March 2, 2012 Mr. John R. Reynolds Dan Reynolds Company P. O. Box 457 Camden, AR 71701 RE: AFIN: 52-00598 Permit Tracking No.: 0487-WG-SW-1 Dear Mr. Reynolds: On, February 28, 2012, Chris Voss, ADEQ Inspector, and I performed a routine compliance inspection of the referenced facility in accordance with the provisions of the Arkansas Water and Air Pollution Control Act and the regulations promulgated thereunder. This inspection revealed the following violations: 1. Free standing oil was observed around Leo Berg Y # 3 SWD well head and at Dan Reynolds # 3 production well. This is a violation of Part I A. 6. of the permit. 2. The system sign at Leo Berg Y # 3 tank battery had the wrong permit number listed. This is a violation of Part II A. 3. B. of the permit. 3. All three tank batteries had low firewall berms. The NOI stated that all berms were to be 3 deep. The firewall berm on the Leo Berg Y # 3 battery had erosion noted on it. This is a violation of Part II A. 4. of the permit. 4. The Leo Berg Y # 3 battery had excessive vegetation (i.e bushes) growing on the firewall berm. This is a violation of Part II A. 5. of the permit. 5. Excessive vegetation was noted on a transmission line into/out of the Leo Berg Y # 3 battery. The permit requires all transmission lines to free of excessive vegetation to allow for inspection. This is a violation of Part II A. 7. of the permit. 6. An overflow pipe was noted from one of the SWD tanks to a pit behind the tank battery. This overflow pipe to the pit must be removed. This is violation of Part I.A6.B of the permit.
Page 2 The above items require your immediate attention. Please submit a written response to these findings to Water Division Enforcement Branch. This response should be mailed to the address below, or e-mailed to Water-Enforcement-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 documentations (i.e. photos) is due by March 13, 2012. Sincerely, John W. Lamb District 8 Field Inspector Water Division cc: Water Division Permits Branch Water Division Enforcement Branch No Discharge SWD Report Page 2
ADEQ Water SWD No Discharge AFIN: 52-00598 Permit Tracking No.: 0487-WG-SW-1 ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY GENERAL PERMIT 0000-WG-SW INSPECTION FORM AFIN: 52-00598 Permit No.: 0487-WG-SW-1 Inspection Date: 2-28-12 Media: Water Inspector: John Lamb Compliance Status: IN / OUT 1. Permittee (Operator): Dan Reynolds Co. System Name: Leo Berg No. Y-3 SWD Location: N 33.39154 W 092.65131 County: Ouachita 2. Name of On-Site Representative: N/A 3. Name of Responsible Official: John R. Reynolds Address: P. O. Box 457, 313 Reynolds Drive SW, Camden, AR 71701 Telephone: 214-692-1567 4. Production Wells: Production Well Number Location Tank Battery Number Arnold No. 1 Leo Berg Y No. 1 Reynolds & Berg No. 1 Reynolds & Berg No. 3 Reynolds & Berg No. 4 5. Are complaints registered against this permitted facility? Yes No If yes, give date and description of complaint: 6. Are there any additions, modifications, or corrections to the facility since the last inspection? Yes No If yes, explain: No Discharge SWD Report Page 3
ADEQ Water SWD No Discharge AFIN: 52-00598 Permit Tracking No.: 0487-WG-SW-1 7. Nearest Stream: Ouachita River 8. Is runoff or a discharge present, or evidence of runoff or a discharge present? Yes No If yes, describe: 9. Are there any oil or saltwater spills at the site? Yes No If yes, describe: Free standing oil around SWD well head, and near Dan Reynolds # 3. 10. Are there any pits containing oil or saltwater at the site? Yes No If yes, describe: 11. Is a sign posted with the information required by the general permit? Yes No If no, describe: System sign on the Leo Berg Y battery had wrong permit number. 12. Does the firewall berm appear impermeable & able to contain 1.5 times the largest vessel? Yes No If no, describe: All 3 batteries have low firewall berms and some erosion on Leo Berg. 13. Is the firewall free from excessive vegetation? Yes No If no, describe: Firewall berm on Leo Berg Y battery has large bushes growing on it. 14. If a pipe is present through the firewall, is it capped to prevent a discharge? Yes No If no, explain: 15. Are the tanks & pumps free from leaks? If no, describe: Yes No 16. Any leaks or excessive vegetation noted at the transmission lines during the inspection? Yes No If yes, describe: Heavy vegetation on area around line from Leo Berg Y battery. No Discharge SWD Report Page 4
ADEQ Water SWD No Discharge AFIN: 52-00598 Permit Tracking No.: 0487-WG-SW-1 17. Are there any production wells associated with the SWD system that are not listed on the permit? Yes No If yes, describe: SUMMARY OF FINDINGS/COMMENTS 9. Free standing oil around Leo Berg Y # 3 SWD well head and at Dan Reynolds # 3 well. 11. System sign at Leo Berg Y # 3 had wrong permit number. 12. All three tank batteries have low firewall berms which are listed at 3ft.on the NOI. The battery at Leo Berg Y # 3 had some erosion on the berm. 13. The firewall berm at the Leo Berg Y # 3 had bushes growing from the berm. 16. Heavy vegetation on area around disposal line from Leo Berg Y # 3 battery to SWD well. A large pit was noted behind the SWD Battery. This pit had a large overflow pipe in it from one of the SWD tanks. This pit is not permitted on the NOI. The water in the pit was not salt water. PDS #064197 Inspector Signature: Date of Report: 01 March 2012 Signature of Reviewer: / Eric Fleming Date of Review: 3-2-12 No Discharge SWD Report Page 5
ADEQ Water SWD No Discharge AFIN: 52-00598 Permit Tracking No.: 0487-WG-SW-1 Water Division No Discharge Industrial Photographic Evidence Sheet Location: Leo Berg Y No. 3 SWD Photo No. 1 Of 16 Date: 02/28/2012 Time: 09:36 Description: Oil at the SWD well head Photo No. 2 Of 16 Date: 02/28/2012 Time: 09:36 Description: As above No Discharge SWD Report Page 6
ADEQ Water SWD No Discharge AFIN: 52-00598 Permit Tracking No.: 0487-WG-SW-1 Water Division No Discharge Industrial Photographic Evidence Sheet Location: Leo Berg Y No. 3 SWD Photo No. 3 Of 16 Date: 02/28/2012 Time: 09:37 Description: System sign, not legible Photo No. 4 Of 16 Date: 02/28/2012 Time: 09:46 Description: Pit behind main SWD tank battery, fresh water, overflow pipe connected to this pit. No Discharge SWD Report Page 7
ADEQ Water SWD No Discharge AFIN: 52-00598 Permit Tracking No.: 0487-WG-SW-1 Water Division No Discharge Industrial Photographic Evidence Sheet Location: Leo Berg Y No. 3 SWD Photo No. 5 Of 16 Date: 02/28/2012 Time: 09:47 Description: Overflow pipe from main SWD tank battery to pit Photo No. 6 Of 16 Date: 02/28/2012 Time: 09:47 Description: As above No Discharge SWD Report Page 8
ADEQ Water SWD No Discharge AFIN: 52-00598 Permit Tracking No.: 0487-WG-SW-1 Water Division No Discharge Industrial Photographic Evidence Sheet Location: Leo Berg Y No. 3 SWD Photo No. 7 Of 16 Date: 02/28/2012 Time: 09:47 Description: Overflow pipe from Salt water tank Photo No. 8 Of 16 Date: 02/28/2012 Time: 09:50 Description: Firewall low at Leo Berg Y 3 Battery, NOI states 3 feet, (note 3 foot yard stick above firewall No Discharge SWD Report Page 9
ADEQ Water SWD No Discharge AFIN: 52-00598 Permit Tracking No.: 0487-WG-SW-1 Water Division No Discharge Industrial Photographic Evidence Sheet Location: Leo Berg Y No. 3 SWD Photo No. 9 Of 16 Date: 02/28/2012 Time: 09:50 Description: Erosion on Leo Berg Y 3 tank batter firewall Photo No. 10 Of 16 Date: 02/28/2012 Time: 09:54 Description: Excessive vegetation on transmission lines into/out of tank Leo Berg Y 3 tank battery No Discharge SWD Report Page 10
ADEQ Water SWD No Discharge AFIN: 52-00598 Permit Tracking No.: 0487-WG-SW-1 Water Division No Discharge Industrial Photographic Evidence Sheet Location: Leo Berg Y No. 3 SWD Photo No. 11 Of 16 Date: 02/28/2012 Time: 09:59 Description: Incorrect permit number at Leo Berg Y No 3 tank battery Photo No. 12 Of 16 Date: 02/28/2012 Time: 09:59 Description: Excessive vegetation (bushes) on the firewall at Leo Berg Y 3 tank battery No Discharge SWD Report Page 11
ADEQ Water SWD No Discharge AFIN: 52-00598 Permit Tracking No.: 0487-WG-SW-1 Water Division No Discharge Industrial Photographic Evidence Sheet Location: Leo Berg Y No. 3 SWD Photo No. 13 Of 16 Date: 02/28/2012 Time: 10:17 Description: Arnold Tank Battery depth, NOI states 3 deep, tank battery less than 1 Photo No. 14 Of 16 Date: 02/28/2012 Time: 10:32 Description: Reynolds & Berg Tank Battery; NOI states depth 3, less than 12 No Discharge SWD Report Page 12
ADEQ Water SWD No Discharge AFIN: 52-00598 Permit Tracking No.: 0487-WG-SW-1 Water Division No Discharge Industrial Photographic Evidence Sheet Location: Leo Berg Y No. 3 SWD Photo No. 15 Of 16 Date: 02/28/2012 Time: 10:40 Description: Free oil noted at Reynolds & Berg No. 3 Photo No. 16 Of 16 Date: 02/28/2012 Time: 10:40 Description: As above No Discharge SWD Report Page 13
From: To: Subject: Date: Sawyer, Sam Allen-Daniel, Leslie FW: AFIN: 52-00598; Permit Tracking No.:0487-WG-SW-1 Tuesday, March 13, 2012 8:40:24 AM From: John Reynolds [mailto:drco@att.net] Sent: Monday, March 12, 2012 3:33 PM To: Water-Enforcement-Report Subject: AFIN: 52-00598; Permit Tracking No.:0487-WG-SW-1 This e-mail is in response to your letter dated 3/2/12 from John W. Lamb regarding the above referenced facility. As set out in Item #1, the free standing oil has now been cleaned up. A new sign with the correct permit number has now been placed at the tank battery as instructed by Item #2. The overflow pipe has been removed and capped as listed in Item #6. Pertaining to Items #3, #4 and #5, we have hired Ramsey Contractors of Smackover, Arkansas, to build up all firewalls to 3' and above, and to remove all excessive vegetation. As soon as all items have been completed, I will send you pictures showing compliance with these violations. John R. Reynolds, Sr.
From: To: Subject: Date: Attachments: Sawyer, Sam Allen-Daniel, Leslie FW: AFIN:52-00598 Friday, March 16, 2012 8:14:56 AM Arnold Tank Battery.jpg Arnold Tank Battery2.jpg Leo Berg SWD.jpg Leo Berg SWD2.jpg Leo Berg SWD3.jpg Leo Berg SWD4.jpg Leo Berg SWD5.jpg Reynolds & Berg Tank.jpg From: John Reynolds [mailto:drco@att.net] Sent: Thursday, March 15, 2012 7:26 PM To: Water-Enforcement-Report Cc: Dan Reynolds Company Subject: Fw: AFIN:52-00598 March 13, 2011 John W. Lamb District 8 Field Inspector Water Division RE: AFIN: 52-00598 WG-SW-1 Permit Tracking No.: 0487- Dear Mr. Lamb: In response to your letter of March 2, 2012, concerning the Dan Reynolds Company, Leo Berg SWD system and tank batteries connect. I hope you received my response on 3/11/2012 notifying you that I had complete item number 1, 2, and 6 and would finish the rest as soon as possible. This letter is to notify you that all ADEQ requirements have been completed. Below are some comments: 1. Pictures number 1 through 5 are of the Leo Berg # 3 SWD Tank Battery. In order for me to number these pictures with Leo Berg name I had to use the number after the name so don't confuse this as well numbers. I hope this is not confusing if so contact me. A.) There is a new sign placed at the Leo Berg #3 well that has the correct well name, permit number, location description and county. Your photo # 3. B.) Walls are built up to a minimal of 3' and weeds have been cut down C.) Over flow line at back of Leo Berg Tank Battery connect to pit has been cut and capped. Your photo #4, 5, & 6. 2. Pictures numbers 6 and 7 are of the Arnold Tank Battery which water goes to the Leo
Berg SWD. 3. Pictures number 8 are of the Reynolds and Berg Tank Battery and this water also goes to the Leo Berg SWD. A.) Oil at Reynolds and Berg #3 well has been cleaned up. If there are any other problems at your inspection please notify me and I will comply immediately. Sincerely, John R. Reynolds Sr.
March 16, 2012 John Reynolds Dan Reynolds Company P.O. Box 457 Camden, AR 71701 RE: AFIN: 52-00598 Permit No.: 0487-WG-SW-1 Dear Mr. Reynolds: The Department has received your response to the February 28, 2012 inspection of your facility by our District Field Inspector, John Lamb. Your letter appears to adequately address the discrepancies identified during the visit. The Department expects the corrective actions taken will be maintained to ensure consistent compliance with the requirements of the permit. Acceptance of this response by the Department does not preclude any future enforcement action deemed necessary at this site or any other site. The Department will keep the inspection and response on file. If future violations occur that require enforcement action, the Department will consider the inspection and response as required by the Pollution Control and Ecology Commission Regulation No. 7, Civil Penalties. This regulation requires the Department to consider the past history of your site and how expeditiously the violations were addressed in determining any civil penalty that may be necessary for any future violations. 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 501-682-0667 or you may e-mail me at bolenbaughm@adeq.state.ar.us. Sincerely, Michelle Bolenbaugh Enforcement Analyst Water Division Enforcement Branch