Document yb5g0B1JNEM5DKV7DOnY2p5Zd

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: El Dorado Operating, LLC Gregory Lease Tank Battery In Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.250258, -92.537361. El Dorado, AR, 71730 920 N Jefferson El Dorado, AR 71730 Union County 870-725-3042 (Jerry Langley) Jim Phillips Representative jimphillips@arprodserv.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: N/A ARU002281 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: 2025.04.03 14:38:49 -05'00' Date JEANNE ECKHART Date: 2025.04.03 15:01:40 -05'00' Digitally signed by JEANNE ECKHART Jeanne Eckhart Date 6ENFORM-019-R8.2 (02/12/2020) 1 Section I - INTRODUCTION El Dorado Operating, LLC / Gregory Lease Tank Battery (ARU002281 / CWA) Inspection Date 01/30/2025 PURPOSE OF THE INSPECTION EPA Region 6 inspectors Kerri McCabe (lead) and Michael Blaha arrived at the El Dorado Operating, LLC / Gregory Lease Tank Battery ("facility"), located from Highway 63 E, then Armer Rd, left onto an oil lease road at 33.250258, -92.537361; at 1100 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 El Dorado Operating, LLC / Gregory Lease Tank Battery, which contained five (5) storage/separation tanks for crude oil and saltwater, two (2) saltwater disposal (SWD) injection wells, and an additional tank battery that appeared to be out of service. Map 1. Aerial imagery (Google Earth dated 03/11/2024) of the El Dorado Operating, LLC / Gregory Lease Tank Battery. 2 Section II - OBSERVATIONS El Dorado Operating, LLC / Gregory Lease Tank Battery (ARU002281 / CWA) Inspection Date 01/30/2025 I observed the El Dorado Operating, LLC / Gregory Lease Tank Battery facility and associated signage, secondary containment, storage tanks, and treaters/separators; see Appendix 1 (Photographs Log), see Photos No. 1 and No. 2. For additional GPS location and photo metadata, see Appendix 1. I observed the inside of the secondary containment with residual crude oil, salt crystal formation, and dirt work for drainage and berm maintenance, see Photos No. 3 through No. 6. I observed two transfer lines without catchment buckets outside secondary containment, see Photos No. 7 and No. 8. I observed the sump area and drainpipe for the secondary containment, see Photos No. 9 and No. 10. I observed an additional tank battery located near the facility that appeared to be out of service, see Photo No. 11. I observed two (2) SWD injection wells both with workover pits that contained residual crude oil and saltwater, see Photos No. 12 through No. 16. Section III - AREAS OF CONCERN No closing conference was held due to no personnel with El Dorado Operating, LLC being present during the inspection. Areas of concern at the time of the inspection include the following: Residual crude oil and salt crystal formation inside secondary containment (Photos No. 3 through No. 6 and No. 9), Transfer lines without catchment buckets outside secondary containment (Photos No. 7 and No. 8), An additional tank battery that appeared to be out of service (Photo No. 11), and Two (2) workover pits that contained residual crude oil and saltwater (Photos No. 13, No. 14, and No. 16). Section IV - FOLLOW UP Inspector will conduct follow-up phone calls and emails 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 - 16 photos taken 01/30/2025. 3 El Dorado Operating, LLC / Gregory Lease Tank Battery (ARU002281 / CWA) Inspection Date 01/30/2025 Appendix 1 Photograph Log 16 Photos UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.250258, 92.537361. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0586 Orientation: 272 W Date of Photo: 01/30/2025 Time of Photo: 1122 Latitude: 33.250300 Longitude: -92.537517 Photographer: Kerri McCabe Description: Looking W, this photo shows the signage at the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.250258, 92.537361. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0587 Orientation: 176 S Date of Photo: 01/30/2025 Time of Photo: 1123 Latitude: 33.250400 Longitude: -92.537400 Photographer: Kerri McCabe Description: Looking S, this photo shows an overview of the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.250258, 92.537361. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0588 Orientation: 276 W Date of Photo: 01/30/2025 Time of Photo: 1123 Latitude: 33.250350 Longitude: -92.537483 Photographer: Kerri McCabe Description: Looking W, this photo shows loose oil inside the secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.250258, 92.537361. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0589 Orientation: 138 SE Date of Photo: 01/30/2025 Time of Photo: 1124 Latitude: 33.250350 Longitude: -92.537583 Photographer: Kerri McCabe Description: Looking SE, this photo shows an overview of the storage tanks and treaters/separators inside secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.250258, 92.537361. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0591 Orientation: 100 E Date of Photo: 01/30/2025 Time of Photo: 1124 Latitude: 33.250250 Longitude: -92.537683 Photographer: Kerri McCabe Description: Looking E, this photo shows some dirt work for drainage and berms inside secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.250258, 92.537361. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0593 Orientation: 21 NNE Date of Photo: 01/30/2025 Time of Photo: 1125 Latitude: 33.250100 Longitude: -92.537450 Photographer: Kerri McCabe Description: Looking NNE, this photo shows residual crude oil and salt crystal formation inside secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.250258, 92.537361. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0595 Orientation: 312 NW Date of Photo: 01/30/2025 Time of Photo: 1125 Latitude: 33.250183 Longitude: -92.537317 Photographer: Kerri McCabe Description: Looking NW, this photo shows a transfer line without a catchment bucket. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.250258, 92.537361. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0596 Orientation: 335 NNW Date of Photo: 01/30/2025 Time of Photo: 1125 Latitude: 33.250283 Longitude: -92.537400 Photographer: Kerri McCabe Description: Looking NNW, this photo shows a transfer line without a catchment bucket. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 Location: Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.250258, 92.537361. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0597 Orientation: 307 NW Date of Photo: 01/30/2025 Time of Photo: 1127 Latitude: 33.250167 Longitude: -92.537417 Photographer: Kerri McCabe Description: Looking NW, this photo shows sump area of the secondary containment with loose crude oil and salt crystal formation. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 10 Location: Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.250258, 92.537361. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0598 Orientation: 351 N Date of Photo: 01/30/2025 Time of Photo: 1127 Latitude: 33.250167 Longitude: -92.537403 Photographer: Kerri McCabe Description: Looking N, this photo shows the drainpipe for the secondary containment. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 11 Location: Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.250258, 92.537361. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0599 Orientation: 147 SSE Date of Photo: 01/30/2025 Time of Photo: 1127 Latitude: 33.250150 Longitude: -92.537267 Photographer: Kerri McCabe Description: Looking SSE, this photo shows an additional tank battery adjacent to the Gregory Lease Tank Battery that appeared to be out of service. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 12 Location: Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.250258, 92.537361. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0582 Orientation: 172 S Date of Photo: 01/30/2025 Time of Photo: 1120 Latitude: 33.251200 Longitude: -92.536833 Photographer: Kerri McCabe Description: Looking S, this photo shows a saltwater disposal (SWD) injection well associated with the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 13 Location: Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.250258, 92.537361. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0583 Orientation: 73 ENE Date of Photo: 01/30/2025 Time of Photo: 1120 Latitude: 33.251167 Longitude: -92.536817 Photographer: Kerri McCabe Description: Looking ENE, this photo shows a workover pit with residual crude oil and saltwater next to the SWD well in Photo No. 12. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 14 Location: Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.250258, 92.537361. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0584 Orientation: 52 NE Date of Photo: 01/30/2025 Time of Photo: 1120 Latitude: 33.251167 Longitude: -92.536792 Photographer: Kerri McCabe Description: Looking NE, this photo shows a closeup of the workover pit from Photo No. 13. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 15 Location: Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.250258, 92.537361. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0600 Orientation: 43 NE Date of Photo: 01/30/2025 Time of Photo: 1128 Latitude: 33.250217 Longitude: -92.536933 Photographer: Kerri McCabe Description: Looking NE, this photo shows another SWD injection well associated with the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 16 Location: Old Union from Highway 63 N, then Armer Rd, and left onto an oil lease road at 33.250258, 92.537361. City: El Dorado County/Parish: Union State: Arkansas Photo File Name: 100-0601 Orientation: 60 ENE Date of Photo: 01/30/2025 Time of Photo: 1128 Latitude: 33.250217 Longitude: -92.536873 Photographer: Kerri McCabe Description: Looking ENE, this photo shows a workover pit with residual crude oil and saltwater next to the SWD in Photo No. 15.