February 17, 2015 Jon Myhre Enerco Operating Corporation 6237 Tulip Lane Dallas, TX 75230 RE: Fouke # D-3 SWD System Inspection (Miller Co) AFIN: 46-00279 State Permit No.: 0572-WG-SW-2 Dear Mr. Myhre: On February 5, 2015, I performed a Compliance Evaluation Inspection of the above referenced facility in accordance with the provisions of the Federal Clean Water Act, the Arkansas Water and Air Pollution Control Act, and the regulations promulgated thereunder. A copy of the inspection report is enclosed for your records. Please refer to the Summary of Findings section of the attached inspection report and provide a written response for each violation that was noted. This response should be mailed to the attention of the Water Division Inspection Branch at the address at the bottom of this letter or e- mailed to Water-Inspection-Report@adeq.state.ar.us. This response should contain documentation describing the course of action taken to correct each item noted. This corrective action should be completed as soon as possible, and the written response with all necessary documentation (i.e. photos) is due by March 3, 2015. If I can be of any assistance, please contact me at voss@adeq.state.ar.us or (501)-837-2077. Sincerely, Chris Voss District 8 Oil & Gas Field Inspector Water Division cc: Jerry Smith, Field Contact, P.O. Box 127, Fouke, AR 71837 Page 1 of 10
Inspection Report: Fouke # D-3 SWD System, AFIN: 46-00279, Permit #: 0572-WG-SW-2 FACILITY INFORMATION NAME: Fouke # D-3 SWD System LOCATION: CITY: NAME: / TITLE Jon Myhre / RESPONSIBLE OFFICIAL COMPANY: Enerco Operating Corporation MAILING ADDRESS: 6237 Tulip Lane CITY, STATE, ZIP: Dallas TX 75230 PHONE & EXT: / FAX: 214-750 0080 / EMAIL: WATER DIVISION INSPECTION REPORT AFIN: 46-00279 PERMIT #: 0572-WG-SW-2 DATE: 2/5/2015 COUNTY: 46 Miller PDS #: 082396 MEDIA: WS GPS LAT: 33.31408 LONG: 93.82705 LOCATION: General Area FACILITY TYPE: 5 - Oil Gas FACILITY EVALUATION RATING: N INSPECTION INFORMATION INSPECTOR ID#: 26416 S - State DATE(S): ENTRY TIME: EXIT TIME: 2/5/2015 FAYETTEVILLE SHALE RELATED: N INSPECTION TYPE: Compliance Evaluation PERMIT EFFECTIVE DATE: 12/1/2011 PERMIT EXPIRATION DATE: 11/30/2016 FAYETTEVILLE SHALE VIOLATIONS: N INSPECTION PARTICIPANTS NAME/TITLE/PHONE/FAX/EMAIL/ETC.: Jerry Smith CONTACTED DURING INSPECTION: No AREA EVALUATIONS (S=Satisfactory, M=Marginal, U=Unsatisfactory, N=Not Applicable/Evaluated) S PERMIT U NOI N REGULATION 1 N RECORDS U OPERATION & MAINTENANCE U FACILITY SITE REVIEW N INSPECTIONS S SPILLS/REPORTING N STORMWATER N OTHER: SUMMARY OF FINDINGS 1.) The NOI included with this system is outdated and does not contain current information needed for this system. This is a violation of Part II A. 1. C. of the permit. 2.) Sign located on the SWD had the wrong name and did not contain the Department s permit number. This is a violation of Part II A. 3. of the permit. 4.) The firewall berms located at the Weeks, Goldman, and Sturgis N tank batteries were not maintained to contain 1.5 times the volume of the largest vessel. This is a violation of Part II B. 10. A. of the permit. 5.) Multiple leaks from lines, pumps, valves, and well heads were observed during the inspection. This is a violation of Part I A. 6. A. of the permit. GENERAL COMMENTS Fifty-four production wells, multiple tank batteries, and one (1) SWD were listed on the system. Forty-four production wells, seven (7) tank batteries, and one (1) SWD were inspected. Also, two (2) open pits were noted during this inspection. Report forwarded to AOGC El Dorado Office for their review. INSPECTOR S SIGNATURE: Chris Voss DATE: 2/10/2015 SUPERVISOR S SIGNATURE: -Supervisor Name DATE: 2/13/2015 Inspection Report Page 2 of 10
Inspection Report: Fouke # D-3 SWD System, AFIN: 46-00279, Permit #: 0572-WG-SW-2 ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY GENERAL PERMIT 0000-WG-SW INSPECTION FORM Inspection Date: February 5, 2015 Inspector: Chris Voss Compliance Status: IN / OUT Permit 1. Permittee (Operator): Enerco Operating Corporation System Name: Fouke # D-3 SWD System Location: N 33.31408 W 93.82705 County: Miller 2. Name of On-Site Representative: N/A 3. Name of Responsible Official: Jon Myhre Address: 6237 Tulip Lane; Dallas, TX 75230 Telephone: 214-750-0080 4. Is the permit retained on site? Yes No NE COMMENTS ON PERMIT: Regulation 1/A.C.A. 8-4-217 (a) 5. Is runoff or a discharge present, or evidence of runoff or a discharge present? Yes No If yes, describe: N/A 6. Nearest Stream: Beech Creek 7. Have pollutants entered Waters of the State? Yes No COMMENTS ON REGULATION 1/A.C.A. 8-4-217 (a): NOI 8. Is Notice of Intent (NOI) current, including: Yes No NE List of wells from which salt water is received? Yes No NE Method of salt water receipt (truck, rail, pipeline, etc.)? Yes No NE Salt water storage capacity (in barrels)? Yes No NE Maps, diagrams accurate? Yes No NE 9. Are there any additions, modifications, or corrections to the facility since the last inspection? Yes No NE If yes, explain: Wells added and removed from system. 10. Are there any production wells associated with the SWD system that are not listed on the permit? Yes No NE If yes, describe: Multiple wells added and removed from system. 11. Does a new NOI need to be submitted? Yes No COMMENTS ON NOI: The NOI included with this system is outdated and does not contain current information needed for this system. Inspection Report Page 3 of 10
Inspection Report: Fouke # D-3 SWD System, AFIN: 46-00279, Permit #: 0572-WG-SW-2 Operation and Maintenance 12. Are complaints registered against this permitted facility? Yes No NE If yes, give date and description of complaint: N/A 13. Are signs posted with the information required by the general permit? Yes No NE If no, describe: Sign at SWD did not contain information required. 14. Does the firewall berm appear impermeable & able to contain 1.5 times the largest vessel? Yes No NE If no, describe: Berms not maintained at Weeks, Goldman, & Sturgis N tank batteries. 15. Is the firewall free from excessive vegetation? Yes No NE If no, describe: 16. Any leaks or excessive vegetation noted at the transmission lines during the inspection? Yes No NE If yes, describe: 17. Are there any pits containing oil or saltwater at the site? Yes If yes, describe: A few open pits were observed during this inspection. No NE 18. Are the tanks & pumps free from leaks? Yes No NE If no, describe: Multiple leaks & evidence of leaks were observed during this inspection. 19. Production Wells: Production Well Number Location Tank Battery Number NOI list of wells does not match wells inspected. COMMENTS ON OPERATION AND MAINTENANCE: Sign located on the SWD had the wrong name and did not contain the Department s permit number. The firewall berms located at the Weeks, Goldman, and Sturgis N tank batteries were not maintained to contain 1.5 times the volume of the largest vessel. Multiple leaks from lines, pumps, valves, and well heads were observed during the inspection. Inspections 20. Does the facility conduct inspections as required? Yes No NE 21. Is inspection frequency adequate? Yes No NE Frequency: 22. Are inspection records complete and include: Yes No NE Inspector Name and Title? Yes No NE Date of Inspection? Yes No NE Identify which transmission pipes inspected? Yes No NE Inspection Report Page 4 of 10
Inspection Report: Fouke # D-3 SWD System, AFIN: 46-00279, Permit #: 0572-WG-SW-2 COMMENTS ON INSPECTIONS: Spills, Leaks, Seeps 23. Are there any oil or saltwater spills at the site? Yes No 24. Does the facility have adequate response measures for spills? Yes No NE 25. Are spills reported as required by the permit? Yes No NE COMMENTS ON SPILLS: See O & M Section. Stormwater 26. Does facility maintain records of stormwater discharge from the firewall for 6 months? Yes No NE 27. Is operator checking for sheen and chlorides prior to release? Yes No NE 28. Is a representative of the permit present during release? Yes No NE 29. Are additional BMP needed to manage stormwater discharges from containment? Yes No NE COMMENTS ON STORMWATER: Inspector Signature: Signature of Reviewer: Chris Voss Kerri McCabe Date of Report: February 10, 2015 Date of Review: February 13, 2015 Inspection Report Page 5 of 10
Inspection Report: Fouke # D-3 SWD System, AFIN: 46-00279, Permit #: 0572-WG-SW-2 Water Division Photographic Evidence Sheet Location: Fouke # D-3 SWD System Photographer: Chris Voss Date: 2/5/15 Time: 10:38 Witness: Jerry Smith Photo #: 1 Description: Evidence of spills and leaks inside SWD battery. Photographer: Chris Voss Date: 2/5/15 Time: 10:38 Witness: Jerry Smith Photo #: 2 Description: Same as above. Inspection Report Page 6 of 10
Inspection Report: Fouke # D-3 SWD System, AFIN: 46-00279, Permit #: 0572-WG-SW-2 Water Division Photographic Evidence Sheet Location: Fouke # D-3 SWD System Photographer: Chris Voss Date: 2/5/15 Time: 10:38 Witness: Jerry Smith Photo #: 3 Description: Leak from valve inside the SWD battery. Photographer: Chris Voss Date: 2/5/15 Time: 10:40 Witness: Jerry Smith Photo #: 4 Description: Sign wrong and no permit # on the Fouke # D-3 SWD. Inspection Report Page 7 of 10
Inspection Report: Fouke # D-3 SWD System, AFIN: 46-00279, Permit #: 0572-WG-SW-2 Water Division Photographic Evidence Sheet Location: Fouke # D-3 SWD System Photographer: Chris Voss Date: 2/5/15 Time: 10:42 Witness: Jerry Smith Photo #: 5 Description: Berm not maintained on Goldman battery. Photographer: Chris Voss Date: 2/5/15 Time: 10:42 Witness: Jerry Smith Photo #: 6 Description: Evidence of a spill from the Goldman battery. Inspection Report Page 8 of 10
Inspection Report: Fouke # D-3 SWD System, AFIN: 46-00279, Permit #: 0572-WG-SW-2 Water Division Photographic Evidence Sheet Location: Fouke # D-3 SWD System Photographer: Chris Voss Date: 2/5/15 Time: 10:42 Witness: Jerry Smith Photo #: 7 Description: Same as above. Photographer: Chris Voss Date: 2/5/15 Time: 10:57 Witness: Jerry Smith Photo #: 8 Description: Evidence of a leak inside the Hunter Collins B-2 treater battery. Inspection Report Page 9 of 10
Inspection Report: Fouke # D-3 SWD System, AFIN: 46-00279, Permit #: 0572-WG-SW-2 Water Division Photographic Evidence Sheet Location: Fouke # D-3 SWD System Photographer: Chris Voss Date: 2/5/15 Time: 11:02 Witness: Jerry Smith Photo #: 9 Description: Berm on the Weeks battery not maintained. Photographer: Chris Voss Date: 2/5/15 Time: 11:31 Witness: Jerry Smith Photo #: 10 Description: Berm on the Sturgis N battery not maintained. Inspection Report Page 10 of 10
June 9, 2015 Jon Myhre, Contact Enerco Operating Corporation 6237 Tulip Lane Dallas, TX 75230 RE: Response to Inspection (Miller Co) AFIN: 46-00279 State Permit No.: 0572-WG-SW-2 Dear Mr. Myhre: I have reviewed the response pertaining to my February 5, 2015 inspection of the Fouke #D-3 SWD System. The information provided sufficiently addresses the violations referenced in my inspection report. At this time, the Department has no further comment concerning this particular inspection. Acceptance of this response by the Department does not preclude any future enforcement action deemed necessary at this site or any other site. If we need further information concerning this matter, we will contact you. Thank you for your attention to this matter. Should you have any questions, feel free to contact me at (501) 837-2077 or you may e-mail me at voss@adeq.state.ar.us. Sincerely, District 8 Oil & Gas Field Inspector Water Division