Document oMy2gNObRgenZdmnNDbkk7r5g

Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date(s): Media: Regulatory Program(s) April 30, 2018 Water (CWA) NPDES - Brine Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: Perdure Petroleum, LLC North Burbank Unit 56-12 36.793783N, -96.738003W (Sect. 26, T 27N, R 5E) Shidler, Oklahoma 74652 101 N. Robinson Ave. 13th Floor Oklahoma City, Oklahoma 73102 Okmulgee Robert Sutherland (281) 668 - 8488; bobs@perdurepetro.com FRS Number: Identification/Permit Number: Media Number: NAICS: SIC: N/A OKU000870 N/A 211111 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/Date Sanborn, Kent Digitally signed by Sanborn, Kent DN: cn=Sanborn, Kent, email=Sanborn.Kent@epa.gov Date: 2018.06.18 15:58:54 -05'00' Kent W. Sanborn GUY TIDMORE Digitally signed by GUY TIDMORE DN: c=US, o=U.S. Government, ou=USEPA, ou=Staff, cn=GUY TIDMORE, dnQualifier=0000012807 Date: 2018.06.19 11:49:42 -05'00' Guy Tidmore Date 19 JUN 2018 Date 6ENFORM-019-R7 (2/15/2017) 1 Section I - INTRODUCTION Perdure Petroleum, LLC / North Burbank Unit 56-12 Inspection Date: April 30, 2018 PURPOSE OF THE INSPECTION EPA Region 6 inspector Kent W. Sanborn arrived at the Perdure Petroleum, LLC, North Burbank Unit 5612 lease on a property near Shidler, Osage County, Oklahoma at about 11:00 am on April 30, 2018 for an inspection. The inspection was initiated by a reported discharge of fluids into a nearby water body by Perdure Petroleum, LLC. There were several company representatives at the site during the inspection. The discharge had reached a tributary of Mud Creek. Cleanup activities were active at the site during the inspection. The inspection was conducted under the authority of Section 308 of the Clean Water Act (CWA). The scope of the inspection was to determine if the facility was in compliance with the CWA, including Section 301, and to identify and document discharges of produced wastewater (brine) to waters of the United States. FACILITY DESCRIPTION The origination point of discharge was from a plastic flowline that parted at a welded joint and leaked brine fluids to the tributary of Mud Creek. That line was just northwest of a tributary of Mud Creek. Mud Creek was braided with several tributaries joining together in this area and the discharge occurred in a tributary of Mud Creek. This facility is located directly behind the Perdure field office, which is west of Shidler, Oklahoma. Section II - OBSERVATIONS I initially arrived at the Perdure Petroleum, LLC, North Burbank Unit 56-12 lease at about 11:00 am on April 30, 2018. Photo 1 shows the nearest well to the flow line break located a few yards southeast of the discharge point of produced water, or brine. The flow line, which was repaired at the time of the inspection is shown in Photo 2. The flow path of brine and oil flowed south (Photo 3) then southeast (Photo 4) toward the tributary of Mud Creek. The point of entry to the tributary of Mud Creek and the first temporary dam are shown in Photo 5. A Specific Conductance field reading taken with a calibrated YSI 30 Conductivity Meter at the point of entry, from fluids at the first temporary dam, was 105.7 milliSiemens/centimeters (mS/cm), which was converted to 68,705 milligrams/Liter (mg/L) Total Dissolved Solids (TDS) as shown in Appendix 2 (Photo 6 in Appendix 1). A second dam was constructed on the tributary farther south, downstream from the point of entry (Photo 7). Numerous dead fish were seen at this point (Photos 8,9, and 10). A Specific Conductance field reading taken at the second temporary dam, from fluids at the second temporary dam was 77.7 mS/cm, which was converted to 50,505 mg/L TDS as shown in Appendix 2 (Photo 11 in Appendix 1). The third temporary dam was located downstream from the second temporary dam, where an additional branch to the tributary of Mud Creek was flowing into the tributary from the northeast shown in Photo 12. A Specific Conductance field reading taken at the third temporary dam, from fluids at the third temporary dam was 117.5 mS/cm, which was converted to 76,375 mg/L TDS as shown in Appendix 2 (Photo 13 in Appendix 1). Farther downstream trucks were removing brine from the tributary of Mud Creek (Photo 14). I observed several crayfish and a turtle were found dead in this area of the tributary (Photos 15, 16, and 17). An additional Specific Conductance field reading was taken at the third temporary dam and 2 Perdure Petroleum, LLC / North Burbank Unit 56-12 Inspection Date: April 30, 2018 was 101.9 mS/cm, which was converted to 66,235 mg/L TDS as shown in Appendix 2 (Photo 18 in Appendix 1). A pump was being used downstream to pump water from a 4th dammed area in the tributary of Mud Creek (Photo 19). That water was being sent to a frac tank (Photo 20) south. An additional Specific Conductance field reading was taken from the tributary of Mud Creek at Photo No. 20 location and was 5.45 mS/cm, which was converted to 3,542.5 mg/L TDS as shown in Appendix 2 (Photo 21 in Appendix 1). The tributary near the frac tank location is shown in Photo 22. The tributary of Mud Creek was joined by another branch of Mud Creek coming from the northeast. The confluence of these two tributaries was downstream of all the temporary dams within the tributary of Mud Creek. A Specific Conductance field reading was taken below the confluence of tributaries at Photo No. 22 location and was 1,227 microSiemens/centimeters (uS/cm), which was converted to 797.5 mg/L TDS as shown in Appendix 2 (Photo 23 in Appendix 1). An unaffected upstream area in a tributary of Mud Creek, which was upstream from the contaminated area near the third temporary dam and is shown in Photo 24. This tributary was the first branch that joined the contaminated tributary of Mud Creek near the third dam site. A Specific Conductance field reading was taken at the location shown in Photo No. 24, an unaffected portion of the tributary of Mud Creek and was 1,156 uS/cm, which was converted to 751.4 mg/L TDS as shown in Appendix 2 (Photo 25 in Appendix 1). Section III - AREAS OF CONCERN There was dead aquatic life along the tributary of Mud Creek, including less than 50 dead fish, dead crayfish, and one dead turtle. There were onsite remedial activities ongoing during the inspection. I observed elevated levels of TDS in the tributary of Mud Creek from a flow line that leaked. I observed a flow path from the flow line that leaked to the tributary of Mud Creek. Section IV - FOLLOW UP A follow up inspection will be conducted as needed. Section V - LIST OF APPENDICES Appendix 1 - Photo Log - 25 photos taken 4/30/2018. Appendix 2 - Table 1: Conversion of Specific Conductance Readings to Total Dissolved Solids. 3 Perdure Petroleum, LLC/North Burbank Unit 56-12 Inspection Date: 4/30/2018 Appendix 1 Photographic Log (25 photos) UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 36.793783N, -96.738003W (Sect. 26, T 27N, R 5E) City: Shidler County: Osage State: Oklahoma Photo File Name: Photo 1 (DSC_0034) Orientation: South Date of Photo: 04/30/2018 Time of Photo: 11:28 am Latitude: 36.794062N Longitude: -96.737850W Photographer: K.W. Sanborn Description: This photo shows the sign at the Perdure Petroleum, LLC, North Burbank Unit 56-12. A discharge of produced fluids (brine) originated in a line a few yards from the injection well at this site. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 36.793783N, -96.738003W (Sect. 26, T 27N, R 5E) City: Shidler County: Osage State: Oklahoma Photo File Name: Photo 2 (DSC_0035) Orientation: Northwest Date of Photo: 04/30/2018 Time of Photo: 11:28 am Latitude: 36.794062N Longitude: -96.737850W Photographer: K.W. Sanborn Description: The line shown parted and temporarily repaired after spilling produced water, or brine, and some oil to the nearby tributary of Mud Creek. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 36.793783N, -96.738003W (Sect. 26, T 27N, R 5E) City: Shidler County: Osage State: Oklahoma Photo File Name: Photo 3 (DSC_0033) Orientation: Northwest Date of Photo: 04/30/2018 Time of Photo: 11:28 am Latitude: 36.794062N Longitude: -96.737850W Photographer: K.W. Sanborn Description: The discharge of brine flowed from the leaking flow line south towards the tributary of Mud Creek, as shown in this photo. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 36.793783N, -96.738003W (Sect. 26, T 27N, R 5E) City: Shidler County: Osage State: Oklahoma Photo File Name: Photo 4 (DSC_0037) Orientation: Southeast Date of Photo: 04/30/2018 Time of Photo: 11:29 am Latitude: 36.793801N Longitude: -96.737920W Photographer: K.W. Sanborn Description: This discharge flow path flowed towards the tributary of Mud Creek located near the tank truck seen in this photo. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 36.793783N, -96.738003W (Sect. 26, T 27N, R 5E) City: Shidler County: Osage State: Oklahoma Photo File Name: Photo 5 (DSC_0038) Orientation: South Date of Photo: 04/30/2018 Time of Photo: 11:33 am Latitude: 36.791907N Longitude: -96.737520W Photographer: K.W. Sanborn Description: The first temporary dam along the flow path at the point of entry to the tributary of Mud Creek is shown here. I observed oil sheen at this location. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 36.793783N, -96.738003W (Sect. 26, T 27N, R 5E) City: Shidler County: Osage State: Oklahoma Photo File Name: Photo 6 (DSC_0046) Orientation: South Date of Photo: 04/30/2018 Time of Photo: 11:58 am Latitude: 36.791907N Longitude: -96.737520W Photographer: K.W. Sanborn Description: A Specific Conductance field reading was taken with a calibrated YSI 30 Conductivity Meter at the point of entry, from fluids at the first temporary dam was 105.7 milliSiemens/centimeters (mS/cm), which was converted to 68,705 milligrams/Liter (mg/L) Total Dissolved Solids (TDS) as shown in Appendix 2. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 36.793783N, -96.738003W (Sect. 26, T 27N, R 5E) City: Shidler County: Osage State: Oklahoma Photo File Name: Photo 7 (DSC_0039) Orientation: South Date of Photo: 04/30/2018 Time of Photo: 11:34 am Latitude: 36.791442N Longitude: -96.737577W Photographer: K.W. Sanborn Description: The brine flowed south to the second temporary dam in the tributary of Mud Creek shown here. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 36.793783N, -96.738003W (Sect. 26, T 27N, R 5E) City: Shidler County: Osage State: Oklahoma Photo File Name: Photo 8 (DSC_0040) Orientation: South Date of Photo: 04/30/2018 Time of Photo: 11:35 am Latitude: 36.791442N Longitude: -96.737577W Photographer: K.W. Sanborn Description: I observed dead fish along the tributary of Mud Creek the second temporary dam location. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 36.793783N, -96.738003W (Sect. 26, T 27N, R 5E) City: Shidler County: Osage State: Oklahoma Photo File Name: Photo 9 (DSC_0041) Orientation: East Date of Photo: 04/30/2018 Time of Photo: 791442N Latitude: 36.737577W Longitude: -96.120737W Photographer: K.W. Sanborn Description: I observed more dead fish in and around the second temporary dam 2 location. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 10 36.793783N, -96.738003W (Sect. 26, T 27N, R 5E) City: Shidler County: Osage State: Oklahoma Photo File Name: Photo 10 (DSC_0042) Orientation: East Date of Photo: 04/30/2018 Time of Photo: 11:35 am Latitude: 36.791442N Longitude: -96.737577W Photographer: K.W. Sanborn Description: I observed another dead fish at the second dam site in the tributary of Mud Creek. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 11 36.793783N, -96.738003W (Sect. 26, T 27N, R 5E) City: Shidler County: Osage State: Oklahoma Photo File Name: Photo 11 (DSC_0048) Orientation: East Date of Photo: 04/30/2018 Time of Photo: 11:58 am Latitude: 36.791442N Longitude: -96.737577W Photographer: K.W. Sanborn Description: A Specific Conductance field reading was taken at the second temporary dam, from fluids at the second temporary dam was 77.7 mS/cm, which was converted to 50,505 mg/L TDS as shown in Appendix 2. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 12 36.793783N, -96.738003W (Sect. 26, T 27N, R 5E) City: Shidler County: Osage State: Oklahoma Photo File Name: Photo 12 (DSC_0050) Orientation: North Date of Photo: 04/30/2018 Time of Photo: 12:03 pm Latitude: 36.790455N Longitude: -96.737533W Photographer: K.W. Sanborn Description: The third temporary dam shown here is located downstream from the second temporary dam, where an additional branch to the tributary of Mud Creek was flowing into the tributary from the northeast. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 13 36.793783N, -96.738003W (Sect. 26, T 27N, R 5E) City: Shidler County: Osage State: Oklahoma Photo File Name: Photo 13 (DSC_0049) Orientation: North Date of Photo: 04/30/2018 Time of Photo: 11:59 am Latitude: 36.790455N Longitude: -96.737533W Photographer: K.W. Sanborn Description: A Specific Conductance field reading was taken at the third temporary dam, from fluids at the third temporary dam was 117.5 mS/cm, which was converted to 76,375 mg/L TDS as shown in Appendix 2. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 14 36.793783N, -96.738003W (Sect. 26, T 27N, R 5E) City: Shidler County: Osage State: Oklahoma Photo File Name: Photo 14 (DSC_0058) Orientation: North Date of Photo: 04/30/2018 Time of Photo: 12:09 pm Latitude: 36.789708N Longitude: -96.737530W Photographer: K.W. Sanborn Description: The tributary of Mud Creek south of the third temporary dam is shown here. that trucks were pumping out the tributary during the inspection at this location. I observed UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 15 36.793783N, -96.738003W (Sect. 26, T 27N, R 5E) City: Shidler County: Osage State: Oklahoma Photo File Name: Photo 15 (DSC_0044) Orientation: East Date of Photo: 04/30/2018 Time of Photo: 11:38 am Latitude: 36.789708N Longitude: -96.737530W Photographer: K.W. Sanborn Description: I observed one dead crayfish near the location shown in Photo 14 in the tributary of Mud Creek. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 16 36.793783N, -96.738003W (Sect. 26, T 27N, R 5E) City: Shidler County: Osage State: Oklahoma Photo File Name: Photo 16 (DSC_0045) Orientation: East Date of Photo: 04/30/2018 Time of Photo: 11:38 am Latitude: 36.789708N Longitude: -96.737530W Photographer: K.W. Sanborn Description: I observed an additional dead crayfish near the third temporary dam site in the tributary of Mud Creek. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 17 36.793783N, -96.738003W (Sect. 26, T 27N, R 5E) City: Shidler County: Osage State: Oklahoma Photo File Name: Photo 17 (DSC_0056) Orientation: West Date of Photo: 04/30/2018 Time of Photo: 12:07 pm Latitude: 36.789708N Longitude: -96.737530W Photographer: K.W. Sanborn Description: I observed a dead turtle in the tributary of Mud Creek near the third temporary dam during the inspection. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 18 36.793783N, -96.738003W (Sect. 26, T 27N, R 5E) City: Shidler County: Osage State: Oklahoma Photo File Name: Photo 18 (DSC_0057) Orientation: West Date of Photo: 04/30/2018 Time of Photo: 12:09 pm Latitude: 36.789708N Longitude: -96.737530W Photographer: K.W. Sanborn Description: An additional Specific Conductance field reading was taken at the third temporary dam and was 101.9 mS/cm, which was converted to 66,235 mg/L TDS as shown in Appendix 2. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 19 36.793783N, -96.738003W (Sect. 26, T 27N, R 5E) City: Shidler County: Osage State: Oklahoma Photo file Name: Photo 19 (DSC_0061) Orientation: North Date of Photo: 04/30/2018 Time of Photo: 12:27 pm Latitude: 36.788731N Longitude: -96.738708W Photographer: K.W. Sanborn Description: I observed a fourth temporary dam, which is shown here in this photo. used to pump tributary fluids to a frac tank south of this area. A pump was being UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 20 36.793783N, -96.738003W (Sect. 26, T 27N, R 5E) City: Shidler County: Osage State: Oklahoma Photo File Name: Photo 20 (DSC_0062) Orientation: South Date of Photo: 04/30/2018 Time of Photo: 12:27 pm Latitude: 36.788731N Longitude: -96.738708W Photographer: K.W. Sanborn Description: This photo shows a view of the tributary of Mud Creek south of the fourth temporary dam. I observed that most of the fluids upstream of this point along the tributary had been removed due to pumping out activities. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 21 36.793783N, -96.738003W (Sect. 26, T 27N, R 5E) City: Shidler County: Osage State: Oklahoma Photo File Name: Photo 21 (DSC_0063) Orientation: West Date of Photo: 04/30/2018 Time of Photo: 12:28 pm Latitude: 36.788731N Longitude: -96.738708W Photographer: K. W. Sanborn Description: An additional Specific Conductance field reading was taken at Photo No. 20 and was 5.45 mS/cm, which was converted to 3,542.5 mg/L TDS as shown in Appendix 2. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 22 36.793783N, -96.738003W (Sect. 26, T 27N, R 5E) City: Shidler County: Osage State: Oklahoma Photo File Name: Photo 22 (DSC_0065) Orientation: Northeast Date of Photo: 04/30/2018 Time of Photo: 1:15 pm Latitude: 36.786398N Longitude: -96.739476W Photographer: K.W. Sanborn Description: The tributary of Mud Creek was joined by another branch of Mud Creek coming from the northeast shown here. The confluence of the two tributaries was downstream of all the temporary dams within the tributary of Mud Creek. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 23 36.793783N, -96.738003W (Sect. 26, T 27N, R 5E) City: Shidler County: Osage State: Oklahoma Photo File Name: Photo 23 (DSC_0064) Orientation: North Date of Photo: 04/30/2018 Time of Photo: 1:15 pm Latitude: 36.786398N Longitude: -96.739476W Photographer: K.W. Sanborn Description: A Specific Conductance field reading was taken at Photo No. 22 and was 1,227 microSiemens/centimeters (uS/cm), which was converted to 797.5 mg/L TDS as shown in Appendix 2. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 24 36.793783N, -96.738003W (Sect. 26, T 27N, R 5E) City: Shidler County: Osage State: Oklahoma Photo File Name: Photo 24 (DSC_0053) Orientation: Northeast Date of Photo: 04/30/2018 Time of Photo: 12:06 pm Latitude: 36.790455N Longitude: -96.737533W Photographer: K.W. Sanborn Description: This photo shows an unaffected upstream area in a tributary of Mud Creek, which is upstream from the contaminated area near the third temporary dam. This tributary was the first branch that joined the contaminated tributary of Mud Creek near the third dam site. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 25 36.793783N, -96.738003W (Sect. 26, T 27N, R 5E) City: Shidler County: Osage State: Oklahoma Photo File Name: Photo 25 (DSC_0054) Orientation: North Date of Photo: 04/30/2018 Time of Photo: 12:06 pm Latitude: 36.790455N Longitude: -96.737533W Photographer: K.W. Sanborn Description: A Specific Conductance field reading was taken at Photo No. 24, an unaffected portion of the tributary of Mud Creek and was 1,156 uS/cm, which was converted to 751.4 mg/L TDS as shown in Appendix 2. Perdure Petroleum, LLC / North Burbank Unit 56-12 Inspection Date: 4/30/2018 Appendix 2 Table 1: Conversion of Specific Conductance Readings to Total Dissolved Solids Perdure Petroleum, LLC / North Burbank Unit 56-12 Inspection Date: 4/30/2018 Table 1 Conversion from Specific Conductance (milliSiemens/centimeter) Field Readings to Total Dissolved Solids (milligrams/Liter) Measurements taken with a calibrated YSI 30 Conductivity Meter Inspection Report Photo No. Photo No. 6 Specific Conductance Reading (mS/cm) 105.7 mS/cm Specific Conductance (uS/cm) 105,700 uS/cm Converted Total Dissolved Solids (mg/L)* 68,705 mg/L Photo No. 11 77.7 mS/cm 77,700 uS/cm 50,505 mg/L Photo No. 13 117.5 mS/cm 117,500 uS/cm 76,375 mg/L Photo No. 18 101.9 mS/cm 101,900 uS/cm 66,235 mg/L Photo No. 21 5.45 mS/cm 5,450 uS/cm 3,542.5 mg/L Photo No. 22 N/A 12227 uS/cm 797.5 mg/L Photo No. N/A 1156 uS/cm 751.4 mg/L *The default conversion value to convert specific conductance (uS/cm) to Total Dissolved Solids (TDS) used in this inspection report was 0.65. For example, 105.7 uS/cm multiplied by 0.65 equates to 68,705 mg/L TDS.