Document ppr8J6oe0epozOoEJEyZxrg9k

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: Eubanks, James and Mike (J&M) Howard "B" 1 SWD Tank Battery From Highway 7B in Sandy Land, then left onto Union Co Rd 459, off an oil lease road at 33.33997, -92.713382 Smackover, AR, 71762 615 Broadway Smackover, AR, 71762 Union County 870-725-2907 James Eubanks Person Responsible for Operation rick@jrmorgancpa.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: N/A ARU002252 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 11:15:31 -05'00' Date JEANNE ECKHART Date: 2024.10.29 15:38:29 -05'00' Digitally signed by JEANNE ECKHART Jeanne Eckhart Date 6ENFORM-019-R8.2 (02/12/2020) 1 Eubanks, James and Mike (J&M) / Howard "B" 1 SWD Tank Battery (ARU002252 / 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 Eubanks, James and Mike (J&M) / Howard "B" 1 SWD Tank Battery, located from Highway 7B in Sandy Land, then left onto Union Co Rd 459, off an oil lease road at 33.33997, -92.713382; at 1015 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 James and Mike (J&M) Eubanks / Howard "B" 1 SWD Tank Battery, which contained two (2) tank batteries, five (5) storage/separator tanks for crude oil and saltwater, and one (1) Saltwater Disposal (SWD) well. Map 1. Aerial imagery (Google Earth dated 09/26/2023) of the James and Mike (J&M) Eubanks - Howard "B" 1 SWD Tank Battery. 2 Eubanks, James and Mike (J&M) / Howard "B" 1 SWD Tank Battery (ARU002252 / CWA) Inspection Date 10/08/2024 Section II - OBSERVATIONS I observed the James and Mike (J&M) Eubanks - Howard "B" 1 SWD Tank Battery, signage, and associated secondary containments, storage tanks, and saltwater disposal (SWD) well; see Appendix 1 (Photographs Log), see Photo No. 1 and No. 2. For additional GPS location and photo metadata, see Appendix 1. I observed one of two tank batteries (TB #1) at the facility, see Photo No. 3. I observed production/transfer lines at TB #1 without catchment buckets, see Photo No. 4. I observed active leaks of crude oil from tanks inside TB #1, see Photo No. 5 through No. 9. I observed the drainpipe and the cap for TB #1, see Photo No. 10 and No. 11. I observed two of two tank batteries (TB #2) at the facility, see Photo No. 12. I observed loose oil inside TB #2, see Photo No. 13 and No. 15. I observed the separator with residual oil stains on the outside of the tank, see Photo No. 14. I observed the drainpipe and the cap for TB #2, see Photo No. 16 and No. 17. I observed the flowpath of contaminated stormwater originating from TB #2, see Photo No. 18 and No. 19. I observed the signage and the SWD well associated with the tank batteries, see Photo No. 20 and No. 21. I observed areas of miscellaneous solid waste around the SWD and the tank batteries, see Photo No. 22 and No. 23. Section III - AREAS OF CONCERN No closing conference was held due to no personnel with James and Mike (J&M) Eubanks being present during the inspection. Areas of concern at the time of the inspection include the following: Illegible signage at the tank batteries for the facility, Loose, residual oil inside both tank batteries associated with the facility, Transfer pipes outside secondary containment without catchment buckets, Active leaks from tanks inside secondary containment for the facility, Drainpipes for the secondary containment without caps, Evidence of contaminated stormwater discharge from the facility, and Miscellaneous solid waste of petroleum-based containers and other oilfield wastes onsite. 3 Eubanks, James and Mike (J&M) / Howard "B" 1 SWD Tank Battery (ARU002252 / 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 - 23 photos taken 10/08/2024. 4 J&M Eubanks / Howard "B" 1 SWD (CWA / ARU002252) Inspection Date 10/08/2024 Appendix 1 Photograph Log 23 Photos Note: date/time stamp programmed incorrectly; metadata provided with field notes UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: J & M Eubanks - Howard "B" 1 SWD Tank Battery in Sandy Land at 33.339997, -92.713382 City: Smackover County/Parish: Union State: Arkansas Photo File Name: PA08-0037 Orientation: NW Date of Photo: 10/08/2024 Time of Photo: 1045 Latitude: 33.340526 Longitude: -92.713348 Photographer: Kerri McCabe Description: Looking NW, this photo shows signage at the Howard "B" 1 SWD Tank Battery. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: J & M Eubanks - Howard "B" 1 SWD Tank Battery in Sandy Land at 33.339997, -92.713382 City: Smackover County/Parish: Union State: Arkansas Photo File Name: PA08-0038 Orientation: NE Date of Photo: 10/08/2024 Time of Photo: 1045 Latitude: 33.340420 Longitude: -92.713409 Photographer: Kerri McCabe Description: Looking NE, this photo shows an overview of the Howard "B" 1 SWD Tank Battery. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: J & M Eubanks - Howard "B" 1 SWD Tank Battery in Sandy Land at 33.339997, -92.713382 City: Smackover County/Parish: Union State: Arkansas Photo File Name: PA08-0039 Orientation: E Date of Photo: 10/08/2024 Time of Photo: 1046 Latitude: 33.340539 Longitude: -92.713324 Photographer: Kerri McCabe Description: Looking E, this photo shows an overview of one of the two tank batteries (TB) onsite; three tanks were inside containment (TB #1). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: J & M Eubanks - Howard "B" 1 SWD Tank Battery in Sandy Land at 33.339997, -92.713382 City: Smackover County/Parish: Union State: Arkansas Photo File Name: PA08-0040 Orientation: E-SE Date of Photo: 10/08/2024 Time of Photo: 1046 Latitude: 33.340610 Longitude: -92.713268 Photographer: Kerri McCabe Description: Looking E-SE, this photo shows two production/transfer lines outside secondary containment with no catch buckets at valves (TB #1). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: J & M Eubanks - Howard "B" 1 SWD Tank Battery in Sandy Land at 33.339997, -92.713382 City: Smackover County/Parish: Union State: Arkansas Photo File Name: PA08-0041 Orientation: NE Date of Photo: 10/08/2024 Time of Photo: 1046 Latitude: 33.340557 Longitude: -92.713369 Photographer: Kerri McCabe Description: Looking E-SE, this photo shows loose oil inside secondary containment (TB #1). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: J & M Eubanks - Howard "B" 1 SWD Tank Battery in Sandy Land at 33.339997, -92.713382 City: Smackover County/Parish: Union State: Arkansas Photo File Name: PA08-0042 Orientation: NE Date of Photo: 10/08/2024 Time of Photo: 1046 Latitude: 33.340557 Longitude: -92.713369 Photographer: Kerri McCabe Description: Looking NE, this photo shows Tank 3280, from Photo No. 5, with the loose oil. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: J & M Eubanks - Howard "B" 1 SWD Tank Battery in Sandy Land at 33.339997, -92.713382 City: Smackover County/Parish: Union State: Arkansas Photo File Name: PA08-0043 Orientation: W-SW Date of Photo: 10/08/2024 Time of Photo: 1047 Latitude: 33.340584 Longitude: -92.713349 Photographer: Kerri McCabe Description: Looking W-SW, this photo shows loose oil from an additional tank (TB #1). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: J & M Eubanks - Howard "B" 1 SWD Tank Battery in Sandy Land at 33.339997, -92.713382 City: Smackover County/Parish: Union State: Arkansas Photo File Name: PA08-0044 Orientation: NW Date of Photo: 10/08/2024 Time of Photo: 1047 Latitude: 33.340584 Longitude: -92.713349 Photographer: Kerri McCabe Description: Looking NW, this photo shows a closeup of the loose oil between the two tanks in Photo No. 7. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 Location: J & M Eubanks - Howard "B" 1 SWD Tank Battery in Sandy Land at 33.339997, -92.713382 City: Smackover County/Parish: Union State: Arkansas Photo File Name: PA08-0045 Orientation: E-SE Date of Photo: 10/08/2024 Time of Photo: 1047 Latitude: 33.340584 Longitude: -92.713349 Photographer: Kerri McCabe Description: Looking E-SE, this photo shows the flowpath for the loose oil (TB #1). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 10 Location: J & M Eubanks - Howard "B" 1 SWD Tank Battery in Sandy Land at 33.339997, -92.713382 City: Smackover County/Parish: Union State: Arkansas Photo File Name: PA08-0046 Orientation: N-NW Date of Photo: 10/08/2024 Time of Photo: 1048 Latitude: 33.340508 Longitude: -92.713388 Photographer: Kerri McCabe Description: Looking N-NW, this photo shows the drainpipe for TB #1. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 11 Location: J & M Eubanks - Howard "B" 1 SWD Tank Battery in Sandy Land at 33.339997, -92.713382 City: Smackover County/Parish: Union State: Arkansas Photo File Name: PA08-0047 Orientation: N-NE Date of Photo: 10/08/2024 Time of Photo: 1048 Latitude: 33.340508 Longitude: -92.713388 Photographer: Kerri McCabe Description: Looking N-NE, this photo shows a closeup of the drainpipe cap from Photo No. 10; cap was loose during inspection. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 12 Location: J & M Eubanks - Howard "B" 1 SWD Tank Battery in Sandy Land at 33.339997, -92.713382 City: Smackover County/Parish: Union State: Arkansas Photo File Name: PA08-0048 Orientation: E-NE Date of Photo: 10/08/2024 Time of Photo: 1048 Latitude: 33.340492 Longitude: -92.713486 Photographer: Kerri McCabe Description: Looking E-NE, this photo shows an overview of one of the two tank batteries (TB) onsite; two tanks were inside containment (TB #2). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 13 Location: J & M Eubanks - Howard "B" 1 SWD Tank Battery in Sandy Land at 33.339997, -92.713382 City: Smackover County/Parish: Union State: Arkansas Photo File Name: PA08-0049 Orientation: E-NE Date of Photo: 10/08/2024 Time of Photo: 1048 Latitude: 33.340497 Longitude: -92.713520 Photographer: Kerri McCabe Description: Looking E-NE, this photo shows loose oil inside secondary containment (TB #2). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 14 Location: J & M Eubanks - Howard "B" 1 SWD Tank Battery in Sandy Land at 33.339997, -92.713382 City: Smackover County/Parish: Union State: Arkansas Photo File Name: PA08-0051 Orientation: E-NE Date of Photo: 10/08/2024 Time of Photo: 1049 Latitude: 33.340497 Longitude: -92.713520 Photographer: Kerri McCabe Description: Looking E-NE, this photo shows a previous overflow at one of the tanks (TB #2). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 15 Location: J & M Eubanks - Howard "B" 1 SWD Tank Battery in Sandy Land at 33.339997, -92.713382 City: Smackover County/Parish: Union State: Arkansas Photo File Name: PA08-0052 Orientation: NE Date of Photo: 10/08/2024 Time of Photo: 1049 Latitude: 33.340465 Longitude: -92.713573 Photographer: Kerri McCabe Description: Looking NE, this photo shows loose oil inside secondary containment (TB #2). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 16 Location: J & M Eubanks - Howard "B" 1 SWD Tank Battery in Sandy Land at 33.339997, -92.713382 City: Smackover County/Parish: Union State: Arkansas Photo File Name: PA08-0053 Orientation: NW Date of Photo: 10/08/2024 Time of Photo: 1049 Latitude: 33.340432 Longitude: -92.713660 Photographer: Kerri McCabe Description: Looking NW, this photo shows the cap for the drainpipe on top of the secondary containment berm (TB #2). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 17 Location: J & M Eubanks - Howard "B" 1 SWD Tank Battery in Sandy Land at 33.339997, -92.713382 City: Smackover County/Parish: Union State: Arkansas Photo File Name: PA08-0054 Orientation: SW Date of Photo: 10/08/2024 Time of Photo: 1050 Latitude: 33.340432 Longitude: -92.713660 Photographer: Kerri McCabe Description: Looking SW, this photo shows the open drainpipe from Photo No. 16. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 18 Location: J & M Eubanks - Howard "B" 1 SWD Tank Battery in Sandy Land at 33.339997, -92.713382 City: Smackover County/Parish: Union State: Arkansas Photo File Name: PA08-0055 Orientation: NE Date of Photo: 10/08/2024 Time of Photo: 1050 Latitude: 33.340473 Longitude: -92.713706 Photographer: Kerri McCabe Description: Looking NE, this photo shows a flowpath from the drainpipe for TB #2 into the surrounding riparian of an unnamed tributary (UT) of Holmes Creek. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 19 Location: J & M Eubanks - Howard "B" 1 SWD Tank Battery in Sandy Land at 33.339997, -92.713382 City: Smackover County/Parish: Union State: Arkansas Photo File Name: PA08-0056 Orientation: NE Date of Photo: 10/08/2024 Time of Photo: 1050 Latitude: 33.340473 Longitude: -92.713706 Photographer: Kerri McCabe Description: Looking NE, this photo shows an additional view of the flowpath from Photo No. 18; note loose oil and dead vegetation within flowpath. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 20 Location: J & M Eubanks - Howard "B" 1 SWD Tank Battery in Sandy Land at 33.339997, -92.713382 City: Smackover County/Parish: Union State: Arkansas Photo File Name: PA08-0057 Orientation: N-NW Date of Photo: 10/08/2024 Time of Photo: 1053 Latitude: 33.339997 Longitude: -92.713382 Photographer: Kerri McCabe Description: Looking N-NW, this photo shows the signage at the Howard "B" 1 SWD well. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 21 Location: J & M Eubanks - Howard "B" 1 SWD Tank Battery in Sandy Land at 33.339997, -92.713382 City: Smackover County/Parish: Union State: Arkansas Photo File Name: PA08-0058 Orientation: E-NE Date of Photo: 10/08/2024 Time of Photo: 1053 Latitude: 33.339997 Longitude: -92.713382 Photographer: Kerri McCabe Description: Looking E-NE, this photo shows an overview of the SWD adjacent to the two tank batteries. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 22 Location: J & M Eubanks - Howard "B" 1 SWD Tank Battery in Sandy Land at 33.339997, -92.713382 City: Smackover County/Parish: Union State: Arkansas Photo File Name: PA08-0059 Orientation: SE Date of Photo: 10/08/2024 Time of Photo: 1053 Latitude: 33.340003 Longitude: -92.713453 Photographer: Kerri McCabe Description: Looking SE, this photo shows a waste pit adjacent to the SWD in Photo No. 21. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 23 Location: J & M Eubanks - Howard "B" 1 SWD Tank Battery in Sandy Land at 33.339997, -92.713382 City: Smackover County/Parish: Union State: Arkansas Photo File Name: PA08-0060 Orientation: W Date of Photo: 10/08/2024 Time of Photo: 1055 Latitude: 33.340556 Longitude: -92.713253 Photographer: Kerri McCabe Description: Looking W, this photo shows miscellaneous petroleum-related containers onsite.