Document rJeQxkJ3p5Ev9Ekd5NdJDD20

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: Pharr, Billy W (dba 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 Inspector / Enforcement Officer EPA Lead Inspector Signature/Date Supervisor Signature/Date KERRI MCCABE Kerri McCabe Digitally signed by KERRI MCCABE Date: 2025.01.07 10:40:21 -06'00' Date JEANNE ECKHART Date: 2025.01.10 07:45:54 -06'00' Digitally signed by JEANNE ECKHART Jeanne Eckhart Date 6ENFORM-019-R8.2 (02/12/2020) 1 Pharr, Billy W (dba B Pharr Operating, LLC) / Bo Gregory #2 SWD Tank Battery (ARU002254 / CWA) Inspection Date 11/08/2024 Section I - INTRODUCTION PURPOSE OF THE INSPECTION EPA Region 6 inspector Kerri McCabe (lead) arrived at the Pharr, Billy W (dba B Pharr Operating, LLC) / Bo Gregory #2 SWD Tank Battery ("facility") at 1345 on 11/08/2024 for an unannounced follow-up inspection. The facility is located from Highway 63 E, then Armer Rd, left onto an oil lease road at 33.253333, -92.538889. 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 Kerri McCabe on 10/08/2024. FACILITY DESCRIPTION EPA conducted a follow-up inspection on the Pharr, Billy W (dba 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 (dba B Pharr Operating, LLC) - Bo Gregory #2 SWD Tank Battery. 2 Pharr, Billy W (dba B Pharr Operating, LLC) / Bo Gregory #2 SWD Tank Battery (ARU002254 / CWA) Inspection Date 11/08/2024 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) well; see Appendix 1 (Photograph Log), see 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 and No. 4. I observed an active leak of saltwater from a valve from one of the tanks inside secondary containment, see Photo No. 5. I observed loose crude oil and pooled saltwater inside the secondary containment, see Photo No. 6 and No. 7. I observed residual crude oil from the overflow noted during the 10/08/2024 inspection on the outside of secondary containment, see Photo No. 8. I observed an area of the secondary containment berm that had been repaired since the 10/08/2024 inspection, see Photo No. 9. Section III - AREAS OF CONCERN No closing conference was held due to no personnel with Pharr, Billy W (dba 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 crude oil inside and outside secondary containment for the facility, An active leak of saltwater from a valve from one of the storage tanks, and Crude oil and pooled saltwater inside 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 - 9 photos taken 11/08/2024. 3 Pharr, Billy W (B Pharr Operating, LLC) / Bo Gregory #2 SWD Tank Battery (ARU002254 / CWA) Inspection Date 11/08/2024 Appendix 1 Photograph Log 9 Photos UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.253333, 92.538889. City: El Dorado County/Parish: Union State: AR Photo File Name: 100-0371 Orientation: SSE Date of Photo: 11/08/2024 Time of Photo: 1401 Latitude: 33.253550 Longitude: -92.539067 Photographer: Kerri McCabe Description: Looking SSE, this photo shows the signage at the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.253333, 92.538889. City: El Dorado County/Parish: Union State: AR Photo File Name: 100-0372 Orientation: SE Date of Photo: 11/08/2024 Time of Photo: 1402 Latitude: 33.253700 Longitude: -92.539200 Photographer: Kerri McCabe Description: Looking SE, this photo shows an overview of the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.253333, 92.538889. City: El Dorado County/Parish: Union State: AR Photo File Name: 100-0373 Orientation: E Date of Photo: 11/08/2024 Time of Photo: 1402 Latitude: 33.253550 Longitude: -92.539200 Photographer: Kerri McCabe Description: Looking E, this photo shows loose oil inside secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.253333, 92.538889. City: El Dorado County/Parish: Union State: AR Photo File Name: 100-0374 Orientation: E Date of Photo: 11/08/2024 Time of Photo: 1402 Latitude: 33.253550 Longitude: -92.539217 Photographer: Kerri McCabe Description: Looking E, this photo shows loose oil inside secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.253333, 92.538889. City: El Dorado County/Parish: Union State: AR Photo File Name: 100-0375 Orientation: ENE Date of Photo: 11/08/2024 Time of Photo: 1403 Latitude: 33.253500 Longitude: -92.539183 Photographer: Kerri McCabe Description: Looking ENE, this photo shows an active leak of saltwater from a valve from one of the tanks inside secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.253333, 92.538889. City: El Dorado County/Parish: Union State: AR Photo File Name: 100-0376 Orientation: ESE Date of Photo: 11/08/2024 Time of Photo: 1403 Latitude: 33.253500 Longitude: -92.539183 Photographer: Kerri McCabe Description: Looking ESE, this photo shows loose crude oil and saltwater pooled in the sump area of secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.253333, 92.538889. City: El Dorado County/Parish: Union State: AR Photo File Name: 100-0377 Orientation: E Date of Photo: 11/08/2024 Time of Photo: 1403 Latitude: 33.253467 Longitude: -92.539200 Photographer: Kerri McCabe Description: Looking E, this photo shows an additional view from Photo No. 6. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.253333, 92.538889. City: El Dorado County/Parish: Union State: AR Photo File Name: 100-0378 Orientation: NE Date of Photo: 11/08/2024 Time of Photo: 1404 Latitude: 33.253433 Longitude: -92.539033 Photographer: Kerri McCabe Description: Looking NE, this photo shows an area of the overflow with residual crude oil staining the outside of the secondary containment berm. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 Location: Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.253333, 92.538889. City: El Dorado County/Parish: Union State: AR Photo File Name: 100-0379 Orientation: NNE Date of Photo: 11/08/2024 Time of Photo: 1404 Latitude: 33.253433 Longitude: -92.539033 Photographer: Kerri McCabe Description: Looking NNE, this photo shows an area of the secondary containment berm that had been repaired since the 10/08/2024 inspection.