Document rpEmDV4q5mDnqjVD39kvbp0V7

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 06/09/2022 Water Clean Water Act - National Pollution Discharge Elimination System (Brine) Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: PE-Osage, LLC Breene Unit Latitude: 36.283030, Longitude: -96.209480 Skiatook, Oklahoma, 74070 PO BOX 13178 Oklahoma City, Oklahoma, 73113 Osage County 405-607-8826 Roy Fletcher CEO raf@pennant-energy.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: n/a OKU000875 n/a 211111 1311 Personnel participating in inspection: Matthew Allen EPA, Region 6 ECDW Carl Wills EPA, Region 6 ECDWA Inspector Inspector EPA Lead Inspector Signature/Date Supervisor Signature/Date Carl Wills 07/28/2022 Date ESTEBAN HERRERA Date: 2022.07.28 12:37:49 -05'00' Digitally signed by ESTEBAN HERRERA Esteban Herrera Date 6ENFORM-019-R8.2 (02/12/2020) 1 Section I - INTRODUCTION PE Osage/ Breene Unit (CWA) Inspection Date 06/09/2022 PURPOSE OF THE INSPECTION EPA Region 6 inspectors Carl Wills and Matthew Allen arrived at the PE Osage, LLC, Breene Unit (EPA ID No. OKU000875), at 1:30 PM on 06/09/2022 for an unannounced inspection. Carl Wills was the lead inspector for the inspection. There was no company representative present at the inspection. The inspection was conducted by the authority of the Clean Water Act to determine compliance with Environmental Protection Agency (EPA) regulations. There was no other Federal, State or Local agency present at the time of the inspection. FACILITY DESCRIPTION EPA conducted a follow-up inspection on the PE-Osage, Breene Unit. The Breene Unit was located approximately 11.5 miles southwest of Skiatook, Oklahoma, in Osage County. Section II - OBSERVATIONS I observed the Breene Unit tank battery and sign, this was documented in Appendix 1/Photo Log, photo No. 1. I observed the secondary containment pit inside the Breene Unit tank battery berm, which was full of water at the time of the inspection. The secondary containment pit was documented in photo No. 2. On the south side of the southernmost secondary containment berm of the Breene Unit tank battery, I observed water leaking through the berm and flowing downgradient to the south, this was documented in photo No. 3. I observed the water as it continued south along the flowpath. I observed the impacted land/soil along the flowpath and estimated approximately 80 percent of the impacted area had fully recovered with vegetation. Section III - AREAS OF CONCERN EPA Region 6 inspectors observed water leaking through the secondary containment berm which could allow recurrence of the spill event as the primary area of concern. The secondary containment pit should be emptied, and the secondary containment berm should be repaired to prevent fluid migration through the berm. I also observed moderate soil erosion along the flowpath where brine impacts prevented revegetation, this area of soil erosion should be corrected to prevent additional erosion. Section IV - FOLLOW UP No additional information was received by EPA after exiting the Facility on 06/09/2022. Section V - LIST OF APPENDICES Appendix 1 - Photo Log - 4 photos taken 06/09/2022 2 PE-Osage/ Breene Unit (CWA) Inspection Date: 06/09/2022 Appendix 1 Photograph Log 4 Photos UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.283030, -96.209480 City: Skiatook Photo No. 1 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0599 Orientation: S Date of Photo: 06/09/2022 Time of Photo: 1:58 PM Latitude: 36.283030 Longitude: -96.209480 Photographer: Carl Wills Description: This was the Breene Unit tank battery sign. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.283030, -96.209480 City: Skiatook Photo No. 2 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0601 Orientation: S Date of Photo: 06/09/2022 Time of Photo: 2:06 PM Latitude: 36.283030 Longitude: -96.209480 Photographer: Carl Wills Description: This was a photo showing the secondary containment "pit" located at the Breene Unit tank battery. The pit was full of water at the time of the inspection. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.283030, -96.209480 City: Skiatook Photo No. 3 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0602 Orientation: N Date of Photo: 06/09/2022 Time of Photo: 2:09 PM Latitude: 36.283013 Longitude: -96.209779 Photographer: Carl Wills Description: This was a photo of the south berm of the Breene Unit tank battery. The pit full of water was located on the north side of the berm, inside the tank battery. Water was flowing from inside the tank battery, through the berm, then continuing south downgradient. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.283030, -96.209480 City: Skiatook Photo No. 4 County/Parish: Osage State: Oklahoma Photo File Name: DSCN0603 Orientation: S Date of Photo: 06/09/2022 Time of Photo: 2:11 PM Latitude: 36.283013 Longitude: -96.209779 Photographer: Carl Wills Description: This was a photo taken standing at the south berm of the Breene Unit tank battery, with a view downgradient/south. The flowpath had not fully recovered from the brine impacts. I estimated the flowpath was approximately 80 percent recovered.