Document vBxexwYNgMJ91mqJMaDoZn7bE

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 01/30/2025 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: ArklaTx Operating Co., Inc. Spooner, WW Lease Tank Battery In Old Union (El Dorado), Union County, Arkansas from Arkansas Highway 63 North, thence left onto Kelly Rd, and right onto an oil field lease road at 33.250127, -92.547190. El Dorado, AR 71759 706 Ouachita Road 72 Smackover, AR 71762 Union County 870-725-3666 Larry L. Oswald (318-995-0502) Person Responsible for Operation Rick V. Bauman (870-314-0807) Representative rvbauman@yahoo.com (Rick V. Bauman) FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: N/A ARU002279 N/A 211111 1311 Personnel participating in inspection: Kerri McCabe (lead) EPA / Region 6 ECDW Michael Blaha EPA / Region 6 ECDW Inspector / Enforcement Officer Inspector / Enforcement Officer EPA Lead Inspector Signature/Date Supervisor Signature/Date KERRI MCCABE Kerri McCabe Digitally signed by KERRI MCCABE Date: 2025.04.02 07:41:41 -05'00' Date JEANNE ECKHART Date: 2025.04.03 11:11:26 -05'00' Digitally signed by JEANNE ECKHART Jeanne Eckhart Date 6ENFORM-019-R8.2 (02/12/2020) 1 ArklaTx Operating Co., Inc. / Spooner, WW Lease Tank Battery (ARU002279 / CWA) Inspection Date 01/30/2025 Section I - INTRODUCTION PURPOSE OF THE INSPECTION EPA Region 6 Inspectors Kerri McCabe (lead) and Michael Blaha arrived at the ArklaTx Operating Co., Inc. / Spooner, WW Lease Tank Battery ("facility") located from Arkansas Highway 63 North, thence left onto Kelly Rd, and right onto an oil field lease road at 33.250127, -92.547190 in Old Union, Union County, Arkansas; at 0900 on 01/30/2025 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 ArklaTx Operating Co., Inc. / Spooner, WW Lease Tank Battery facility, which contained one (1) tank battery, four (4) storage tanks for crude oil/saltwater storage, one (1) saltwater disposal (SWD) injection well, and one (1) production well. Map 1. Aerial imagery (Google Earth dated 03/11/2024) of the ArklaTx Operating Co., Inc. / Spooner, WW Lease Tank Battery. 2 ArklaTx Operating Co., Inc. / Spooner, WW Lease Tank Battery (ARU002279 / CWA) Inspection Date 01/30/2025 Section II - OBSERVATIONS I observed the facility sign, secondary containment, pipes and valves, and storage tanks located at the facility; see Appendix 1 (Photographs Log), Photo No. 1 through No. 6. For additional GPS location and photo metadata, see Appendix 1. I observed an excavated pit adjacent to the tank battery, which had a drainpipe open to the pit. The pit contained residual crude oil, and there was a flowline passing through the pit's earthen levee, see Photo No. 7 through No. 12. I observed the SWD injection well located onsite with residual crude oil noted on the ground, see Photo No. 13 and No. 14. I observed a nearby crude oil production well and a flowline that were adjacent to a wetland. Total Dissolved Solid (TDS) readings were obtained from the surface water in the wetland in the area adjacent to the production well, see Photo No. 15 through No. 28. I observed a TDS reading of 1,408 mg/L in the drainage from the production well, see Photo No. 17 through No. 19. I observed dead vegetation and oil staining in the wetland, see Photo No. 20. I observed an elevated TDS reading of 16,993 mg/L in a pool of water in the wetland, see Photo No. 21 through No. 23. I observed a TDS reading of 2,162 mg/L at a series of culverts under a lease road in the wetland downstream from the elevated TDS reading referenced above, see Photo No. 24 through No. 27. I observed a flowline parallel to the lease road, see Photo No. 28. Section III - AREAS OF CONCERN No closing conference was held due to no personnel with ArklaTx Operating Co., Inc. being present during the inspection. Areas of concern at the time of the inspection include the following: Residual, loose crude oil inside the tank battery (Photo No. 5), An open pipe through the secondary containment berm of the tank battery (Photo No. 6), An excavated pit adjacent to the tank battery with residual, loose crude oil and a flowline passing through the earthen levee of the pit (Photo No. 7 through No. 12), Residual, loose oil around the SWD injection well onsite (Photo No. 14), Residual, loose oil around a nearby production well (Photo No. 15), and Elevated TDS readings from surface water of a wetland near the production well (Photos No. 17, No. 21, and No. 24). 3 ArklaTx Operating Co., Inc. / Spooner, WW Lease Tank Battery (ARU002279 / CWA) Inspection Date 01/30/2025 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 - 28 photos taken 01/30/2025 4 ArklaTx Operating Co., Inc. / Spooner, WW Lease Tank Battery (ARU002279 / CWA) Inspection Date 01/30/2025 Appendix 1 Photograph Log 28 Photos UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: Located from Arkansas Highway 63 North, thence left onto Kelly Rd, and right onto an oil field lease road at 33.250127, -92.547190. City: Old Union (El Dorado) County/Parish: Union State: Arkansas Photo File Name: 100-0507 Orientation: 40 NE Date of Photo: 01/30/2025 Time of Photo: 0917 Latitude: 33.250117 Longitude: -92.547367 Photographer: Kerri McCabe Description: Looking NE, this photo shows the signage for the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: Located from Arkansas Highway 63 North, thence left onto Kelly Rd, and right onto an oil field lease road at 33.250127, -92.547190. City: Old Union (El Dorado) County/Parish: Union State: Arkansas Photo File Name: 100-0508 Orientation: 50 NE Date of Photo: 01/30/2025 Time of Photo: 0917 Latitude: 33.250033 Longitude: -92.547417 Photographer: Kerri McCabe Description: Looking NE, this photo shows an overview of the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: Located from Arkansas Highway 63 North, thence left onto Kelly Rd, and right onto an oil field lease road at 33.250127, -92.547190. City: Old Union (El Dorado) County/Parish: Union State: Arkansas Photo File Name: 100-0509 Orientation: 79 E Date of Photo: 01/30/2025 Time of Photo: 0917 Latitude: 33.250083 Longitude: -92.547433 Photographer: Kerri McCabe Description: Looking E, this photo shows the frontside of the tank battery with transfer lines and catchment for product. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: Located from Arkansas Highway 63 North, thence left onto Kelly Rd, and right onto an oil field lease road at 33.250127, -92.547190. City: Old Union (El Dorado) County/Parish: Union State: Arkansas Photo File Name: 100-0510 Orientation: 15 NNE Date of Photo: 01/30/2025 Time of Photo: 0918 Latitude: 33.250100 Longitude: -92.547317 Photographer: Kerri McCabe Description: Looking NNE, this photo shows the backside of the tank battery with some residual oil noted inside the tank battery. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: Located from Arkansas Highway 63 North, thence left onto Kelly Rd, and right onto an oil field lease road at 33.250127, -92.547190. City: Old Union (El Dorado) County/Parish: Union State: Arkansas Photo File Name: 100-0522 Orientation: 72 ENE Date of Photo: 01/30/2025 Time of Photo: 0922 Latitude: 33.250333 Longitude: -92.547267 Photographer: Kerri McCabe Description: Looking ENE, this photo shows an open pipe coming through the secondary containment of the tank battery without a shutoff valve or cap. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: Located from Arkansas Highway 63 North, thence left onto Kelly Rd, and right onto an oil field lease road at 33.250127, -92.547190. City: Old Union (El Dorado) County/Parish: Union State: Arkansas Photo File Name: 100-0524 Orientation: 87 E Date of Photo: 01/30/2025 Time of Photo: 0923 Latitude: 33.250167 Longitude: -92.547433 Photographer: Kerri McCabe Description: Looking E, this photo shows residual, loose oil inside secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: Located from Arkansas Highway 63 North, thence left onto Kelly Rd, and right onto an oil field lease road at 33.250127, -92.547190. City: Old Union (El Dorado) County/Parish: Union State: Arkansas Photo File Name: 100-0512 Orientation: 14 NNE Date of Photo: 01/30/2025 Time of Photo: 0918 Latitude: 33.250167 Longitude: -92.547217 Photographer: Kerri McCabe Description: Looking NNE, this photo shows a pit directly behind the drainpipe for the tank battery. Residual, loose oil staining was noted within the pit. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: Located from Arkansas Highway 63 North, thence left onto Kelly Rd, and right onto an oil field lease road at 33.250127, -92.547190. City: Old Union (El Dorado) County/Parish: Union State: Arkansas Photo File Name: 100-0516 Orientation: 230 SW Date of Photo: 01/30/2025 Time of Photo: 0920 Latitude: 33.250367 Longitude: -92.547052 Photographer: Kerri McCabe Description: Looking SW, this photo shows an alternate view of the pit, drainpipe, and residual oil from Photo No. 7. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 Location: Located from Arkansas Highway 63 North, thence left onto Kelly Rd, and right onto an oil field lease road at 33.250127, -92.547190. City: Old Union (El Dorado) County/Parish: Union State: Arkansas Photo File Name: 100-0517 Orientation: 101 E Date of Photo: 01/30/2025 Time of Photo: 0920 Latitude: 33.250359 Longitude: -92.547083 Photographer: Kerri McCabe Description: Looking E, this photo shows a flowline ran through the levee of the pit from Photo No. 7. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 10 Location: Located from Arkansas Highway 63 North, thence left onto Kelly Rd, and right onto an oil field lease road at 33.250127, -92.547190. City: Old Union (El Dorado) County/Parish: Union State: Arkansas Photo File Name: 100-0518 Orientation: 96 E Date of Photo: 01/30/2025 Time of Photo: 0920 Latitude: 33.250351 Longitude: -92.547083 Photographer: Kerri McCabe Description: Looking E, this photo shows the flowline from Photo No. 9 from the inside of the pit. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 11 Location: Located from Arkansas Highway 63 North, thence left onto Kelly Rd, and right onto an oil field lease road at 33.250127, -92.547190. City: Old Union (El Dorado) County/Parish: Union State: Arkansas Photo File Name: 100-0519 Orientation: 67 ENE Date of Photo: 01/30/2025 Time of Photo: 0920 Latitude: 33.250351 Longitude: -92.547083 Photographer: Kerri McCabe Description: Looking ENE, this photo shows the flowline from Photo No. 9 from the outside of the pit. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 12 Location: Located from Arkansas Highway 63 North, thence left onto Kelly Rd, and right onto an oil field lease road at 33.250127, -92.547190. City: Old Union (El Dorado) County/Parish: Union State: Arkansas Photo File Name: 100-0520 Orientation: 27 NNE Date of Photo: 01/30/2025 Time of Photo: 0921 Latitude: 33.250351 Longitude: -92.547200 Photographer: Kerri McCabe Description: Looking NNE, this photo shows the open drainpipe for the tank battery directed to the pit. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 13 Location: Located from Arkansas Highway 63 North, thence left onto Kelly Rd, and right onto an oil field lease road at 33.250127, -92.547190. City: Old Union (El Dorado) County/Parish: Union State: Arkansas Photo File Name: 100-0513 Orientation: 14 NNE Date of Photo: 01/30/2025 Time of Photo: 0919 Latitude: 33.250267 Longitude: -92.547000 Photographer: Kerri McCabe Description: Looking NNE, this photo shows the signage and an overview of the saltwater disposal (SWD) injection well adjacent to the tank battery. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 14 Location: Located from Arkansas Highway 63 North, thence left onto Kelly Rd, and right onto an oil field lease road at 33.250127, -92.547190. City: Old Union (El Dorado) County/Parish: Union State: Arkansas Photo File Name: 100-0515 Orientation: 9 N Date of Photo: 01/30/2025 Time of Photo: 0919 Latitude: 33.250332 Longitude: -92.546967 Photographer: Kerri McCabe Description: Looking N, this photo shows residual, loose oil on the ground around the SWD injection well. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 15 Location: Located from Arkansas Highway 63 North, thence left onto Kelly Rd, and right onto an oil field lease road at 33.250127, -92.547190. City: Old Union (El Dorado) County/Parish: Union State: Arkansas Photo File Name: 100-0526 Orientation: 135 SE Date of Photo: 01/30/2025 Time of Photo: 0930 Latitude: 33.251583 Longitude: -92.546617 Photographer: Kerri McCabe Description: Looking SE, this photo shows residual, loose oil on the ground around a nearby production well. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 16 Location: Located from Arkansas Highway 63 North, thence left onto Kelly Rd, and right onto an oil field lease road at 33.250127, -92.547190. City: Old Union (El Dorado) County/Parish: Union State: Arkansas Photo File Name: 100-0528 Orientation: 173 S Date of Photo: 01/30/2025 Time of Photo: 0932 Latitude: 33.251367 Longitude: -92.546567 Photographer: Kerri McCabe Description: Looking S, this photo shows a flowpath through a wetland adjacent to the production well. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 17 Location: Located from Arkansas Highway 63 North, thence left onto Kelly Rd, and right onto an oil field lease road at 33.250127, -92.547190. City: Old Union (El Dorado) County/Parish: Union State: Arkansas Photo File Name: 100-0529 Orientation: 354 N Date of Photo: 01/30/2025 Time of Photo: 0932 Latitude: 33.251300 Longitude: -92.546583 Photographer: Kerri McCabe Description: Looking N, this photo shows a Total Dissolved Solids (TDS) reading of 1,408 mg/L for the water in the drainage from the production well area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 18 Location: Located from Arkansas Highway 63 North, thence left onto Kelly Rd, and right onto an oil field lease road at 33.250127, -92.547190. City: Old Union (El Dorado) County/Parish: Union State: Arkansas Photo File Name: 100-0530 Orientation: 26 NNE Date of Photo: 01/30/2025 Time of Photo: 0932 Latitude: 33.251283 Longitude: -92.546567 Photographer: Kerri McCabe Description: Looking NNE, this photo shows the upstream view of the drainage from Photo No. 17. Flow direction line added for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 19 Location: Located from Arkansas Highway 63 North, thence left onto Kelly Rd, and right onto an oil field lease road at 33.250127, -92.547190. City: Old Union (El Dorado) County/Parish: Union State: Arkansas Photo File Name: 100-0531 Orientation: 166 SSE Date of Photo: 01/30/2025 Time of Photo: 0932 Latitude: 33.251303 Longitude: -92.546567 Photographer: Kerri McCabe Description: Looking SSE, this photo shows the downstream view of the drainage from Photo No. 17. Flow direction line added for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 20 Location: Located from Arkansas Highway 63 North, thence left onto Kelly Rd, and right onto an oil field lease road at 33.250127, -92.547190. City: Old Union (El Dorado) County/Parish: Union State: Arkansas Photo File Name: 100-0532 Orientation: 328 NNW Date of Photo: 01/30/2025 Time of Photo: 0933 Latitude: 33.251234 Longitude: -92.546567 Photographer: Kerri McCabe Description: Looking NNW, this photo shows dead vegetation and oil staining in the wetland. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 21 Location: Located from Arkansas Highway 63 North, thence left onto Kelly Rd, and right onto an oil field lease road at 33.250127, -92.547190. City: Old Union (El Dorado) County/Parish: Union State: Arkansas Photo File Name: 100-0533 Orientation: 352 N Date of Photo: 01/30/2025 Time of Photo: 0937 Latitude: 33.251133 Longitude: -92.546617 Photographer: Kerri McCabe Description: Looking N, this photo shows the TDS reading of 16,993 mg/L in a pool of water in the wetland downstream of the drainage from the production well. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 22 Location: Located from Arkansas Highway 63 North, thence left onto Kelly Rd, and right onto an oil field lease road at 33.250127, -92.547190. City: Old Union (El Dorado) County/Parish: Union State: Arkansas Photo File Name: 100-0534 Orientation: 352 N Date of Photo: 01/30/2025 Time of Photo: 0937 Latitude: 33.251150 Longitude: -92.546617 Photographer: Kerri McCabe Description: Looking N, this photo shows the upstream view of the pool of water in the wetland from Photo No. 21. Flow direction line added for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 23 Location: Located from Arkansas Highway 63 North, thence left onto Kelly Rd, and right onto an oil field lease road at 33.250127, -92.547190. City: Old Union (El Dorado) County/Parish: Union State: Arkansas Photo File Name: 100-0535 Orientation: 151 SSE Date of Photo: 01/30/2025 Time of Photo: 0937 Latitude: 33.251167 Longitude: -92.546600 Photographer: Kerri McCabe Description: Looking SSE, this photo shows the downstream view of the pool of water in the wetland from Photo No. 21. Flow direction lined added for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 24 Location: Located from Arkansas Highway 63 North, thence left onto Kelly Rd, and right onto an oil field lease road at 33.250127, -92.547190. City: Old Union (El Dorado) County/Parish: Union State: Arkansas Photo File Name: 100-0536 Orientation: 82 E Date of Photo: 01/30/2025 Time of Photo: 0939 Latitude: 33.251033 Longitude: -92.546567 Photographer: Kerri McCabe Description: Looking E, this photo shows the TDS reading of 2,162 mg/L at a series of culverts under the lease road in the wetland downstream of the pool of water in Photo No. 22. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 25 Location: Located from Arkansas Highway 63 North, thence left onto Kelly Rd, and right onto an oil field lease road at 33.250127, -92.547190. City: Old Union (El Dorado) County/Parish: Union State: Arkansas Photo File Name: 100-0537 Orientation: 331 NNW Date of Photo: 01/30/2025 Time of Photo: 0939 Latitude: 33.251033 Longitude: -92.546567 Photographer: Kerri McCabe Description: Looking NNW, this photo shows the upstream view of the culvert area in the wetland from Photo No. 24. Flow direction line added for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 26 Location: Located from Arkansas Highway 63 North, thence left onto Kelly Rd, and right onto an oil field lease road at 33.250127, -92.547190. City: Old Union (El Dorado) County/Parish: Union State: Arkansas Photo File Name: 100-0538 Orientation: 97 E Date of Photo: 01/30/2025 Time of Photo: 0939 Latitude: 33.251050 Longitude: -92.546567 Photographer: Kerri McCabe Description: Looking E, this photo shows the downstream view of the culvert area in the wetland from Photo No. 24. Flow direction line added for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 27 Location: Located from Arkansas Highway 63 North, thence left onto Kelly Rd, and right onto an oil field lease road at 33.250127, -92.547190. City: Old Union (El Dorado) County/Parish: Union State: Arkansas Photo File Name: 100-0539 Orientation: 46 NE Date of Photo: 01/30/2025 Time of Photo: 0939 Latitude: 33.251001 Longitude: -92.546615 Photographer: Kerri McCabe Description: Looking NE, this photo shows an additional view of the wetland connected by culverts under the lease road. Flow direction line added for clarity. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 28 Location: Located from Arkansas Highway 63 North, thence left onto Kelly Rd, and right onto an oil field lease road at 33.250127, -92.547190. City: Old Union (El Dorado) County/Parish: Union State: Arkansas Photo File Name: 100-0541 Orientation: 20 NNE Date of Photo: 01/30/2025 Time of Photo: 0940 Latitude: 33.251150 Longitude: -92.546600 Photographer: Kerri McCabe Description: Looking NNE, this photo shows an anchor used to keep the flowline in place during highflow events. Flowline is parallel with the lease road.