Document wrJrLmV36MkeLkD2673qZj1qo

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 05/28/2024 Water Clean Water Act - National Pollutant 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: Box L Operating Lynn Lease 36.577750, -96.491602 Fairfax, OK, 74637 3337 CR 5270 Hominy, OK 74035 Osage County 918-694-7349 Jesse (JT) Hough jess.hough@yahoo.com Owner/Operator FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: n/a OKU002209 n/a 211111 1311 Personnel participating in inspection: Matthew Allen EPA Region 6 ECDW Chris Laviolette Osage Nation DNR Caleb Kennedy Osage Nation DNR Inspector Inspector Inspector EPA Lead Inspector Signature/Date Supervisor Signature/Date MATTHEW ALLEN Date: 2024.06.20 07:58:28 -05'00' Digitally signed by MATTHEW ALLEN MATTHEW ALLEN Date JEANNE ECKHART Date: 2024.06.21 11:19:03 -05'00' Digitally signed by JEANNE ECKHART JEANNE ECKHART Date 6ENFORM-019-R8.2 (02/12/2020) 1 Section I - INTRODUCTION Box L Operating / Lynn Lease (OKU002209) Inspection Date: 05/28/2024 PURPOSE OF THE INSPECTION EPA Region 6 inspector Matthew Allen arrived at the Box L Operating/Lynn Lease at 9:15AM on 05/28/2024 for an unannounced inspection. Inspector met with JT Hough (owner/operator), Mike Perrier (BIA field inspector), Chris Laviolette (Osage Nation DNR inspector) and Caleb Kennedy (Osage Nation DNR inspector) for an opening conference. This was an EPA inspection in response to a spill complaint (NRC#1400165) received by referral from the BIA Osage Agency. The inspection was conducted under the authority of the Clean Water Act (CWA) to ensure compliance with Environmental Protection Agency (EPA) regulations. FACILITY DESCRIPTION The Box L Operating, Lynn Lease tank battery consisted of 2 oil storage tanks, 2 oil/water separators, 1 saltwater storage tank and 1 saltwater disposal pump. The spill occurred when one of the oil storage tanks experienced an integrity failure, resulting in the release of crude oil into the facilities secondary containment. Released oil migrated out of the secondary containment through a previously unknown plastic pipe conduit, through the secondary containment berm, then into an unnamed tributary of Hominy Creek. Section II - OBSERVATIONS I observed the Box L Operating, Lynn Lease tank battery and facility signage. The overall facility maintenance and appearance indicated the facility was well managed except for the recent spill impacts which were not fully cleaned at the time of the inspection. See Appendix 1 (photo log) photos No. 1 and 2. For GPS location information and additional meta data, please see the photo log. I observed the pit or sump area of the facility (inside secondary containment) where spilled oil initially pooled upon release. At the time of the inspection there was free oil, oil-stained grass, soil, and rocks in the sump area. See photo No. 3. I observed the 2" pipe conduit which allowed the spill to escape the secondary containment. At the time of the inspection, the operator had installed a cap on the line to prevent future releases. It was not determined whether this was a sump area drain line used to remove excess rainwater from the facility or if the line was an abandoned flowline which had been left behind by a previous operator. See photo No. 4. I observed the Point of Entry (POE) into the unnamed tributary of Hominy Creek. At the time of the inspection there was free oil floating on the water in the main channel of the tributary. I also observed oil-stained soil, rocks, and vegetation at and around to POE. See photo No. 5. 2 Box L Operating / Lynn Lease (OKU002209) Inspection Date: 05/28/2024 I observed free oil along the impacted tributary in an area where the operator was working to remove oil from the tributary. See photo No. 6. Continuing downstream, I observed multiple consecutive locations with oil-stained rocks, vegetation, and soil. These same locations included scorched and burned vegetation in and along the impacted tributary, evidence the oil along this section of the impacted tributary had burned prior to the inspection. The operator stated the oil was not burned when they left just ahead of a significant thunder/lightning storm the prior night. When the operator returned the following morning, oil along this section of the tributary had already burned. See photos No. 7, 8, 9 and 10. I observed a temporary containment dam which had been placed by the operator to prevent downstream migration of oil. At this same location there was oil-stained rocks, soil, and vegetation. There was also a significant amount of "sphag sorb" (an industrial, peat moss based industrial oil absorbent) present on the banks and in the main channel of the tributary. See photo No. 11. Continuing downstream from the containment dam, I observed continuing oil impacts along the banks as well as free oil floating on the water. The bed and bank features of the tributary were also captured in photos No. 12, 13, 14, 15, 16, 17 and 18. I observed oil-staining, free oil and a floating, oil absorbent containment boom at the point where spill impacts crossed onto a second landowner. See photo No. 19. I observed an additional floating, absorbent, containment boom as well as contained oil floating on the surface of the impacted tributary. See photo No. 20. I observed the end of spill impacts and the final/lowermost, downstream, floating, oil absorbent, containment boom. At the time of the inspection, the spill was effectively contained by proper placement of the final containment boom. See photo No. 21. While leaving the inspection area, I observed the operator and equipment enroute to install a temporary containment dam with underflow and additional absorbent booms to ensure no further downstream migration of spill impacts. Section III - AREAS OF CONCERN EPA inspector conducted a closing conference with JT Hough (Operator) and Mike Perrier (BIA). Mr. Hough stated he would continue his cleanup efforts including monitoring/maintaining the temporary containment dams and the absorbent/containment booms to ensure continuing, sufficient spill containment. 3 Box L Operating / Lynn Lease (OKU002209) Inspection Date: 05/28/2024 The primary areas of concern included the free oil, oil-stained soil, rocks, and vegetation along the impacted tributary as well as the oil contaminated sphag sorb which had been applied to the waterway as part of the containment and cleanup effort. A final area of concern was the conduit/flowline/drain line which allowed the oil to escape the secondary containment. Section IV - FOLLOW UP Inspector participated in a follow-up investigation conducted by EPA OSC Jennifer Polk on 05/30/2024. Inspector will conduct follow up calls and site visits as necessary to ensure areas of concern are adequately addressed. Section V - LIST OF APPENDICES Appendix 1 - Photo Log - 21 photos taken 5/28/2024. 4 Box L Operating /Lynn Lease (OKU002209) Inspection Date: 05/28/2024 Appendix 1 Photograph Log 21 Photos UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.577750, -96.491602 City: Fairfax Photo No. 1 County/Parish: Osage State: Oklahoma Photo File Name: R0010396 Orientation: W Date of Photo: 5/28/2024 Time of Photo: 9:15AM Latitude: 36.577750 Longitude: -96.491602 Photographer: Matthew Allen Description: This was the Box L Operating, Lynn Lease tank battery facility signage. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.577750, -96.491602 City: Fairfax Photo No. 2 County/Parish: Osage State: Oklahoma Photo File Name: R0010397 Orientation: N Date of Photo: 05/28/2024 Time of Photo: 9:16AM Latitude: 36.577750 Longitude: -96.491602 Photographer: Matthew Allen Description: This was an overview of the Lynn Lease tank battery, looking along the west side of the facility. The oil leak occurred from the tank nearest the photographer in the photo. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.577750, -96.491602 City: Fairfax Photo No. 3 County/Parish: Osage State: Oklahoma Photo File Name: R0010398 Orientation: NW Date of Photo: 05/28/2024 Time of Photo: 9:16AM Latitude: 36.577750 Longitude: -96.491602 Photographer: Matthew Allen Description: This was the "pit" or "sump" area of the facility where the oil pooled before migrating through the secondary containment. Free oil and oil-stained soil/vegetation were present at the time of the inspection and can be seen in the photo. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.577750, -96.491602 City: Fairfax Photo No. 4 County/Parish: Osage State: Oklahoma Photo File Name: R0010399 Orientation: N/A Date of Photo: 05/28/2024 Time of Photo: 9:16AM Latitude: 36.577856 Longitude: -96.491928 Photographer: Matthew Allen Description: This was the "drain line" which transported the spilled oil through the secondary containment. This photo is taken on the west side of the facility, outside of the berm. At the time of the inspection, the line had been capped by the operator. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.577750, -96.491602 City: Fairfax Photo No. 5 County/Parish: Osage State: Oklahoma Photo File Name: R0010400 Orientation: SW Date of Photo: 05/28/2024 Time of Photo: 9:19AM Latitude: 36.577891 Longitude: -96.492053 Photographer: Matthew Allen Description: This was the Point of Entry into the unnamed tributary of Hominy Creek. Loose oil and oilstained soil and vegetation were present at the time of the inspection. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.577750, -96.491602 City: Fairfax Photo No. 6 County/Parish: Osage State: Oklahoma Photo File Name: R0010401 Orientation: N/A Date of Photo: 05/28/2024 Time of Photo: 9:24AM Latitude: 36.577730 Longitude: -96.492128 Photographer: Matthew Allen Description: This was a photo of loose oil along the unnamed tributary. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.577750, -96.491602 City: Fairfax Photo No. 7 County/Parish: Osage State: Oklahoma Photo File Name: R0010402 Orientation: SW Date of Photo: 05/28/2024 Time of Photo: 9:26AM Latitude: 36.577722 Longitude: -96.492623 Photographer: Matthew Allen Description: This was photo of oil-stained rock and soil along the impacted tributary. The oil in this area had burned prior to the inspection. The black and ash covered sticks in the bottom middle of the photo were evidence of the oil burning. The tributary was covered in "sphag sorb" (an industrial oil absorbent) at the time of the inspection. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.577750, -96.491602 City: Fairfax Photo No. 8 County/Parish: Osage State: Oklahoma Photo File Name: R0010403 Orientation: W Date of Photo: 05/28/2024 Time of Photo: 9:30AM Latitude: 36.577346 Longitude: -96.492760 Photographer: Matthew Allen Description: This was a photo showing oil sheen, spahg sorb and burned oil along the impacted tributary. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.577750, -96.491602 City: Fairfax Photo No. 9 County/Parish: Osage State: Oklahoma Photo File Name: R0010404 Orientation: WSW Date of Photo: 05/28/2024 Time of Photo: 9:32AM Latitude: 36.577031 Longitude: -96.492851 Photographer: Matthew Allen Description: This was an area upstream from the first temporary containment berm where a significant amount of oil burned. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.577750, -96.491602 City: Fairfax Photo No. 10 County/Parish: Osage State: Oklahoma Photo File Name: R0010405 Orientation: NE Date of Photo: 05/28/2024 Time of Photo: 9:34AM Latitude: 36.576886 Longitude: -96.493145 Photographer: Matthew Allen Description: This photo showed charred trees approximately 15-20 feet above the impacted tributary. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.577750, -96.491602 City: Fairfax Photo No. 11 County/Parish: Osage State: Oklahoma Photo File Na R0010406 Orientation: SSE Date of Photo: 05/28/2024 Time of Photo: 9:35AM Latitude: 36.576886 Longitude: -96.493145 Photographer: Matthew Allen Description: This was the first temporary containment dam which had been placed by the operator to prevent downstream migration of the spilled oil. Oil-stained soil, rock and vegetation were present along the banks and dam. Significant amounts of sphag sorb were present on the tributary at this location. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.577750, -96.491602 City: Fairfax Photo No. 12 County/Parish: Osage State: Oklahoma Photo File Name: R0010408 Orientation: SSE Date of Photo: 05/28/2024 Time of Photo: 9:39PM Latitude: 36.576174 Longitude: -96.492845 Photographer: Matthew Allen Description: This was a photo showing oil floating on the impacted tributary as well as oil staining along the banks. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.577750, -96.491602 City: Fairfax Photo No. 13 County/Parish: Osage State: Oklahoma Photo File Name: R0010410 Orientation: SSE Date of Photo: 05/28/2024 Time of Photo: 9:44AM Latitude: 36.575155 Longitude: -96.492939 Photographer: Matthew Allen Description: This was a photo showing the bed and bank features of the unnamed tributary. This location was approximately 1300 feet downstream from the POE. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.577750, -96.491602 City: Fairfax Photo No. 14 County/Parish: Osage State: Oklahoma Photo File Name: R0010411 Orientation: S Date of Photo: 05/282024 Time of Photo: 9:45AM Latitude: 36.575155 Longitude: -96.492939 Photographer: Matthew Allen Description: This was a photo of oil floating on the water as well as oil-stained soil and rocks along the impacted tributary. This was at the same location as photo No. 13. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.577750, -96.491602 City: Fairfax Photo No. 15 County/Parish: Osage State: Oklahoma Photo File Name: R0010412 Orientation: NNE Date of Photo: 05/28/2024 Time of Photo: 9:48AM Latitude: 36.574116 Longitude: -96.491901 Photographer: Matthew Allen Description: This was a photo of oil floating on the impacted tributary. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.577750, -96.491602 City: Fairfax Photo No. 16 County/Parish: Osage State: Oklahoma Photo File Name: R0010413 Orientation: NE Date of Photo: 5/28/2024 Time of Photo: 9:50AM Latitude: 36.573437 Longitude: -96.491941 Photographer: Matthew Allen Description: This was a photo showing the bed and bank features of the impacted tributary. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.577750, -96.491602 City: Fairfax Photo No. 17 County/Parish: Osage State: Oklahoma Photo File Name: R0010414 Orientation: ENE Date of Photo: 5/28/2024 Time of Photo: 9:56AM Latitude: 36.571922 Longitude: -96.491897 Photographer: Matthew Allen Description: This was a photo of sheen on the water as well as the bed and bank features of the tributary along the impacted tributary. This was a view upstream from the location. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.577750, -96.491602 City: Fairfax Photo No. 18 County/Parish: Osage State: Oklahoma Photo File Name: R0010416 Orientation: WSW Date of Photo: 5/28/2024 Time of Photo: 9:58AM Latitude: 36.571922 Longitude: -96.491897 Photographer: Matthew Allen Description: This photo showed oil on the water along the impacted tributary. This was a downstream view from the same location as photo No. 17. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.577750, -96.491602 City: Fairfax Photo No. 19 County/Parish: Osage State: Oklahoma Photo File Name: R0010417 Orientation: WSW Date of Photo: 5/28/2024 Time of Photo: 9:59AM Latitude: 36.571713 Longitude: -96.492477 Photographer: Matthew Allen Description: This was a photo of oil on the water at the point where the spill crossed onto a second landowner. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.577750, -96.491602 City: Fairfax Photo No. 20 County/Parish: Osage State: Oklahoma Photo File Name: R0010418 Orientation: NNE Date of Photo: 5/28/2024 Time of Photo: 10:06AM Latitude: 36.570216 Longitude: -96.492258 Photographer: Matthew Allen Description: This was an oil absorbent containment boom installed across the tributary to prevent downstream migration of spill impacts. This photo was taken with an upstream view from the location. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 36.577750, -96.491602 City: Fairfax Photo No. 21 County/Parish: Osage State: Oklahoma Photo File Name: R0010419 Orientation: NE Date of Photo: 5/28/2024 Time of Photo: 10:09AM Latitude: 36.569700 Longitude: -96.493202 Photographer: Matthew Allen Description: This was the lowermost, downstream containment boom with a small amount of oil sheen trapped on the upstream side of the boom. This was the furthest downstream location where spill impacts were observed. At the time of the inspection, the spill was effectively contained.