Document p327L2DQY4wrroYbzyp7MD6w

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 10/08/2024 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: Pharr, Billy W (B Pharr Operating, LLC) Bo Gregory 2 SWD Tank Battery In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.253333, -92.538889 El Dorado, AR, 71730 P.O. Box 130 Emerson, AR, 71740 Union County 870-904-5573 Billy Pharr Owner / Operator bp@hydrooil.net FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: N/A ARU002254 N/A 211111 1311 Personnel participating in inspection: Kerri McCabe (lead) EPA / Region 6 ECDW Michael Blaha EPA / Region 6 ECDW Uma Lad EPA / Region 6 ECDW Inspector / Enforcement Officer Inspector / Enforcement Officer Inspector / Enforcement Officer EPA Lead Inspector Signature/Date Supervisor Signature/Date KERRI MCCABE Kerri McCabe Digitally signed by KERRI MCCABE Date: 2024.10.22 11:36:37 -05'00' Date JEANNE ECKHART Date: 2024.10.29 15:49:43 -05'00' Digitally signed by JEANNE ECKHART Jeanne Eckhart Date 6ENFORM-019-R8.2 (02/12/2020) 1 Pharr, Billy W (B Pharr Operating, LLC) / Bo Gregory 2 SWD Tank Battery (ARU002254 / CWA) Inspection Date 10/08/2024 Section I - INTRODUCTION PURPOSE OF THE INSPECTION EPA Region 6 inspectors Kerri McCabe (lead), Michael Blaha, and Uma Lad arrived at the Pharr, Billy W (B Pharr Operating, LLC) / Bo Gregory 2 SWD Tank Battery, located from Highway 63 E, then Armer Rd, left onto an oil lease road at 33.253333, -92.538889; at 1645 on 10/08/2024 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 Pharr, Billy W (B Pharr Operating, LLC) / Bo Gregory 2 SWD Tank Battery, which contained one (1) tank battery, four (4) storage/separation tanks for crude oil and saltwater, and two (2) Saltwater Disposal (SWD) wells. Map 1. Aerial imagery (Google Earth dated 03/11/2024) of the Pharr, Billy W (B Pharr Operating, LLC) - Bo Gregory 2 SWD Tank Battery. 2 Pharr, Billy W (B Pharr Operating, LLC) / Bo Gregory 2 SWD Tank Battery (ARU002254 / CWA) Inspection Date 10/08/2024 Section II - OBSERVATIONS I observed the Pharr, Billy W (B Pharr Operating, LLC) / Bo Gregory 2 SWD Tank Battery, signage, and associated secondary containment, storage tanks, separators/treaters, and saltwater disposal (SWD) wells; see Appendix 1 (Photographs Log), see Photo No. 1, No. 2, and No. 13. For additional GPS location and photo metadata, see Appendix 1. I observed loose oil inside secondary containment, see Photo No. 3 through No. 5, No. 7 and No. 8, and No. 12. I observed disturbed areas of the secondary containment with evidence of repairs made to tanks, pumps, and the berm; see Photo No. 6, No. 9 and No. 10, No. 17, and No. 19. I observed two points of crude oil/saltwater release from the facility and associated SWD, see Photo No. 11 and No. 14. I observed a labeled barrel containing toxic material outside secondary containment, see Photo No. 15 and No. 16. I observed the flowpath of the release of crude oil/saltwater, see Photo No. 18 through No. 30. Directional arrows have been added for clarity. I observed a Total Dissolved Solids (TDS) reading of 1,708 mg/L for the release Point of Entry (POE) into a wetland associated with an unnamed tributary (UT) of Mill Creek, see Photo No. 31 through No. 33. I observed a TDS reading of 3,145 mg/L downstream of the POE for the release at a bridge crossing for the UT of Mill Creek, see Photo No. 34 through No. 36. Note: All TDS field readings observed throughout the inspection were taken with a properly calibrated, EPA-issued, YSI Pro30 Conductivity/TDS/Salinity/Temperature Meter (#Y60530). Section III - AREAS OF CONCERN No closing conference was held due to no personnel with Pharr, Billy W (B Pharr Operating, 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, Two release points of crude oil/saltwater from the facility into wetlands and surface water, A labeled barrel outside secondary containment, Residual crude oil/saltwater along the flowpath into wetlands and surface water, and Elevated TDS readings at the release POE and in an UT of Mill Creek. 3 Pharr, Billy W (B Pharr Operating, LLC) / Bo Gregory 2 SWD Tank Battery (ARU002254 / CWA) Inspection Date 10/08/2024 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 - 36 photos taken 10/08/2024. 4 Pharr, Billy W (B Pharr Operating, LLC) / Bo Gregory 2 SWD Tank Battery Inspection Date 10/08/2024 Appendix 1 Photograph Log 36 Photos UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: Pharr, Billy W (B Pharr Operating, LLC) - Bo Gregory 2 SWD Tank Battery in Old Union at 33.253333, -92.538889. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: PA08-0131 Orientation: S-SE Date of Photo: 10/08/2024 Time of Photo: 18:28 Latitude: 33.253624 Longitude: -92.539154 Photographer: Kerri McCabe Description: Looking S-SE, this photo shows the signage at the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: Pharr, Billy W (B Pharr Operating, LLC) - Bo Gregory 2 SWD Tank Battery in Old Union at 33.253333, -92.538889. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: PA08-0132 Orientation: SW Date of Photo: 10/08/2024 Time of Photo: 18:29 Latitude: 33.253641 Longitude: -92.539195 Photographer: Kerri McCabe Description: Looking SW, this photo shows an overview of the Bo Gregory 2 SWD Tank Battery facility with one of two saltwater disposal (SWD) wells onsite. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: Pharr, Billy W (B Pharr Operating, LLC) - Bo Gregory 2 SWD Tank Battery in Old Union at 33.253333, -92.538889. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: PA08-0134 Orientation: S-SE Date of Photo: 10/08/2024 Time of Photo: 18:29 Latitude: 33.253550 Longitude: -92.539192 Photographer: Kerri McCabe Description: Looking S-SE, this photo shows inside the tank battery with staining from crude oil on the berm levee. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: Pharr, Billy W (B Pharr Operating, LLC) - Bo Gregory 2 SWD Tank Battery in Old Union at 33.253333, -92.538889. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: PA08-0135 Orientation: SW Date of Photo: 10/08/2024 Time of Photo: 18:30 Latitude: 33.253469 Longitude: -92.539148 Photographer: Kerri McCabe Description: Looking SW, this photo shows the backside of the tank battery with loose oil, oil staining, and sand from berm repairs. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: Pharr, Billy W (B Pharr Operating, LLC) - Bo Gregory 2 SWD Tank Battery in Old Union at 33.253333, -92.538889. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: PA08-0136 Orientation: SW Date of Photo: 10/08/2024 Time of Photo: 18:30 Latitude: 33.253469 Longitude: -92.539148 Photographer: Kerri McCabe Description: Looking SW, this photo shows a closeup of the loose oil, oil staining, and sand within secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: Pharr, Billy W (B Pharr Operating, LLC) - Bo Gregory 2 SWD Tank Battery in Old Union at 33.253333, -92.538889. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: PA08-0137 Orientation: S-SW Date of Photo: 10/08/2024 Time of Photo: 18:30 Latitude: 33.253469 Longitude: -92.539148 Photographer: Kerri McCabe Description: Looking S-SW, this photo shows a section of the berm that had been breached to replace the drainpipe through the berm. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: Pharr, Billy W (B Pharr Operating, LLC) - Bo Gregory 2 SWD Tank Battery in Old Union at 33.253333, -92.538889. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: PA08-0138 Orientation: W Date of Photo: 10/08/2024 Time of Photo: 18:30 Latitude: 33.253479 Longitude: -92.539147 Photographer: Kerri McCabe Description: Looking W, this photo shows an active leak of crude oil from a valve and a gap under the tank. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: Pharr, Billy W (B Pharr Operating, LLC) - Bo Gregory 2 SWD Tank Battery in Old Union at 33.253333, -92.538889. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: PA08-0140 Orientation: SW Date of Photo: 10/08/2024 Time of Photo: 18:31 Latitude: 33.253461 Longitude: -92.539049 Photographer: Kerri McCabe Description: Looking SW, this photo shows an overview of the loose oil pooled within the berm and the high-level mark from oil staining. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 Location: Pharr, Billy W (B Pharr Operating, LLC) - Bo Gregory 2 SWD Tank Battery in Old Union at 33.253333, -92.538889. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: PA08-0141 Orientation: N-NW Date of Photo: 10/08/2024 Time of Photo: 18:31 Latitude: 33.253612 Longitude: -92.539027 Photographer: Kerri McCabe Description: Looking N-NW, this photo shows area at the front of the tank battery that had been breached to allow heavy equipment inside the berm. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 10 Location: Pharr, Billy W (B Pharr Operating, LLC) - Bo Gregory 2 SWD Tank Battery in Old Union at 33.253333, -92.538889. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: PA08-0142 Orientation: S Date of Photo: 10/08/2024 Time of Photo: 18:31 Latitude: 33.253612 Longitude: -92.539027 Photographer: Kerri McCabe Description: Looking S, this photo shows heavy equipment tracking on the sand inside the secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 11 Location: Pharr, Billy W (B Pharr Operating, LLC) - Bo Gregory 2 SWD Tank Battery in Old Union at 33.253333, -92.538889. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: PA08-0143 Orientation: E-NE Date of Photo: 10/08/2024 Time of Photo: 18:31 Latitude: 33.253612 Longitude: -92.539027 Photographer: Kerri McCabe Description: Looking E-NE, this photo shows the separator with evidence of overflow. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 12 Location: Pharr, Billy W (B Pharr Operating, LLC) - Bo Gregory 2 SWD Tank Battery in Old Union at 33.253333, -92.538889. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: PA08-0144 Orientation: SW Date of Photo: 10/08/2024 Time of Photo: 18:32 Latitude: 33.253554 Longitude: -92.539143 Photographer: Kerri McCabe Description: Looking SW, this photo shows extensive oil staining inside the secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 13 Location: Pharr, Billy W (B Pharr Operating, LLC) - Bo Gregory 2 SWD Tank Battery in Old Union at 33.253333, -92.538889. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: PA08-0127 Orientation: SE Date of Photo: 10/08/2024 Time of Photo: 18:26 Latitude: 33.253347 Longitude: -92.539312 Photographer: Kerri McCabe Description: Looking SE, this photo shows two of two SWD wells onsite. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 14 Location: Pharr, Billy W (B Pharr Operating, LLC) - Bo Gregory 2 SWD Tank Battery in Old Union at 33.253333, -92.538889. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: PA08-0126 Orientation: S Date of Photo: 10/08/2024 Time of Photo: 18:26 Latitude: 33.253347 Longitude: -92.539312 Photographer: Kerri McCabe Description: Looking S, this photo shows one of two release points located at the site. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 15 Location: Pharr, Billy W (B Pharr Operating, LLC) - Bo Gregory 2 SWD Tank Battery in Old Union at 33.253333, -92.538889. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: PA08-0128 Orientation: N-NW Date of Photo: 10/08/2024 Time of Photo: 18:27 Latitude: 33.253347 Longitude: -92.539312 Photographer: Kerri McCabe Description: Looking N-NW, this photo shows a barrel labeled with "Plexbreak 45 (UN 1993)," which contained fluid during the inspection. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 16 Location: Pharr, Billy W (B Pharr Operating, LLC) - Bo Gregory 2 SWD Tank Battery in Old Union at 33.253333, -92.538889. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: PA08-0129 Orientation: N-NE Date of Photo: 10/08/2024 Time of Photo: 18:27 Latitude: 33.253347 Longitude: -92.539312 Photographer: Kerri McCabe Description: Looking N-NE, this photo shows an additional view of the barrel in Photo No. 15. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 17 Location: Pharr, Billy W (B Pharr Operating, LLC) - Bo Gregory 2 SWD Tank Battery in Old Union at 33.253333, -92.538889. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: PA08-0130 Orientation: W-SW Date of Photo: 10/08/2024 Time of Photo: 18:27 Latitude: 33.253347 Longitude: -92.539312 Photographer: Kerri McCabe Description: Looking W-SW, this photo shows disturbed soil around the containment berm; oil staining is highlighted. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 18 Location: Pharr, Billy W (B Pharr Operating, LLC) - Bo Gregory 2 SWD Tank Battery in Old Union at 33.253333, -92.538889. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: PA08-0124 Orientation: S-SE Date of Photo: 10/08/2024 Time of Photo: 18:24 Latitude: 33.253445 Longitude: -92.538995 Photographer: Kerri McCabe Description: Looking S-SE, this photo shows oil staining from an overflow that occurred from the secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 19 Location: Pharr, Billy W (B Pharr Operating, LLC) - Bo Gregory 2 SWD Tank Battery in Old Union at 33.253333, -92.538889. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: PA08-0125 Orientation: W-SW Date of Photo: 10/08/2024 Time of Photo: 18:24 Latitude: 33.253401 Longitude: -92.539079 Photographer: Kerri McCabe Description: Looking W-SW, this photo shows evidence of overflow and replaced drainpipe from the secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 20 Location: Pharr, Billy W (B Pharr Operating, LLC) - Bo Gregory 2 SWD Tank Battery in Old Union at 33.253333, -92.538889. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: PA08-0123 Orientation: SW Date of Photo: 10/08/2024 Time of Photo: 18:20 Latitude: 33.253315 Longitude: -92.539064 Photographer: Kerri McCabe Description: Looking SW, this photo shows the beginning of the flowpath for the overflow that occurred at the secondary containment; flowpath has been highlighted for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 21 Location: Pharr, Billy W (B Pharr Operating, LLC) - Bo Gregory 2 SWD Tank Battery in Old Union at 33.253333, -92.538889. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: PA08-0122 Orientation: W-NW Date of Photo: 10/08/2024 Time of Photo: 18:20 Latitude: 33.253315 Longitude: -92.539064 Photographer: Kerri McCabe Description: Looking N-NW, this photo shows the continuation of the flowpath from the overflow from the secondary containment; flowpath has been highlighted for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 22 Location: Pharr, Billy W (B Pharr Operating, LLC) - Bo Gregory 2 SWD Tank Battery in Old Union at 33.253333, -92.538889. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: PA08-0121 Orientation: S-SW Date of Photo: 10/08/2024 Time of Photo: 18:20 Latitude: 33.253315 Longitude: -92.539064 Photographer: Kerri McCabe Description: Looking S-SW, this photo shows the continuation of the flowpath from the overflow from the secondary containment; flowpath has been highlighted for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 23 Location: Pharr, Billy W (B Pharr Operating, LLC) - Bo Gregory 2 SWD Tank Battery in Old Union at 33.253333, -92.538889. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: PA08-0120 Orientation: S Date of Photo: 10/08/2024 Time of Photo: 18:17 Latitude: 33.252831 Longitude: -92.538637 Photographer: Kerri McCabe Description: Looking S, this photo shows the continuation of the flowpath from the overflow from the secondary containment; flowpath has been highlighted for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 24 Location: Pharr, Billy W (B Pharr Operating, LLC) - Bo Gregory 2 SWD Tank Battery in Old Union at 33.253333, -92.538889. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: PA08-0119 Orientation: S-SW Date of Photo: 10/08/2024 Time of Photo: 18:16 Latitude: 33.252732 Longitude: -92.538435 Photographer: Kerri McCabe Description: Looking S-SW, this photo shows the continuation of the flowpath from the overflow from the secondary containment; flowpath has been highlighted for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 25 Location: Pharr, Billy W (B Pharr Operating, LLC) - Bo Gregory 2 SWD Tank Battery in Old Union at 33.253333, -92.538889. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: PA08-0118 Orientation: S-SW Date of Photo: 10/08/2024 Time of Photo: 18:16 Latitude: 33.252561 Longitude: -92.538270 Photographer: Kerri McCabe Description: Looking S-SW, this photo shows the continuation of the flowpath from the overflow from the secondary containment; flowpath has been highlighted for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 26 Location: Pharr, Billy W (B Pharr Operating, LLC) - Bo Gregory 2 SWD Tank Battery in Old Union at 33.253333, -92.538889. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: PA08-0117 Orientation: S-SW Date of Photo: 10/08/2024 Time of Photo: 18:15 Latitude: 33.252359 Longitude: -92.538183 Photographer: Kerri McCabe Description: Looking S-SW, this photo shows the continuation of the flowpath from the overflow from the secondary containment; flowpath has been highlighted for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 27 Location: Pharr, Billy W (B Pharr Operating, LLC) - Bo Gregory 2 SWD Tank Battery in Old Union at 33.253333, -92.538889. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: PA08-0116 Orientation: S Date of Photo: 10/08/2024 Time of Photo: 18:14 Latitude: 33.252206 Longitude: -92.538173 Photographer: Kerri McCabe Description: Looking S, this photo shows the continuation of the flowpath from the overflow from the secondary containment; flowpath has been highlighted for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 28 Location: Pharr, Billy W (B Pharr Operating, LLC) - Bo Gregory 2 SWD Tank Battery in Old Union at 33.253333, -92.538889. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: PA08-0115 Orientation: S-SW Date of Photo: 10/08/2024 Time of Photo: 18:13 Latitude: 33.252043 Longitude: -92.538111 Photographer: Kerri McCabe Description: Looking S-SW, this photo shows the continuation of the flowpath from the overflow from the secondary containment; flowpath has been highlighted for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 29 Location: Pharr, Billy W (B Pharr Operating, LLC) - Bo Gregory 2 SWD Tank Battery in Old Union at 33.253333, -92.538889. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: PA08-0114 Orientation: S Date of Photo: 10/08/2024 Time of Photo: 18:13 Latitude: 33.251919 Longitude: -92.538067 Photographer: Kerri McCabe Description: Looking S, this photo shows the continuation of the flowpath from the overflow from the secondary containment; flowpath has been highlighted for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 30 Location: Pharr, Billy W (B Pharr Operating, LLC) - Bo Gregory 2 SWD Tank Battery in Old Union at 33.253333, -92.538889. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: PA08-0113 Orientation: S-SE Date of Photo: 10/08/2024 Time of Photo: 18:13 Latitude: 33.251919 Longitude: -92.538067 Photographer: Kerri McCabe Description: Looking S-SE, this photo shows the continuation of the flowpath from the overflow from the secondary containment; flowpath has been highlighted for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 31 Location: Pharr, Billy W (B Pharr Operating, LLC) - Bo Gregory 2 SWD Tank Battery in Old Union at 33.253333, -92.538889. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: PA08-0110 Orientation: E Date of Photo: 10/08/2024 Time of Photo: 18:06 Latitude: 33.251762 Longitude: -92.538089 Photographer: Kerri McCabe Description: Looking E, this photo shows the Total Dissolved Solids (TDS) reading of 1,708 mg/L at the point of entry into a wetland downstream of the flowpath of the release. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 32 Location: Pharr, Billy W (B Pharr Operating, LLC) - Bo Gregory 2 SWD Tank Battery in Old Union at 33.253333, -92.538889. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: PA08-0111 Orientation: NE Date of Photo: 10/08/2024 Time of Photo: 18:08 Latitude: 33.251762 Longitude: -92.538089 Photographer: Kerri McCabe Description: Looking NE, this photo shows the area upstream of the TDS reading in Photo No. 31. Note reddish staining and petroleum sheen caused by a saltwater/crude oil discharge (bottom right). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 33 Location: Pharr, Billy W (B Pharr Operating, LLC) - Bo Gregory 2 SWD Tank Battery in Old Union at 33.253333, -92.538889. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: PA08-0112 Orientation: S-SE Date of Photo: 10/08/2024 Time of Photo: 18:08 Latitude: 33.251762 Longitude: -92.538089 Photographer: Kerri McCabe Description: Looking S-SE, this photo shows the area downstream of the TDS reading in Photo No. 31; stream flow direction has been highlighted for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 34 Location: Pharr, Billy W (B Pharr Operating, LLC) - Bo Gregory 2 SWD Tank Battery in Old Union at 33.253333, -92.538889. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: PA08-0147 Orientation: N-NW Date of Photo: 10/08/2024 Time of Photo: 19:13 Latitude: 33.251899 Longitude: -92.534467 Photographer: Kerri McCabe Description: Looking N-NW, this photo shows the TDS reading of 3,145 mg/L for the unnamed tributary (UT) of Mill Creek, which is downstream of the release site. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 35 Location: Pharr, Billy W (B Pharr Operating, LLC) - Bo Gregory 2 SWD Tank Battery in Old Union at 33.253333, -92.538889. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: PA08-0107 Orientation: SW Date of Photo: 10/08/2024 Time of Photo: 16:56 Latitude: 33.251899 Longitude: -92.534467 Photographer: Kerri McCabe Description: Looking SW, this photo shows the area upstream of the TDS reading in Photo No. 34; stream flow direction has been highlighted for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 36 Location: Pharr, Billy W (B Pharr Operating, LLC) - Bo Gregory 2 SWD Tank Battery in Old Union at 33.253333, -92.538889. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: PA08-0108 Orientation: SE Date of Photo: 10/08/2024 Time of Photo: 16:57 Latitude: 33.251899 Longitude: -92.534467 Photographer: Kerri McCabe Description: Looking SE, this photo shows the area downstream of the TDS reading in Photo No. 34; stream flow direction has been highlighted for clarity.