Document oejvjMRz3b6OQgQYYd45nDj6w

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 11/08/2019 Water, Clean Water Act, National Pollution Discharge Elimination System Oil and Gas, Produced Water Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: Red Oak Operating, LLC Shiloh Lease 33.394962N, -93.463712W Buckner, Arkansas 71827 1997 Columbia 34 Magnolia, Arkansas 71753 Lafayette 870-310-4254 Mark Thomas N/A N/A FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: N/A ARU001274 N/A 211111 1311 Personnel participating in inspection: Kent W. Sanborn U.S. EPA, Region 6, ECDWE 918-557-1615 EPA Lead Inspector Signature/Date Supervisor Signature/Date Digitally signed by Kent W. Sanborn Kent W. Sanborn DN: cn=Kent W. Sanborn, o, ou=6EN-WR, email=sanborn.kent@epa.gov, c=US Date: 2019.12.09 14:24:06 -06'00' Kent W. Sanborn Date GUY TIDMORE Digitally signed by GUY TIDMORE DN: c=US, o=U.S. Government, ou=Environmental Protection Agency, cn=GUY TIDMORE, 0.9.2342.19200300.100.1.1=68001003655426 Date: 2019.12.10 14:37:58 -06'00' Guy Tidmore 12 DEC 2019 Date 6ENFORM-019-8 (10/31/2019) 1 Section I - INTRODUCTION Red Oak Operating, LLC / Shiloh Lease Inspection Date: 11/08/2019 PURPOSE OF THE INSPECTION EPA Region 6 inspector Kent W. Sanborn arrived at the Red Oak Operating, LLC Shiloh Lease near Stamps, Arkansas at about 10:30 AM on November 8, 2019 for an unannounced inspection. There were no company representatives at the site. The inspection was conducted to determine the facility's compliance with the Clean Water Act (CWA). The scope of the inspection was to determine if the facility was in compliance with the CWA, and to identify and document unauthorized discharges of produced wastewater (brine) to a water of the United States. FACILITY DESCRIPTION There were no signs on the lease or wells that indicate a legal description or location. The area was known as the Shiloh oil and gas field. The discharge of produced water, or brine, originated from the facility associated with the Shiloh Lease, where brine was stored. The brine was being released out a drain valve and pipe effectively draining the secondary containment pit to the nearby Clear Creek. The origination point of discharge was the tank battery secondary containment pit, and the pit fluids, including brine drained directly to Clear Creek. Section II - OBSERVATIONS I initially arrived at the Red Oak Operating, LLC Shiloh lease at about 10:30 AM on November 8, 2019. Identification of the lease ownership is shown in Photo 1. An additional sign was located at the tank indicating an additional owner or operator of the lease was present (Photo 2). The pit at the battery, which was the source of the brine discharge, is shown in Photo 3 and Photo 4. I observed that the pit had been completely drained. The pit was drained through a pipe and valve (Photo 5) and fluids, including brine, flowed east to Clear Creek. With a calibrated YSI Pro 30 conductivity meter, I took a Total Dissolved Solids (TDS) reading at the pipe exit of the pit and it measured 17,762 milligrams per liter (mg/L) (Photo 6). The discharge flowed along the south boundary of the tank battery and then flowed east toward Clear Creek (Photo 7). TDS at the location shown in Photo 7 measured 20,935 mg/L (Photo 8). The discharge entered the forested area farther east as shown in Photo 9. The TDS of the location shown in Photo 9 measured 21,262 mg/L (Photo 10). The discharge continued to flow east, down the hill, toward the point of entry to Clear Creek as shown in Photo 11. The TDS just before the entry point to Clear Creek was measured in Photo 11 and was 21,235 mg/L (Photo 12). The discharge entered the creek at the point shown in Photo 13. At the time of the inspection, Clear Creek was flowing and appeared to be spring fed. TDS at the point of entry to the creek measured 28,316 mg/L (Photo 14). Upstream on Clear Creek (Photo 15), the TDS of the flowing creek measured 37 mg/L (Photo 16). I observed that the general flow of Clear Creek was north and northeast. Section III - AREAS OF CONCERN The facility did not have a proper sign to correctly identify ownership and lease location information on site during the inspection. The facility had improper maintenance of the tank battery and was releasing fluids from inside the secondary containment pit by a valve located on the pit. The fluids flowed to Clear 2 6ENFORM-019-8 (10/31/2019) Red Oak Operating, LLC / Shiloh Lease Inspection Date: 11/08/2019 Creek from the tank battery. Elevated levels of TDS were present from the facility, along the flow path, and in Clear Creek Section IV - FOLLOW UP A follow up inspection will be conducted as needed. This facility will be referred to EPA water enforcement. Section V - LIST OF APPENDICES Appendix 1 - Photo Log - 16 photos taken 11/8/2019. 3 6ENFORM-019-8 (10/31/2019) Red Oak Operating, LLC / Shiloh Lease Inspection Date: 11/8/2019 Appendix 1 Photographic Log (16 photos) UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 33.394962N, -93.463712W City: Stamps Photo No. 1 County: Lafayette State: Arkansas Photo File Name: Photo 1 (DSC_0100) Orientation: South Date of Photo: 11/8/2019 Time of Photo: 11:02 am Latitude: 33.394947N longitude: -93.463716W Photographer: K.W. Sanborn Description: This was the first sign that identified the owner and operator at the lease during the inspection. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 33.394962N, -93.463712W City: Stamps Photo No. 2 County: Lafayette State: Arkansas Photo File Name: Photo 2 (DSC_0102) Orientation: South Date of Photo: 11/8/2019 Time of Photo: 11:03 am Latitude: 33.394947N Longitude: -93.463716W Photographer: K.W. Sanborn Description: This sign located at the tank battery identified itself as the Minter #1. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 33.394962N, -93.463712W City: Stamps Photo No. 3 County: Lafayette State: Arkansas Photo File Name: Photo 3 (DSC_0101) Orientation: South Date of Photo: 11/8/2019 Time of Photo: 11:02 am Latitude: 33.394947N Longitude: -93.463716W Photographer: K.W. Sanborn Description: This image shows the overview of the tank battery and secondary containment pit, which had recently been drained. The pit was the source of the discharge or brine from the facility to Clear Creek. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 33.394962N, -93.463712W City: Stamps Photo No. 4 County: Lafayette State: Arkansas Photo File Name: Photo 4 (DSC_0098) Orientation: Southeast Date of Photo: 11/8/2019 Time of Photo: 11:02 am Latitude: 33.394947N Longitude: -93.463716W Photographer: K.W. Sanborn Description: I observed that the tank battery pit was dry after had been drained recently from the facility to Clear Creek. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 33.394962N, -93.463712W City: Stamps Photo No. 5 County: Lafayette State: Arkansas Photo File Name: Photo 5 (DSC_0080) Orientation: Southwest Date of Photo: 11/8/2019 Time of Photo: 10:51 am Latitude: 33.394843N Longitude: -93.463435W Photographer: K.W. Sanborn Description: I observed the drain pipe was draining brine from the tank battery pit to Clear Creek, during the inspection. I observed an oil sheen along the flow path as well. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 33.394962N, -93.463712W City: Stamps Photo No. 6 County: Lafayette State: Arkansas Photo File Name: Photo 6 (DSC_0085) Orientation: Southwest Date of Photo: 11/8/2019 Time of Photo: 10:53 am Latitude: 33.394843N Longitude: -93.463435W Photographer: K.W. Sanborn Description: With a calibrated YSI Pro 30 conductivity meter, I measured Total Dissolved Solids (TDS) at the drain pipe and the discharged fluid, including brine, measured 17,762 milligrams per liter (mg/L). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 33.394962N, -93.463712W City: Stamps Photo No. 7 County: Lafayette State: Arkansas Photo File Name: Photo 7 (DSC_0079) Orientation: Southeast Date of Photo: 11/8/2019 Time of Photo: 10:10:51 am Latitude: 33.394843N Longitude: -93.463435W Photographer: K.W. Sanborn Description: I observed brine that flowed from the pit and the flow path went east toward Clear Creek. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 33.394962N, -93.463712W City: Stamps Photo No. 8 County: Lafayette State: Arkansas Photo File Name: Photo 8 (DSC_0083) Orientation: South Date of Photo: 11/8/2019 Time of Photo: 10:52 am Latitude: 33.394843N Longitude: -93.463435W Photographer: K.W. Sanborn Description: The TDS at the location shown in Photo 7 measured 20,935 mg/L. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 33.394962N, -93.463712W City: Stamps Photo No. 9 County: Lafayette State: Arkansas Photo File Name: Photo 9 (DSC_0087) Orientation: East Date of Photo: 11/8/2019 Time of Photo: 10:56 am Latitude: 33.394725N Longitude: -93.463435W Photographer: K.W. Sanborn Description: The brine flowed into the woods here, on the way to the Clear Creek. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 33.394962N, -93.463712W City: Stamps Photo No. 10 County: Lafayette State: Arkansas Photo File Name: Photo 10 (DSC_0088) Orientation: Southeast Date of Photo: 11/8/2019 Time of Photo: 10:56 am Latitude: 33.394725N Longitude: -93.463189W Photographer: K.W. Sanborn Description: The TDS at the location shown in Photo 9 measured 21,262 mg/L. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 33.394962N, -93.463712W City: Stamps Photo No. 11 County: Lafayette State: Arkansas Photo File Name: Photo 11 (DSC_0090) Orientation: Southeast Date of Photo: 11/8/2019 Time of Photo: 10:57 am Latitude: 33.394604N Longitude: -93.462669W Photographer: K.W. Sanborn Description: This was a view of the brine discharge flowing towards the point of entry to Clear Creek. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 33.394962N, -93.463712W City: Stamps Photo No. 12 County: Lafayette State: Arkansas Photo File Name: Photo 12 (DSC_0089) Orientation: East Date of Photo: 11/8/2019 Time of Photo: 10:56 am Latitude: 33.394604N Longitude: -93.462669W Photographer: K.W. Sanborn Description: The TDS of the discharge location shown in Photo 11 measured 21,235 mg/L. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 33.394962N, -93.463712W City: Stamps Photo No. 13 County: Lafayette State: Arkansas Photo File Name: Photo 13 (DSC_0092) Orientation: East Date of Photo: 11/8/2019 Time of Photo: 10:57 am Latitude: 33.39470N Longitude: -93.46241W Photographer: K.W. Sanborn Description: I observed that the brine discharge from the Shiloh lease facility entered Clear Creek here. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 33.394962N, -93.463712W City: Stamps Photo No. 14 County: Lafayette State: Arkansas Photo File Name: Photo 14 (DSC_0093) Orientation: North Date of Photo: 11/8/2019 Time of Photo: 10:58 am Latitude: 33.39470N Longitude: -93.46241W Photographer: K.W. Sanborn Description: The TDS of Clear Creek at the point of entry measured 28,316 mg/L. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 33.394962N, -93.463712W City: Stamps Photo No. 15 County: Lafayette State: Arkansas Photo File Name: Photo 15 (DSC_0096) Orientation: South Date of Photo: 11/8/2019 Time of Photo: 10:58 am Latitude: 33.39440N Longitude: -93.46258W Photographer: K.W. Sanborn Description: I observed Clear Creek upstream from the point of entry of the discharged brine, here. The creek was flowing at the time of the inspection. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log 33.394962N, -93.463712W City: Stamps Photo No. 16 County: Lafayette State: Arkansas Photo File Name: Photo 16 (DSC_0095) Orientation: South Date of Photo: 11/8/2019 Time of Photo: 10:58 am Latitude: 33.39440N Longitude: -93.46258W Photographer: K.W. Sanborn Description: The TDS of Clear Creek, upstream of the discharge entry point measured 37 mg/L.