmerica Environmental Holdings, LLC / USA Disposal - El Dorado (ARU002251 / CWA) Inspection Date 05/22/2024 I observed an excavated pit, which contained bulked material, synthetic liners, and leachate. See Photo No. 7 through No. 10. I observed bulked material and leachate adjacent to a wetland on the property. See Photo No. 11 through No. 13. I observed bulked material land applied directly onto the ground at the property. See Photo No. 15. I observed bulked material adjacent to another wetland on the property. Dead vegetation was noted in the wetland. See Photo No. 16 and No. 17. I observed the stormwater pond, which contained unknown liquid wastes and sediment. Black staining, a petroleum sheen, gas bubbles, and an odor were noted from the stormwater pond. Erosion gullies leading to the receiving stream, an unnamed tributary (UT) of Boggy Creek, were noted in the stormwater pond levee. See Photo No. 18 through No. 21, and No. 27. I observed the condition of the receiving stream directly downstream of the erosion gullies in the stormwater pond levee. Unknown material, black staining, and odor were noted from the receiving stream. See Photo No. 22. I observed the drainpipes, shutoff valves, and screw caps for the stormwater pond. The cap was missing from the uppermost drainpipe, and an active discharge to the receiving stream was observed. See Photo No. 23 through No. 25. I observed the condition of the receiving stream directly upstream of the drainpipes and erosion gullies. Unknown material, black staining, and odor were noted from the receiving stream. See Photo No. 26. I observed a drainage imbedded through the process area leading toward the stormwater pond. Unknown liquid waste, black staining, and odor were noted from the drainage. See Photo No. 28 and No. 29. I observed one (1) of the concrete holding pits with piping, which contained unknown liquid wastes. Black staining was noted outside the holding pit. See Photo No. 30 and No. 31. I observed dead earthworms in an unknown material in the drainage referenced in Photo No. 28 and No. 29. See Photo No. 32. I observed the building for bulking material storage with sawdust and leachate outside the building. See Photo No. 33. I observed one (1) frac tank and two (2) smaller concrete holding pits, which contained unknown liquid wastes. Black liquid and staining were noted outside the holding pits. See Photo No. 34 through No. 36. I observed one (1) of the concrete holding pits with hosing, which contained unknown liquid wastes. I noted the available freeboard and an erosion gully in the earthen berm. Black liquid and staining were observed outside the holding pit. See Photo No. 37 through No. 39 and No. 42. 3 MidAmerica Environmental Holdings, LLC / USA Disposal - El Dorado (ARU002251 / CWA) Inspection Date 05/22/2024 I observed one (1) of the concrete holding pits used for leachate collection, which contained leachate from bulked material. Black liquid and hydrocarbon sheen were noted in the holding pit. An erosion gully was observed in the earthen berm around the holding pit. The erosion gully led to the holding pit referenced in Photo No. 37. See Photo No. 40 and No. 41 and No. 43. I observed uncovered bulked material, leachate from the bulked material on the ground, and frac tanks outside containment. The frac tanks were not labeled (contents unknown). See Photo No. 44 through No. 47. I observed a "Material / Waste Transfer Form" and a bill of lading from the facility for an incoming truckload. See Photo No. 48 and No. 49. I observed the receiving stream, upstream of the facility, on both sides of a culvert running under Industrial Road. Characteristics of the receiving stream were noted. See Photo No. 50 and No. 51. Section III - AREAS OF CONCERN A closing conference was held with Mr. Kirk Brown with Trekker Energy Services during the inspection. Areas of concern at the time of the inspection include the following: Frac tanks with no labeling and outside secondary containment, Bulked material (sawdust blended with liquid wastes) stockpiled, land filled, and land applied on the property, Bulked material and leachate adjacent to wetlands on the property, The stormwater pond with unknown wastes, erosion gullies in the levee, and opened shutoff valve and removed screw cap; An active discharge into the receiving stream from a dripping drainpipe for the stormwater pond, Unknown waste materials, black staining, and odor in the receiving stream, Conveyances with unknown liquid wastes directed toward the stormwater pond, Holding pits with releases of unknown liquid wastes on the ground, Erosion gullies in the earthen berms of the holding pits, Lack of freeboard for the holding pits, Leachate from bulked material on the ground throughout the property, and Incomplete paperwork for incoming/outgoing truckloads. 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 - 51 photos taken 5/22/2024. 4 MidAmerica Environmental Holdings, LLC / USA Disposal - El Dorado (ARU002251 / CWA) Inspection Date 05/22/2024 Appendix 1 Photograph Log 51 Photos UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010150 Orientation: SW Date of Photo: 05/22/2024 Time of Photo: 1231 Latitude: 33.204317 Longitude: -92.614067 Photographer: Kerri McCabe Description: Looking SW, this photo showed the signage for the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010151 Orientation: NW Date of Photo: 05/22/2024 Time of Photo: 1231 Latitude: 33.204305 Longitude: -92.614038 Photographer: Kerri McCabe Description: Looking NW, this photo showed the overview of the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010152 Orientation: NE Date of Photo: 05/22/2024 Time of Photo: 1232 Latitude: 33.204590 Longitude: -92.614254 Photographer: Kerri McCabe Description: Looking NE, this photo showed four (4) frac tanks (without containment) and heavy equipment at the facility. Frac tanks were not labeled (contents unknown). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010155 Orientation: SE Date of Photo: 05/22/2024 Time of Photo: 1233 Latitude: 33.204666 Longitude: -92.614200 Photographer: Kerri McCabe Description: Looking SE, this photo showed the opposite view from Photo No. 3. A spill was observed in front of the red frac tank. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010153 Orientation: NE Date of Photo: 05/22/2024 Time of Photo: 1232 Latitude: 33.204630 Longitude: -92.614228 Photographer: Kerri McCabe Description: Looking NE, this photo showed four (4) more additional frac tanks (without containment) onsite. Frac tanks were not labeled (contents unknown). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010163 Orientation: S-SE Date of Photo: 05/22/2024 Time of Photo: 1240 Latitude: 33.205967 Longitude: -92.616083 Photographer: Kerri McCabe Description: Looking S-SE, this photo showed bulked waste material (liquid waste blended with sawdust) with runoff adjacent to the stockpile. Synthetic liner pieces were observed in the bulked material, and algal growth was noted in the adjacent runoff. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010164 Orientation: SW Date of Photo: 05/22/2024 Time of Photo: 1241 Latitude: 33.205884 Longitude: -92.616117 Photographer: Kerri McCabe Description: Looking SW, this photo showed an excavated pit with bulked material and solid waste inside the pit. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010165 Orientation: SW Date of Photo: 05/22/2024 Time of Photo: 1241 Latitude: 33.205884 Longitude: -92.616117 Photographer: Kerri McCabe Description: Looking SW, this photo showed a closer view of the excavated pit and contents from Photo No. 7. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010166 Orientation: W-NW Date of Photo: 05/22/2024 Time of Photo: 1241 Latitude: 33.205617 Longitude: -92.616195 Photographer: Kerri McCabe Description: Looking W-NW, this photo showed leachate from the bulked material inside the excavated pit from Photo No. 7. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 10 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010167 Orientation: W Date of Photo: 05/22/2024 Time of Photo: 1241 Latitude: 33.205600 Longitude: -92.616209 Photographer: Kerri McCabe Description: Looking W, this photo showed a closeup of the bulked material inside the excavated pit from Photo No. 7. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 11 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010168 Orientation: SW Date of Photo: 05/22/2024 Time of Photo: 1243 Latitude: 33.205550 Longitude: -92.616683 Photographer: Kerri McCabe Description: Looking SW, this photo showed bulked material and leachate adjacent to a wetland at the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 12 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010169 Orientation: SW Date of Photo: 05/22/2024 Time of Photo: 1243 Latitude: 33.205500 Longitude: -92.616933 Photographer: Kerri McCabe Description: Looking SW, this photo showed bulked material and leachate discharged into the wetland at the facility. Algal growth was noted in the surface water. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 13 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010170 Orientation: SW Date of Photo: 05/22/2024 Time of Photo: 1243 Latitude: 33.205469 Longitude: -92.616855 Photographer: Kerri McCabe Description: Looking SW, this photo showed an additional view of the bulked material and the wetland in Photo No. 12. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 14 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010171 Orientation: SW Date of Photo: 05/22/2024 Time of Photo: 1245 Latitude: 33.205083 Longitude: -92.616317 Photographer: Kerri McCabe Description: Looking SW, this photo showed bulked material stockpiled onsite. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 15 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010174 Orientation: SE Date of Photo: 05/22/2024 Time of Photo: 1248 Latitude: 33.204950 Longitude: -92.616100 Photographer: Kerri McCabe Description: Looking SE, this photo showed bulked material land applied on top of bare soil at the facility. The process area was observed in the background. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 16 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010175 Orientation: SW Date of Photo: 05/22/2024 Time of Photo: 1250 Latitude: 33.204483 Longitude: -92.616117 Photographer: Kerri McCabe Description: Looking SW, this photo showed bulked material adjacent to another wetland located at the facility. Dead vegetation was noted in the wetland. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 17 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010176 Orientation: SW Date of Photo: 05/22/2024 Time of Photo: 1250 Latitude: 33.204483 Longitude: -92.616117 Photographer: Kerri McCabe Description: Looking SW, this photo showed an additional view of the bulked material and dead vegetation at the wetland in Photo No. 16. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 18 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010177 Orientation: SE Date of Photo: 05/22/2024 Time of Photo: 1251 Latitude: 33.204483 Longitude: -92.616117 Photographer: Kerri McCabe Description: Looking SW, this photo showed the stormwater pond utilized by the facility, which is permitted under NPDES permit ARR001445. Black color, hydrocarbon sheen, and odor were noted at stormwater pond. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 19 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010178 Orientation: SW Date of Photo: 05/22/2024 Time of Photo: 1251 Latitude: 33.204267 Longitude: -92.616017 Photographer: Kerri McCabe Description: Looking SW, this photo showed an erosion gully formed in the stormwater pond levee directed to the receiving stream (unnamed tributary (UT) of Boggy Creek). Black staining was noted within the gully. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 20 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010179 Orientation: S-SW Date of Photo: 05/22/2024 Time of Photo: 1251 Latitude: 33.204245 Longitude: -92.616017 Photographer: Kerri McCabe Description: Looking S-SW, this photo showed an additional erosion gully in the stormwater pond levee directed toward the receiving stream (UT of Boggy Creek). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 21 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010180 Orientation: SW Date of Photo: 05/22/2024 Time of Photo: 1251 Latitude: 33.204181 Longitude: -92.616017 Photographer: Kerri McCabe Description: Looking SW, this photo showed the erosion gully from Photo No. 20 leading to the receiving stream (UT of Boggy Creek). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 22 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010182 Orientation: W-SW Date of Photo: 05/22/2024 Time of Photo: 1252 Latitude: 33.204181 Longitude: -92.616017 Photographer: Kerri McCabe Description: Looking W-SW, this photo showed the receiving stream (UT of Boggy Creek) at the erosion gully in Photo No. 20 and No. 21. Unknown material, black staining, and odor were noted at the receiving stream. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 23 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010183 Orientation: S Date of Photo: 05/22/2024 Time of Photo: 1252 Latitude: 33.204181 Longitude: -92.616017 Photographer: Kerri McCabe Description: Looking S, this photo showed two drainpipes for the stormwater pond. Both with shutoff valves and screw caps (caps not in use and uppermost valve actively leaking). The two additional pipes, one in the vertical position and one crossing the receiving stream, are not connected or being used. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 24 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010185 Orientation: S Date of Photo: 05/22/2024 Time of Photo: 1252 Latitude: 33.204133 Longitude: -92.615983 Photographer: Kerri McCabe Description: Looking S, this photo showed an active discharge from the uppermost drainpipe for the stormwater pond into the receiving stream (UT of Boggy Creek). Vertical pipe and pipe across the receiving stream are not connected or being used. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 25 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010187 Orientation: W-SW Date of Photo: 05/22/2024 Time of Photo: 1254 Latitude: 33.204115 Longitude: -92.615993 Photographer: Kerri McCabe Description: Looking W-SW, this photo showed the lowermost drainpipe with a shutoff valve and the screw cap for one of the drainpipes in the receiving stream (UT of Boggy Creek). Vertical pipe and the pipe across the receiving stream are not connected or being used. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 26 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010188 Orientation: S Date of Photo: 05/22/2024 Time of Photo: 1254 Latitude: 33.204100 Longitude: -92.615983 Photographer: Kerri McCabe Description: Looking S, this photo showed the condition of the receiving stream immediately upstream of the drainpipes for the stormwater pond. Unknown material, black staining, and odor were noted at the receiving stream. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 27 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010191 Orientation: N-NW Date of Photo: 05/22/2024 Time of Photo: 1256 Latitude: 33.204128 Longitude: -92.615810 Photographer: Kerri McCabe Description: Looking N-NW, this photo showed an additional view of the stormwater pond utilized by the facility. Gas bubbles from unknown wastes in the stormwater pond were observed. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 28 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010194 Orientation: SE Date of Photo: 05/22/2024 Time of Photo: 1257 Latitude: 33.204150 Longitude: -92.615667 Photographer: Kerri McCabe Description: Looking SE, this photo showed the clarity of the liquid in the drainage conveyance beside the receiving stream and directed toward the stormwater pond. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 29 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010196 Orientation: W Date of Photo: 05/22/2024 Time of Photo: 1259 Latitude: 33.203967 Longitude: -92.615283 Photographer: Kerri McCabe Description: Looking W, this photo showed the drainage area imbedded within the process area at the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 30 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010198 Orientation: NE Date of Photo: 05/22/2024 Time of Photo: 1300 Latitude: 33.204021 Longitude: -92.615184 Photographer: Kerri McCabe Description: Looking NE, this photo showed one of the concrete, bulk storage pits located onsite. All concrete, bulk storage pits are permitted under an Arkansas State No-Discharge (SND) permit (5077-WR7), which expired 5/31/2021 and was administratively extended by the state. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 31 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010199 Orientation: NW Date of Photo: 05/22/2024 Time of Photo: 1300 Latitude: 33.204067 Longitude: -92.615183 Photographer: Kerri McCabe Description: Looking NW, this photo showed the piping at the holding pit viewed in Photo No. 30. Black staining, hydrocarbon sheen, and flow indicators were noted in the process area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 32 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010200 Orientation: N Date of Photo: 05/22/2024 Time of Photo: 1301 Latitude: 33.204000 Longitude: -92.614900 Photographer: Kerri McCabe Description: Looking N, this photo showed dead earthworms in the unknown liquid waste material on the ground at the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 33 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010202 Orientation: E Date of Photo: 05/22/2024 Time of Photo: 1302 Latitude: 33.204033 Longitude: -92.614667 Photographer: Kerri McCabe Description: Looking E, this photo showed the building used for the storage of sawdust (bulking material). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 34 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010203 Orientation: W-NW Date of Photo: 05/22/2024 Time of Photo: 1303 Latitude: 33.204250 Longitude: -92.614933 Photographer: Kerri McCabe Description: Looking W-NW, this photo showed a frac tank stored between two (2) subsurface, concrete pits. Sawdust (bulking material) and unknown liquid wastes noted around the area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 35 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010204 Orientation: W Date of Photo: 05/22/2024 Time of Photo: 1303 Latitude: 33.204250 Longitude: -92.614933 Photographer: Kerri McCabe Description: Looking W, this photo showed the subsurface, concrete pit to the left of the frac tank in Photo No. 34. Unknown liquid wastes and sawdust (bulking material) were noted around the area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 36 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010205 Orientation: W-SW Date of Photo: 05/22/2024 Time of Photo: 1303 Latitude: 33.204350 Longitude: -92.615067 Photographer: Kerri McCabe Description: Looking W-SW, this photo showed the subsurface, concrete pit to the right of the frac tank in Photo No. 34. Unknown liquid wastes were observed in the pit. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 37 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010206 Orientation: NW Date of Photo: 05/22/2024 Time of Photo: 1304 Latitude: 33.204400 Longitude: -92.615350 Photographer: Kerri McCabe Description: Looking NW, this photo showed a large, concrete pit used for storing liquid wastes (contents unknown). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 38 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010207 Orientation: W-NW Date of Photo: 05/22/2024 Time of Photo: 1304 Latitude: 33.204400 Longitude: -92.615432 Photographer: Kerri McCabe Description: Looking W-NW, this photo showed the available freeboard in the concrete pit in Photo No. 37. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 39 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010208 Orientation: W-NW Date of Photo: 05/22/2024 Time of Photo: 1304 Latitude: 33.204385 Longitude: -92.615478 Photographer: Kerri McCabe Description: Looking W-NW, this photo showed an area of the concrete pit that had evidence of overflows. Overflows directed toward the stormwater pond onsite. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 40 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010209 Orientation: N-NE Date of Photo: 05/22/2024 Time of Photo: 1305 Latitude: 33.204396 Longitude: -92.615476 Photographer: Kerri McCabe Description: Looking N-NE, this photo showed another large, concrete pit used to catch leachate from the bulked material. Soil used to make an earthen berm. An erosion gully was noted in the earthen berm with overflows directed toward the concrete pit in Photo No. 37. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 41 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010211 Orientation: E-NE Date of Photo: 05/22/2024 Time of Photo: 1305 Latitude: 33.204550 Longitude: -92.615400 Photographer: Kerri McCabe Description: Looking E-NE, this photo showed sawdust that had been bulked with liquid wastes partially covered with awning. Leachate drained to large, concrete pit from Photo No. 40. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 42 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010212 Orientation: SW Date of Photo: 05/22/2024 Time of Photo: 1305 Latitude: 33.204667 Longitude: -92.615417 Photographer: Kerri McCabe Description: Looking SW, this photo showed an additional view of the large, concrete pit in Photo No. 37. Black staining was noted outside the concrete pit. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 43 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010213 Orientation: SE Date of Photo: 05/22/2024 Time of Photo: 1305 Latitude: 33.204700 Longitude: -92.615333 Photographer: Kerri McCabe Description: Looking SE, this photo showed bulked material partially covered with leachate drained toward the concrete pit in Photo No. 40. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 44 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010214 Orientation: SE Date of Photo: 05/22/2024 Time of Photo: 1306 Latitude: 33.204733 Longitude: -92.615333 Photographer: Kerri McCabe Description: Looking SE, this photo showed bulked material with leachate. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 45 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010215 Orientation: SE Date of Photo: 05/22/2024 Time of Photo: 1306 Latitude: 33.204708 Longitude: -92.615333 Photographer: Kerri McCabe Description: Looking SE, this photo showed an additional view of the bulked material and leachate from Photo No. 44. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 46 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010216 Orientation: W-SW Date of Photo: 05/22/2024 Time of Photo: 1307 Latitude: 33.204667 Longitude: -92.614583 Photographer: Kerri McCabe Description: Looking W-SW, this photo showed an overview of the mixing area with liquid wastes in frac tanks (photo left), and bulked material stockpiled. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 47 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010218 Orientation: W Date of Photo: 05/22/2024 Time of Photo: 1320 Latitude: 33.204517 Longitude: -92.614483 Photographer: Kerri McCabe Description: Looking W, this photo showed leachate drained from bulked material. Frac tanks (photo left) were not labeled (contents unknown). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 48 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010219 Orientation: S-SW Date of Photo: 05/22/2024 Time of Photo: 1323 Latitude: 33.204267 Longitude: -92.614117 Photographer: Kerri McCabe Description: Looking S-SW, this photo showed an incomplete "Material / Waste Transfer Form" for an incoming truck. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 49 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010220 Orientation: S-SW Date of Photo: 05/22/2024 Time of Photo: 1324 Latitude: 33.204267 Longitude: -92.614117 Photographer: Kerri McCabe Description: Looking S-SW, this photo showed a Bill of Lading from Code 3 Services, LLC. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 50 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010221 Orientation: E-SE Date of Photo: 05/22/2024 Time of Photo: 1326 Latitude: 33.203617 Longitude: -92.613833 Photographer: Kerri McCabe Description: Looking E-SE, this photo showed the receiving stream (UT of Boggy Creek) east of the culvert under Industrial Road upstream of the facility. Characteristics were typical of an intermittent, urban stream with no hydrocarbon sheen or odor, and aquatic biota were present. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 51 Location: MidAmerica Environmental Holdings, LLC - USA Disposal - El Dorado at 101 Warehouse Drive, El Dorado, AR 71730 (33.204439, -92.613947) City: El Dorado County/Parish: Union State: Arkansas Photo File Name: R0010222 Orientation: W-NW Date of Photo: 05/22/2024 Time of Photo: 1327 Latitude: 33.203617 Longitude: -92.613833 Photographer: Kerri McCabe Description: Looking W-NW, this photo showed the receiving stream (UT of Boggy Creek) west of the culvert under Industrial Road upstream of the facility. Characteristics were typical of an intermittent, urban stream with no hydrocarbon sheen or odor, and aquatic biota were present.