Document wKgGdOXQvJVNz9rJo8adJ9p34

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 03/05/2025 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: Smith, Roger G Troy Tokio Unit Tank Battery From Willisville, State Highway 371 North, right on Hwy 76, right on Nevark Rd, and then left onto an oilfield lease road at 33.535099, -93.156694. Willisville, AR 71730 2515 North Vine Magnolia, AR 71753 Nevada County 870-234-4421 Roger Smith (870-234-4421) Person Responsible for Operation Dalton Smith (Representative) daltonsmith12@gmail.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: N/A ARU002288 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: 2025.04.10 15:37:19 -05'00' Date JEANNE ECKHART Date: 2025.04.14 06:59:39 -05'00' Digitally signed by JEANNE ECKHART Jeanne Eckhart Date 6ENFORM-019-R8.2 (02/12/2020) 1 Section I - INTRODUCTION Smith, Roger G / Troy Tokio Unit Tank Battery (ARU002288 / CWA) Inspection Date 03/05/2025 PURPOSE OF THE INSPECTION EPA Region 6 inspectors Kerri McCabe (lead) and Michael Blaha arrived at the Smith, Roger G / Troy Tokio Unit Tank Battery ("facility") located from State Highway 371 North, right on Hwy 76, right on Nevark Rd, and then left onto an oilfield lease road at 33.535099, -93.156694 in Willisville, Nevada County, Arkansas; at 1215 on 03/05/2025 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 Smith, Roger G / Troy Tokio Unit Tank Battery facility, which contains four (4) tanks for crude oil and saltwater storage, two (2) separators/treaters, and five (5) miscellaneous tanks outside secondary containment that appeared to be out of service. Map 1. Aerial imagery (Google Earth dated 12/11/2024) of the Smith, Roger G / Troy Tokio Unit Tank Battery facility. 2 Section II - OBSERVATIONS Smith, Roger G / Troy Tokio Unit Tank Battery (ARU002288 / CWA) Inspection Date 03/05/2025 I observed the facility signage, secondary containment, pipes and valves, storage tanks, and separators/treaters; see Appendix 1 (Photographs Log), Photos No. 1 through No. 3. For additional GPS location and photo metadata, see Appendix 1. I observed product transfer lines outside secondary containment without catchment buckets, see Photos No. 2 and No. 3. I observed the sump area, the drainpipe, and a pump for the secondary containment, see Photos No. 4 through No. 6. I observed loose crude oil and salt water inside secondary containment, see Photos No. 7 and No. 8. I observed a low area in the berm of the secondary containment, see Photo No. 9. I observed an active leak of crude oil from one of the tanks inside secondary containment, see Photos No. 10 and No. 11. I observed the drainage area around the secondary containment, flowlines directed toward the saltwater disposal (SWD) well, and bare soil and dead vegetation from a potential saltwater release, see Photos No. 12 through No. 15. I observed five (5) miscellaneous tanks outside secondary containment that appeared to be out of service, see Photos No. 16 and No. 17. Section III - AREAS OF CONCERN No closing conference was held due to no personnel with Smith, Roger G being present during the inspection. Areas of concern at the time of the inspection include the following: Product transfer lines outside secondary containment without catchment buckets (Photos No. 2 and No. 3), Loose and residual crude oil and saltwater inside secondary containment (Photos No. 4, No. 7 and No. 8), The drainpipe for secondary containment without a cap (Photo No. 6), A low area in the berm for the secondary containment (Photo No. 9), An active leak of crude oil from a tank inside secondary containment (Photos No. 10 and No. 11), Bare, erodible soils and dead vegetation from a potential saltwater release (Photos No. 12 through No. 15), and Miscellaneous tanks outside secondary containment that appear to be out of service and not properly labeled (Photos No. 16 and No. 17). 3 Section IV - FOLLOW UP Smith, Roger G / Troy Tokio Unit Tank Battery (ARU002288 / CWA) Inspection Date 03/05/2025 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 - 17 photos taken 03/05/2025. 4 Smith, Roger G / Troy Tokio Unit Tank Battery (ARU002288 / CWA) Inspection Date 03/05/2025 Appendix 1 Photograph Log 17 Photos UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: From Willisville (Nevark Community), State Hwy 371, right on Hwy 76, right on Nevark Rd, then left onto an oilfield lease road at 33.535099, -93.156694. City: Willisville (Nevark) County/Parish: Nevada State: Arkansas Photo File Name: 100-0705 Orientation: 130 SE Date of Photo: 03/05/2025 Time of Photo: 1223 Latitude: 33.535217 Longitude: -93.156667 Photographer: Kerri McCabe Description: Looking SE, this photo shows the signage for the Troy Tokio Unit Tank Battery ("facility"). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: From Willisville (Nevark Community), State Hwy 371, right on Hwy 76, right on Nevark Rd, then left onto an oilfield lease road at 33.535099, -93.156694. City: Willisville (Nevark) County/Parish: Nevada State: Arkansas Photo File Name: 100-0706 Orientation: 71 ENE Date of Photo: 03/05/2025 Time of Photo: 1223 Latitude: 33.535117 Longitude: -93.156733 Photographer: Kerri McCabe Description: Looking ENE, this photo shows an overview of the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: From Willisville (Nevark Community), State Hwy 371, right on Hwy 76, right on Nevark Rd, then left onto an oilfield lease road at 33.535099, -93.156694. City: Willisville (Nevark) County/Parish: Nevada State: Arkansas Photo File Name: 100-0707 Orientation: 44 NE Date of Photo: 03/05/2025 Time of Photo: 1223 Latitude: 33.535133 Longitude: -93.156750 Photographer: Kerri McCabe Description: Looking NE, this photo shows a side view of the inside of the secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: From Willisville (Nevark Community), State Hwy 371, right on Hwy 76, right on Nevark Rd, then left onto an oilfield lease road at 33.535099, -93.156694. City: Willisville (Nevark) County/Parish: Nevada State: Arkansas Photo File Name: 100-0708 Orientation: 49 NE Date of Photo: 03/05/2025 Time of Photo: 1223 Latitude: 33.535067 Longitude: -93.156633 Photographer: Kerri McCabe Description: Looking NE, this photo shows a view of the backside and the sump area inside the secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: From Willisville (Nevark Community), State Hwy 371, right on Hwy 76, right on Nevark Rd, then left onto an oilfield lease road at 33.535099, -93.156694. City: Willisville (Nevark) County/Parish: Nevada State: Arkansas Photo File Name: 100-0709 Orientation: 67 ENE Date of Photo: 03/05/2025 Time of Photo: 1224 Latitude: 33.535083 Longitude: -93.156600 Photographer: Kerri McCabe Description: Looking ENE, this photo shows a pump used at the drainpipe for the sump area of the secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: From Willisville (Nevark Community), State Hwy 371, right on Hwy 76, right on Nevark Rd, then left onto an oilfield lease road at 33.535099, -93.156694. City: Willisville (Nevark) County/Parish: Nevada State: Arkansas Photo File Name: 100-0710 Orientation: 358 N Date of Photo: 03/05/2025 Time of Photo: 1224 Latitude: 33.535033 Longitude: -93.156517 Photographer: Kerri McCabe Description: Looking N, this photo shows the drainpipe for secondary containment with a closed valve and no cap. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: From Willisville (Nevark Community), State Hwy 371, right on Hwy 76, right on Nevark Rd, then left onto an oilfield lease road at 33.535099, -93.156694. City: Willisville (Nevark) County/Parish: Nevada State: Arkansas Photo File Name: 100-0712 Orientation: 18 NNE Date of Photo: 03/05/2025 Time of Photo: 1225 Latitude: 33.535217 Longitude: -93.156500 Photographer: Kerri McCabe Description: Looking NNE, this photo shows loose crude oil and saltwater inside the secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: From Willisville (Nevark Community), State Hwy 371, right on Hwy 76, right on Nevark Rd, then left onto an oilfield lease road at 33.535099, -93.156694. City: Willisville (Nevark) County/Parish: Nevada State: Arkansas Photo File Name: 100-0716 Orientation: 358 N Date of Photo: 03/05/2025 Time of Photo: 1226 Latitude: 33.535350 Longitude: -93.156383 Photographer: Kerri McCabe Description: Looking N, this photo shows the pump used for the saltwater disposal (SWD) injection well. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 Location: From Willisville (Nevark Community), State Hwy 371, right on Hwy 76, right on Nevark Rd, then left onto an oilfield lease road at 33.535099, -93.156694. City: Willisville (Nevark) County/Parish: Nevada State: Arkansas Photo File Name: 100-0717 Orientation: 324 NW Date of Photo: 03/05/2025 Time of Photo: 1227 Latitude: 33.535483 Longitude: -93.156450 Photographer: Kerri McCabe Description: Looking NW, this photo shows a low area in the berm for the secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 10 Location: From Willisville (Nevark Community), State Hwy 371, right on Hwy 76, right on Nevark Rd, then left onto an oilfield lease road at 33.535099, -93.156694. City: Willisville (Nevark) County/Parish: Nevada State: Arkansas Photo File Name: 100-0719 Orientation: 179 S Date of Photo: 03/05/2025 Time of Photo: 1227 Latitude: 33.535433 Longitude: -93.156517 Photographer: Kerri McCabe Description: Looking S, this photo shows a frontside view inside the secondary containment with an active crude oil leak. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 11 Location: From Willisville (Nevark Community), State Hwy 371, right on Hwy 76, right on Nevark Rd, then left onto an oilfield lease road at 33.535099, -93.156694. City: Willisville (Nevark) County/Parish: Nevada State: Arkansas Photo File Name: 100-0720 Orientation: 42 NE Date of Photo: 03/05/2025 Time of Photo: 1227 Latitude: 33.535333 Longitude: -93.156600 Photographer: Kerri McCabe Description: Looking NE, this photo shows a closeup of the active crude oil leak from Photo No. 10. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 12 Location: From Willisville (Nevark Community), State Hwy 371, right on Hwy 76, right on Nevark Rd, then left onto an oilfield lease road at 33.535099, -93.156694. City: Willisville (Nevark) County/Parish: Nevada State: Arkansas Photo File Name: 100-0718 Orientation: 86 E Date of Photo: 03/05/2025 Time of Photo: 1227 Latitude: 33.535517 Longitude: -93.156550 Photographer: Kerri McCabe Description: Looking E, this photo shows the drainage area around the tank battery with dead vegetation in the background. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 13 Location: From Willisville (Nevark Community), State Hwy 371, right on Hwy 76, right on Nevark Rd, then left onto an oilfield lease road at 33.535099, -93.156694. City: Willisville (Nevark) County/Parish: Nevada State: Arkansas Photo File Name: 100-0722 Orientation: 112 ESE Date of Photo: 03/05/2025 Time of Photo: 1228 Latitude: 33.535483 Longitude: -93.156483 Photographer: Kerri McCabe Description: Looking ESE, this photo shows a closeup view of the dead vegetation from Photo No. 12. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 14 Location: From Willisville (Nevark Community), State Hwy 371, right on Hwy 76, right on Nevark Rd, then left onto an oilfield lease road at 33.535099, -93.156694. City: Willisville (Nevark) County/Parish: Nevada State: Arkansas Photo File Name: 100-0723 Orientation: 113 ESE Date of Photo: 03/05/2025 Time of Photo: 1229 Latitude: 33.535217 Longitude: -93.156150 Photographer: Kerri McCabe Description: Looking ESE, this photo shows a historic saltwater release within the flowline area for the SWD injection well. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 15 Location: From Willisville (Nevark Community), State Hwy 371, right on Hwy 76, right on Nevark Rd, then left onto an oilfield lease road at 33.535099, -93.156694. City: Willisville (Nevark) County/Parish: Nevada State: Arkansas Photo File Name: 100-0724 Orientation: 339 NNW Date of Photo: 03/05/2025 Time of Photo: 1237 Latitude: 33.535033 Longitude: -93.155717 Photographer: Kerri McCabe Description: Looking NNW, this photo shows an additional view of the drainage area and the historic saltwater release from Photo No. 14. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 16 Location: From Willisville (Nevark Community), State Hwy 371, right on Hwy 76, right on Nevark Rd, then left onto an oilfield lease road at 33.535099, -93.156694. City: Willisville (Nevark) County/Parish: Nevada State: Arkansas Photo File Name: 100-0725 Orientation: 18 NNE Date of Photo: 03/05/2025 Time of Photo: 1241 Latitude: 33.535200 Longitude: -93.156617 Photographer: Kerri McCabe Description: Looking NNE, this photo shows two (2) treaters and a storage tank that appear to be out of service. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 17 Location: From Willisville (Nevark Community), State Hwy 371, right on Hwy 76, right on Nevark Rd, then left onto an oilfield lease road at 33.535099, -93.156694. City: Willisville (Nevark) County/Parish: Nevada State: Arkansas Photo File Name: 100-0726 Orientation: 263 W Date of Photo: 03/05/2025 Time of Photo: 1241 Latitude: 33.535200 Longitude: -93.156600 Photographer: Kerri McCabe Description: Looking W, this photo shows an additional two (2) storage tanks outside secondary containment that appear to be out of service.