Document xJY7kXwdmLNnQ0deNoxNn1yg

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 4/3/24 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: Rebel Producing, LLC Exxon Lease Tank Battery From Highway 82 East, thence New London Rd, off Winchester Rd at 33.180500, -92.314600. Strong, AR 71765 366 Burnside Farm Road Spearsville, LA 71277 Union County 870-312-2520 David M. Burnside Person Responsible for Operation davidmburnside55@gmail.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: N/A ARU002245 N/A 211111 1311 Personnel participating in inspection: Kerri McCabe (lead) EPA / Region 6 ECDW Inspector / Enforcement Officer EPA Lead Inspector Signature/Date Supervisor Signature/Date KERRI MCCABE Kerri McCabe Digitally signed by KERRI MCCABE Date: 2024.05.06 06:50:25 -05'00' Date JEANNE ECKHART Date: 2024.05.06 16:28:25 -05'00' Digitally signed by JEANNE ECKHART Jeanne Eckhart Date 6ENFORM-019-R8.2 (02/12/2020) 1 Section I - INTRODUCTION Rebel Producing, LLC / Exxon Lease Tank Battery (ARU002245 / CWA) Inspection Date 04/03/2024 PURPOSE OF THE INSPECTION EPA Region 6 Inspector Kerri McCabe (lead) arrived at the Rebel Producing, LLC / Exxon Lease Tank Battery, located from Highway 82 East, thence New London Rd, off Winchester Rd at 33.180500, 92.314600; at 1112 on 4/3/24 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 Rebel Producing, LLC / Exxon Lease Tank Battery, which contains two (2) oil-water separators, five (5) storage tanks, two (2) saltwater disposal (SWD) wells, and one (1) crude oil production well. Section II - OBSERVATIONS I observed the facility sign, secondary containment, oil-water separators, pipes and valves, and storage tanks located at the facility; see Appendix 1 (Photograph Log), Photo No. 1 through No. 3. For additional GPS location and photo metadata, see Appendix 1. I observed a transfer pipe over secondary containment without a catch bucket and loose oil on the ground, see Photo No. 4. I observed an active leak of crude oil and loose oil inside secondary containment, see Photo No. 5 through No. 7. I observed woody vegetation growing in the firewall berm (secondary containment), see Photo No. 8. I observed an active leak of saltwater from one of the storage tanks inside secondary containment, see Photo No. 9. I observed the drainpipe for secondary containment with an open valve and no cap on the pipe; salt crystals were observed on the ground around the drainpipe; see Photo No. 10 and No. 11. Section III - AREAS OF CONCERN No closing conference was held due to no personnel with Rebel Producing, LLC being present during the inspection. Areas of concern at the time of the inspection include the transfer pipe with no catch bucket and loose oil on the ground, an active leak of crude oil from piping inside secondary containment, vegetation growing in the firewall berm, an active leak of saltwater from a storage tank inside secondary 2 Rebel Producing, LLC / Exxon Lease Tank Battery (ARU002245 / CWA) Inspection Date 04/03/2024 containment, and the drainpipe for secondary containment with an open valve and no cap with salt crystals noted on the ground around the drainpipe. 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 - 11 photos taken 4/3/24. 3 Rebel Producing, LLC / Exxon Lease Tank Battery (ARU002245 / CWA) Inspection Date 04/03/2024 Appendix 1 Photograph Log 11 Photos UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: Rebel Producing, LLC - Exxon Lease Tank Battery off Winchester Rd at 33.180500, -92.314600. City: Strong County/Parish: Union State: Arkansas Photo File Name: P4020075 Orientation: ESE Date of Photo: 04/03/2024 Time of Photo: 1142 Latitude: 33.180335 Longitude: -92.314478 Photographer: Kerri McCabe Description: Looking ESE, this photo showed the signage at the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: Rebel Producing, LLC - Exxon Lease Tank Battery off Winchester Rd at 33.180500, -92.314600. City: Strong County/Parish: Union State: Arkansas Photo File Name: P4020076 Orientation: SE Date of Photo: 04/03/2024 Time of Photo: 1143 Latitude: 33.180335 Longitude: -92.314478 Photographer: Kerri McCabe Description: Looking SE, this photo showed additional signage at the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: Rebel Producing, LLC - Exxon Lease Tank Battery off Winchester Rd at 33.180500, -92.314600. City: Strong County/Parish: Union State: Arkansas Photo File Name: P4020077 Orientation: ESE Date of Photo: 04/03/2024 Time of Photo: 1143 Latitude: 33.180180 Longitude: -92.314415 Photographer: Kerri McCabe Description: Looking ESE, this photo showed an overview of the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: Rebel Producing, LLC - Exxon Lease Tank Battery off Winchester Rd at 33.180500, -92.314600. City: Strong County/Parish: Union State: Arkansas Photo File Name: P4020078 Orientation: ENE Date of Photo: 04/03/2024 Time of Photo: 1144 Latitude: 33.180266 Longitude: -92.314481 Photographer: Kerri McCabe Description: Looking ENE, this photo showed a transfer pipe over secondary containment with no catch bucket and loose oil on the ground. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: Rebel Producing, LLC - Exxon Lease Tank Battery off Winchester Rd at 33.180500, -92.314600. City: Strong County/Parish: Union State: Arkansas Photo File Name: P4020079 Orientation: SE Date of Photo: 04/03/2024 Time of Photo: 1144 Latitude: 33.180339 Longitude: -92.314563 Photographer: Kerri McCabe Description: Looking SE, this photo showed loose oil around conduits for the storage tanks inside secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: Rebel Producing, LLC - Exxon Lease Tank Battery off Winchester Rd at 33.180500, -92.314600. City: Strong County/Parish: Union State: Arkansas Photo File Name: P4020083 Orientation: NW Date of Photo: 04/03/2024 Time of Photo: 1147 Latitude: 33.180339 Longitude: -92.314563 Photographer: Kerri McCabe Description: Looking NW, this photo showed an additional view of the loose oil around conduits for the storage tanks from Photo No. 5. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: Rebel Producing, LLC - Exxon Lease Tank Battery off Winchester Rd at 33.180500, -92.314600. City: Strong County/Parish: Union State: Arkansas Photo File Name: P4020084 Orientation: SSW Date of Photo: 04/03/2024 Time of Photo: 1147 Latitude: 33.180339 Longitude: -92.314563 Photographer: Kerri McCabe Description: Looking SSW, this photo showed a closeup of the loose oil around conduits for the storage tanks from Photo No. 5. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: Rebel Producing, LLC - Exxon Lease Tank Battery off Winchester Rd at 33.180500, -92.314600. City: Strong County/Parish: Union State: Arkansas Photo File Name: P4020080 Orientation: E Date of Photo: 04/03/2024 Time of Photo: 1144 Latitude: 33.180464 Longitude: -92.314512 Photographer: Kerri McCabe Description: Looking E, this photo showed woody vegetation growing in the firewall (secondary containment). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 Location: Rebel Producing, LLC - Exxon Lease Tank Battery off Winchester Rd at 33.180500, -92.314600. City: Strong County/Parish: Union State: Arkansas Photo File Name: P4020081 Orientation: N Date of Photo: 04/03/2024 Time of Photo: 1146 Latitude: 33.180394 Longitude: -92.314598 Photographer: Kerri McCabe Description: Looking N, this photo showed an active leak from one of the storage tanks inside secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 10 Location: Rebel Producing, LLC - Exxon Lease Tank Battery off Winchester Rd at 33.180500, -92.314600. City: Strong County/Parish: Union State: Arkansas Photo File Name: P4020085 Orientation: ENE Date of Photo: 04/03/2024 Time of Photo: 1149 Latitude: 33.180135 Longitude: -92.314650 Photographer: Kerri McCabe Description: Looking ENE, this photo showed the drainpipe for secondary containment with an open valve and no cap on the pipe. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 11 Location: Rebel Producing, LLC - Exxon Lease Tank Battery off Winchester Rd at 33.180500, -92.314600. City: Strong County/Parish: Union State: Arkansas Photo File Name: P4020087 Orientation: SW Date of Photo: 04/03/2024 Time of Photo: 1149 Latitude: 33.180135 Longitude: -92.314650 Photographer: Kerri McCabe Description: Looking SW, this photo showed salt crystals in the sand in the area that the drainpipe discharges.