Document o7wv7jK9pgOdDgDKBwpZ9XXg

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: Corley Trust, LLC Wilson #7 SWD Tank Battery In Smackover (Sandyland) from Highway 7 N, then right onto Hwy 7B, right onto Gas Plant Rd, continuing left on Gas Plant Rd, and left onto an oil lease road at 33.353841, -92.692327. Smackover, AR, 71762 410 W. 6th Smackover, AR, 71762 Union County 870-725-3928 Jeff Corley (501-920-5869) Person Responsible for Operation corleytrust@att.net FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: N/A ARU002260 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 10:44:35 -06'00' Date JEANNE ECKHART Date: 2025.01.10 07:56:50 -06'00' Digitally signed by JEANNE ECKHART Jeanne Eckhart Date 6ENFORM-019-R8.2 (02/12/2020) 1 Corley Trust, LLC / Wilson #7 SWD Tank Battery (ARU002260 / CWA) Inspection Date 11/08/2024 Section I - INTRODUCTION PURPOSE OF THE INSPECTION EPA Region 6 inspector Kerri McCabe (lead) arrived at the Corley Trust, LLC / Wilson #7 SWD Tank Battery ("facility"), at 0945 on 11/08/2024 for an unannounced follow-up inspection. The facility is located from Highway 7 N, then right onto Hwy 7B, right onto Gas Plant Rd, continuing left on Gas Plant Rd, and left onto an oil lease road at 33.353841, -92.692327. 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. The facility was originally inspected by Inspector Uma Lad on 10/07/2024. FACILITY DESCRIPTION EPA conducted an inspection on the Corley Trust, LLC / Wilson #7 SWD Tank Battery, which contained six (6) in service storage tanks/separators for crude oil and saltwater, two out of service tanks/separators, one production well (Wilson #5), and one (1) Saltwater Disposal (SWD) well (Wilson #7). Map 1. Aerial imagery (Google Earth dated 09/26/2023) of the Corley Trust, LLC / Wilson #7 SWD Tank Battery facility. 2 Corley Trust, LLC / Wilson #7 SWD Tank Battery (ARU002260 / CWA) Inspection Date 11/08/2024 Section II - OBSERVATIONS I observed the Corley Trust, LLC / Wilson #7 SWD Tank Battery facility, signage, and associated secondary containment, storage tanks, separators/treaters, production well, and saltwater disposal (SWD) well; see Appendix 1 (Photograph Log), Photo No. 1 and No. 2. For additional GPS location and photo metadata, see Appendix 1. I observed loose oil inside secondary containment, see Photo No. 3, No. 4, and No. 12. I observed the SWD well (Wilson #7), see Photo No. 5. I observed transfer pipes outside secondary containment without catchment buckets and loose oil on the ground around the pipes, see Photo No. 6 through No. 8. I observed the area of the workover pit that was identified from the 10/07/2024 inspection, see Photo No. 9, No. 10, No. 13, and No. 14. I observed the drainpipe for secondary containment with a cap and closed valve, see Photo No. 11. I observed a production well (Wilson #5) with minor residual oil staining on the ground, see Photo No. 15. I observed two "out of service" storage tanks without proper labeling, see Photo No. 16 and No. 17. Section III - AREAS OF CONCERN No closing conference was held due to no personnel with Corley Trust, LLC being present during the inspection. The operator was notified by the Arkansas Oil and Gas Commission (AOGC) on 10/09/2024. Areas of concern at the time of the inspection include the following: Loose, residual oil inside and outside secondary containment for the facility, Transfer pipes outside secondary containment without catchment buckets, Minor residual oil staining around a production well (Wilson #5) onsite, and Two tanks without proper "out of service" labeling outside secondary containment. 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 - 17 photos taken 11/08/2024. 3 Corley Trust, LLC / Wilson #7 SWD Tank Battery (ARU002260 / CWA) Inspection Date 11/08/2024 Appendix 1 Photograph Log 17 Photos UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: In Smackover (Sandyland) from Highway 7 N, then right onto Hwy 7B, right onto Gas Plant Rd, continuing left on Gas Plant Rd, and left onto an oil lease road at 33.353841, -92.692327. City: Smackover County/Parish: Union State: Arkansas Photo File Name: 100-0299 Orientation: 28 NNE Date of Photo: 11/08/2024 Time of Photo: 1028 Latitude: 33.353650 Longitude: -92.692350 Photographer: Kerri McCabe Description: Looking NNE, this photo shows the signage at the Wilson #7 Saltwater Disposal (SWD) well tank battery ("facility"). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: In Smackover (Sandyland) from Highway 7 N, then right onto Hwy 7B, right onto Gas Plant Rd, continuing left on Gas Plant Rd, and left onto an oil lease road at 33.353841, -92.692327. City: Smackover County/Parish: Union State: Arkansas Photo File Name: 100-0300 Orientation: 65 ENE Date of Photo: 11/08/2024 Time of Photo: 1029 Latitude: 33.353683 Longitude: -92.692531 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: In Smackover (Sandyland) from Highway 7 N, then right onto Hwy 7B, right onto Gas Plant Rd, continuing left on Gas Plant Rd, and left onto an oil lease road at 33.353841, -92.692327. City: Smackover County/Parish: Union State: Arkansas Photo File Name: 100-0301 Orientation: 65 ENE Date of Photo: 11/08/2024 Time of Photo: 1029 Latitude: 33.353834 Longitude: -92.692505 Photographer: Kerri McCabe Description: Looking ENE, this photo shows loose oil inside secondary containment at the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: In Smackover (Sandyland) from Highway 7 N, then right onto Hwy 7B, right onto Gas Plant Rd, continuing left on Gas Plant Rd, and left onto an oil lease road at 33.353841, -92.692327. City: Smackover County/Parish: Union State: Arkansas Photo File Name: 100-0302 Orientation: 338 NNW Date of Photo: 11/08/2024 Time of Photo: 1030 Latitude: 33.353917 Longitude: -92.692550 Photographer: Kerri McCabe Description: Looking NNW, this photo shows the flowpath to the drainpipe inside secondary containment at the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: In Smackover (Sandyland) from Highway 7 N, then right onto Hwy 7B, right onto Gas Plant Rd, continuing left on Gas Plant Rd, and left onto an oil lease road at 33.353841, -92.692327. City: Smackover County/Parish: Union State: Arkansas Photo File Name: 100-0303 Orientation: 46 NE Date of Photo: 11/08/2024 Time of Photo: 1030 Latitude: 33.353800 Longitude: -92.692383 Photographer: Kerri McCabe Description: Looking NE, this photo shows the Wilson #7 SWD well located at the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: In Smackover (Sandyland) from Highway 7 N, then right onto Hwy 7B, right onto Gas Plant Rd, continuing left on Gas Plant Rd, and left onto an oil lease road at 33.353841, -92.692327. City: Smackover County/Parish: Union State: Arkansas Photo File Name: 100-0304 Orientation: 52 NE Date of Photo: 11/08/2024 Time of Photo: 1030 Latitude: 33.353900 Longitude: -92.692283 Photographer: Kerri McCabe Description: Looking NE, this photo shows the front view of the facility with transfer pipes lacking catchment buckets and loose oil on the ground outside the secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: In Smackover (Sandyland) from Highway 7 N, then right onto Hwy 7B, right onto Gas Plant Rd, continuing left on Gas Plant Rd, and left onto an oil lease road at 33.353841, -92.692327. City: Smackover County/Parish: Union State: Arkansas Photo File Name: 100-0305 Orientation: 29 NNE Date of Photo: 11/08/2024 Time of Photo: 1030 Latitude: 33.353909 Longitude: -92.692265 Photographer: Kerri McCabe Description: Looking NNE, this photo shows one of two transfer pipes without catchment bucket and loose oil outside secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: In Smackover (Sandyland) from Highway 7 N, then right onto Hwy 7B, right onto Gas Plant Rd, continuing left on Gas Plant Rd, and left onto an oil lease road at 33.353841, -92.692327. City: Smackover County/Parish: Union State: Arkansas Photo File Name: 100-0306 Orientation: 26 NNE Date of Photo: 11/08/2024 Time of Photo: 1030 Latitude: 33.354100 Longitude: -92.692300 Photographer: Kerri McCabe Description: Looking NNE, this photo shows two of two transfer pipes without catchment bucket and loose oil outside secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 Location: In Smackover (Sandyland) from Highway 7 N, then right onto Hwy 7B, right onto Gas Plant Rd, continuing left on Gas Plant Rd, and left onto an oil lease road at 33.353841, -92.692327. City: Smackover County/Parish: Union State: Arkansas Photo File Name: 100-0308 Orientation: 169 S Date of Photo: 11/08/2024 Time of Photo: 1031 Latitude: 33.354133 Longitude: -92.692283 Photographer: Kerri McCabe Description: Looking S, this photo shows the closure of a workover pit that was identified at the facility during the 10/07/2024 inspection conducted by Inspector Uma Lad. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 10 Location: In Smackover (Sandyland) from Highway 7 N, then right onto Hwy 7B, right onto Gas Plant Rd, continuing left on Gas Plant Rd, and left onto an oil lease road at 33.353841, -92.692327. City: Smackover County/Parish: Union State: Arkansas Photo File Name: 100-0309 Orientation: 64 ENE Date of Photo: 11/08/2024 Time of Photo: 1031 Latitude: 33.354133 Longitude: -92.692250 Photographer: Kerri McCabe Description: Looking ENE, this photo shows the bridge (background) at Gas Plant Rd that crosses Holmes Creek, which is adjacent to the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 11 Location: In Smackover (Sandyland) from Highway 7 N, then right onto Hwy 7B, right onto Gas Plant Rd, continuing left on Gas Plant Rd, and left onto an oil lease road at 33.353841, -92.692327. City: Smackover County/Parish: Union State: Arkansas Photo File Name: 100-0310 Orientation: 106 ENE Date of Photo: 11/08/2024 Time of Photo: 1032 Latitude: 33.353917 Longitude: -92.692500 Photographer: Kerri McCabe Description: Looking ENE, this photo shows the drainpipe for secondary containment; the valve was closed and capped. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 12 Location: In Smackover (Sandyland) from Highway 7 N, then right onto Hwy 7B, right onto Gas Plant Rd, continuing left on Gas Plant Rd, and left onto an oil lease road at 33.353841, -92.692327. City: Smackover County/Parish: Union State: Arkansas Photo File Name: 100-0311 Orientation: 113 ESE Date of Photo: 11/08/2024 Time of Photo: 1032 Latitude: 33.353883 Longitude: -92.692567 Photographer: Kerri McCabe Description: Looking ESE, this photo shows the pump for the SWD, loose oil, and flow indicators inside secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 13 Location: In Smackover (Sandyland) from Highway 7 N, then right onto Hwy 7B, right onto Gas Plant Rd, continuing left on Gas Plant Rd, and left onto an oil lease road at 33.353841, -92.692327. City: Smackover County/Parish: Union State: Arkansas Photo File Name: 100-0312 Orientation: 41 NE Date of Photo: 11/08/2024 Time of Photo: 1033 Latitude: 33.353900 Longitude: -92.692583 Photographer: Kerri McCabe Description: Looking NE, this photo shows an additional view of the area where a workover pit was located during the 10/07/2024 inspection of the facility UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 14 Location: In Smackover (Sandyland) from Highway 7 N, then right onto Hwy 7B, right onto Gas Plant Rd, continuing left on Gas Plant Rd, and left onto an oil lease road at 33.353841, -92.692327. City: Smackover County/Parish: Union State: Arkansas Photo File Name: 100-0313 Orientation: 55 NE Date of Photo: 11/08/2024 Time of Photo: 1033 Latitude: 33.353917 Longitude: -92.692600 Photographer: Kerri McCabe Description: Looking NE, this photo shows the area from Photo No. 13 that has been covered, grated, and seeded. Emerging seedlings were noted at the time of the inspection. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 15 Location: In Smackover (Sandyland) from Highway 7 N, then right onto Hwy 7B, right onto Gas Plant Rd, continuing left on Gas Plant Rd, and left onto an oil lease road at 33.353841, -92.692327. City: Smackover County/Parish: Union State: Arkansas Photo File Name: 100-0314 Orientation: 171 S Date of Photo: 11/08/2024 Time of Photo: 1033 Latitude: 33.353867 Longitude: -92.692600 Photographer: Kerri McCabe Description: Looking S, this photo shows the Wilson #5 production well located at the facility; residual oil staining noted during the inspection. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 16 Location: In Smackover (Sandyland) from Highway 7 N, then right onto Hwy 7B, right onto Gas Plant Rd, continuing left on Gas Plant Rd, and left onto an oil lease road at 33.353841, -92.692327. City: Smackover County/Parish: Union State: Arkansas Photo File Name: 100-0315 Orientation: 129 SE Date of Photo: 11/08/2024 Time of Photo: 1034 Latitude: 33.353700 Longitude: -92.692450 Photographer: Kerri McCabe Description: Looking SE, this photo shows two storage tanks outside secondary containment without "Out of Service" labeling; view from the tank battery. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 17 Location: In Smackover (Sandyland) from Highway 7 N, then right onto Hwy 7B, right onto Gas Plant Rd, continuing left on Gas Plant Rd, and left onto an oil lease road at 33.353841, -92.692327. City: Smackover County/Parish: Union State: Arkansas Photo File Name: 100-0316 Orientation: 58 ENE Date of Photo: 11/08/2024 Time of Photo: 1034 Latitude: 33.353633 Longitude: -92.692433 Photographer: Kerri McCabe Description: Looking ENE, this photo shows two storage tanks outside secondary containment without "Out of Service" labeling; view from the road.