Document wqqgMNoZJV13gOBvR2xmO1r3D

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 8 RESOURCE CONSERVATION AND RECOVERY ACT BASIC INFORMATION Facility Name: Calpet - La Barge COWDF Facility Location: 42.393747, -110.273988 RCRA ID: WYR000204065 Notification Status: Non-notifier Facility Contacts: Colton Ellingford, 307- 679-5804 Date of Inspection: May 16, 2023 Lead Inspector: Annette Maxwell Arrival Time: 12:15 p.m. Departure Time: 1:34 p.m. Other Attendees: 1. Dennis Lamb, Wyoming Department of Environmental Quality (WDEQ) 2. Colton Ellingford, R360 Environmental Solutions 3. Dee Merritt, R360 Environmental Solutions Type and Purpose of Inspection: Compliance Evaluation Inspection Facility Type: Commercial Oilfield Waste Disposal Facility Applicable Statute to Inspection: RCRA Section 7003 Inspection Type: Announced Inspection Joint: U.S. EPA and Wyoming DEQ OPENING CONFERENCE Facility Operator: Calpet LLC General Facility and Process Description: The Calpet - La Barge facility is a commercial oilfield waste disposal facility (COWDF) that receives RCRA Subtitle C-exempt E&P oilfield waste for storage, treatment and/or disposal. The facility has been issued a permit to operate a COWDF by WDEQ. The facility includes six evaporation ponds (two of which are being converted to landfills), a slop/skim pit, a centrifuge system, storage tanks and a tanker truck offload area. The facility receives and manages waste liquids and solids pursuant to WDEQ Water Quality Division authorization; this includes conversion of Ponds 6 and 9 to RCRA Subtitle C-exempt oilfield waste landfills. A site map is attached as Appendix 1. A RCRA 7003 Amended Administrative Order, Docket No. RCRA-08-2012-0001 (AAO), was issued on May 9, 2012, and remained active at the time of this inspection. The most recent annual report, submitted pursuant to Section VII.E of the AAO, was received on April 11, 2023. Facility Name: Calpet - La Barge COWDF Facility Location: 42.393747, -110.273988 Date of Inspection: May 16, 2023 TOUR INFORMATION Upon arrival at the facility, an opening conference was conducted with Mr. Ellingford and Mr. Merritt, followed by a site walk-through. Areas of the facility toured: Evaporation ponds Slop/skim settling pond Tanker offload area Data Collected and Observations: During the inspection, I observed that netting over the slop/skim pit, referred to as Pond 4, was sagging into the oily waste with oil exposed above the extent of the netting on the east side of the pond. Significant bad weather in the weeks and months before the inspection appeared to be the cause. Mr. Merritt stated that the ponds had only recently thawed out. Mr. Ellingford stated that the entire section of netting would be pulled down and replaced. See photos 2012-2014 and 2021. All inspection photos are included in a photo log attached as Appendix 2. At Pond 6, which has largely, but not yet completely, converted to a waste solids landfill, I observed that very limited standing water was present. Filters and other debris were present in the landfill, and Mr. Ellingford stated that they are checked for radioactivity before disposal into the landfill. For photos of the landfill, see photos 2019-2020 and 2022-2024. On the south end of Pond 9, I observed what appeared to be floating algae at the southeast portion. At the north end, I observed oil floating on the surface that was contained by a hydrocarbon boom. Mr. Merritt stated that work would begin to remove the oil later that week and would include drawing down the water to allow the oil and algae to dry out. Photos 20152018. No other oil was observed on pond surfaces. A photo of pond 7 is included in Attachment 2, photo 2025. I did not observe pond 5 during the inspection. CLOSING CONFERENCE A closing conference was held with Mr. Ellingford and Mr. Merritt in which I stated that I would write an inspection report and that I expected to provide that within 70 days. Page 2 of 3 Facility Name: Calpet - La Barge COWDF Facility Location: 42.393747, -110.273988 Date of Inspection: May 16, 2023 SIGNATURE ANNETTE MAXWELL Date: 2023.07.12 05:37:53 -06'00' Digitally signed by ANNETTE MAXWELL Lead Inspector: ________________________________________________ Annette Maxwell, RCRA Inspector JANICE PEARSON Date: 2023.07.12 08:28:54 -06'00' Digitally signed by JANICE PEARSON Supervisor: ___________________________________________________ Janice A. Pearson, Manager RCRA & OPA Enforcement Branch Enforcement and Compliance Assurance Division Appendices List 1 - Site Map 2 - Photograph Log Page 3 of 3 Facility Name: Calpet - La Barge COWDF Facility Location: 42.393747, -110.273988 Date of Inspection: May 16, 2023 APPENDIX 1: SITE MAP Pond 9 (landfill conversion) Pond 6 (landfill conversion) Pond 4 (netted slop/skim) Calpet-La Barge COWDF Evaporation ponds Facility Name: Calpet - La Barge COWDF Facility Location: 42.393747, -110.273988 Date of Inspection: May 16, 2023 APPENDIX 4: PHOTO LOG For all photos: Photographer: Annette Maxwell Camera Model and ID: Nikon Coolpix S7000, B00228 Photo 2012, DSCN2012.JPG, photo of the netting over pond 4, the slop/skim pit, facing south/southeast. The netting was very degraded and dipped into the pond on the eastern portion of the pond. Page 1 of 14 Facility Name: Calpet - La Barge COWDF Facility Location: 42.393747, -110.273988 Date of Inspection: May 16, 2023 Photo 2013, DSCN2013.JPG, photo of the same area shown in photo 2012, panned right. Page 2 of 14 Facility Name: Calpet - La Barge COWDF Facility Location: 42.393747, -110.273988 Date of Inspection: May 16, 2023 Photo 2014, DSCN2014.JPG, photo of the same area as that shown in photos 2012 and 2013, panned right. Page 3 of 14 Facility Name: Calpet - La Barge COWDF Facility Location: 42.393747, -110.273988 Date of Inspection: May 16, 2023 Photo 2015, DSCN2015.JPG, photo of pond 9 near the southeast portion, facing south/southwest. Material floating on the surface appeared to be an algae. Page 4 of 14 Facility Name: Calpet - La Barge COWDF Facility Location: 42.393747, -110.273988 Date of Inspection: May 16, 2023 Photo 2016, DSCN2016.JPG, photo of the same area as that shown in photo 2015, panned right. Page 5 of 14 Facility Name: Calpet - La Barge COWDF Facility Location: 42.393747, -110.273988 Date of Inspection: May 16, 2023 Photo 2017, DSCN2017.JPG, photo of the same area shown in photo 2015 and 2016, panned right. Page 6 of 14 Facility Name: Calpet - La Barge COWDF Facility Location: 42.393747, -110.273988 Date of Inspection: May 16, 2023 Photo 2018, DSCN2018.JPG, photo of the same area shown in photos 2015-2017, panned right. Oil on the surface of the pond was contained inside a hydrocarbon boom. Page 7 of 14 Facility Name: Calpet - La Barge COWDF Facility Location: 42.393747, -110.273988 Date of Inspection: May 16, 2023 Photo 2019, DSCN2019.JPG, photo of the cell 6 landfill facing north/northeast from southwest area of the landfill. Page 8 of 14 Facility Name: Calpet - La Barge COWDF Facility Location: 42.393747, -110.273988 Date of Inspection: May 16, 2023 Photo 2020, DSCN2020.JPG, photo of the same area shown in photo 2019, panned right. Page 9 of 14 Facility Name: Calpet - La Barge COWDF Facility Location: 42.393747, -110.273988 Date of Inspection: May 16, 2023 Photo 2021, DSCN2021.JPG, photo of pond 4, the slop/skim pit, facing east. Page 10 of 14 Facility Name: Calpet - La Barge COWDF Facility Location: 42.393747, -110.273988 Date of Inspection: May 16, 2023 Photo 2022, DSCN2022.JPG, photo of the cell 6 landfill taken from the south side of the landfill facing west. Page 11 of 14 Facility Name: Calpet - La Barge COWDF Facility Location: 42.393747, -110.273988 Date of Inspection: May 16, 2023 Photo 2023, DSCN2023.JPG, photo of the same area shown in photo 2022, panned right. Page 12 of 14 Facility Name: Calpet - La Barge COWDF Facility Location: 42.393747, -110.273988 Date of Inspection: May 16, 2023 Photo 2024, DSCN2024.JPG, photo of the same area shown in photos 2022 and 2023, panned right. Page 13 of 14 Facility Name: Calpet - La Barge COWDF Facility Location: 42.393747, -110.273988 Date of Inspection: May 16, 2023 Photo 2025, DSCN2025.JPG, photo of pond 7. Page 14 of 14