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March 9, 2011 James Eubanks James & Mike Eubanks P. O. Box
516 Smackover, AR 71762-0516 RE: AFIN: 70-00600, Permit Tracking
No.: 0584-WG-SW-1 Howard SWDS SWD System Dear Mr. Eubanks: On
February 22, 2011, 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. Firewall berms are low at all tank battery sites. See Photo
Nos. 1, 3, 5, 6 & 7. Any change to the information previously
submitted in an NOI requires submittal of a new NOI prior to the
changes taking effect. This is a violation of Part III.A.1. of the
general permit.
2. Oil waste observed inside the containment area of the Howard
Battery. See Photo No. 2.
Waste may not be placed in a manner where it is likely to cause
pollution of any waters of the state. This is a violation of Ark.
Code Ann. § 8-4-217(a)(2).
3. Tree observed on the firewall berm of the Howard saltwater
battery. See Photo No. 4. The
operator is required to properly operate and maintain all parts
of the system and may not place waste in a manner where it is
likely to cause pollution of any waters of the state. This is a
violation of Part III.B.7. of the general permit and Ark. Code Ann.
§ 8-4-217(a)(2).
4. The Patterson & Leverett Battery & Lane Battery
configurations do not match current tank
battery drawings. See Photo Nos. 5 & 7. Any change to the
information previously submitted in an NOI requires submittal of a
new NOI prior to the changes taking effect. This is a violation of
Part III.A.1. of the general permit.
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No Discharge SWD Report Page 2
James & Mike Eubanks March 9, 2011 Page 2 The above item
requires your immediate attention. Please submit a written response
to these findings to Cindy Garner, Water Division Enforcement
Branch Manager. This response should be mailed to the address
below. 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 21, 2011. If you have questions, or if I can be of
assistance, please contact me at (870) 682-5941 or via e-mail at
[email protected]. Sincerely, Connery Salter, ADEQ Inspector
Water Division, El Dorado cc: file (AFIN: 70-00600, Permit Tracking
No.: 0584-WG-SW-1)
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ADEQ Water Industrial No Discharge AFIN: Permit Tracking
No.:
No Discharge SWD Report Page 3
ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY
GENERAL PERMIT 0000-WG-SW INSPECTION FORM
AFIN: 70-00600
Permit No.: 0584-WG-SW-1 Inspection Date: 2-22-11
Media: Water Inspector: Connery Salter
Compliance Status: IN / O OUT 1. Permittee (Operator): James
& Mike Eubanks System Name: Howard SWDS SWD System Location: N
33.34013 W 92.71358 (T) County: Union 2. Name of On-Site
Representative: N/A 3. Name of Responsible Official: James Eubanks
Address: P. O. Box 516 Smackover, AR 71762-0516 Telephone:
870-818-5111 4. Production Wells:
Production Well Number Location Tank Battery Number Balkenbush
No. 1 Howard Nos. 6 & 7 Kane No. 1 Leverett Nos. 1 & 3
Patterson Nos. 1, 5, 6 & 7
5. Are complaints registered against this permitted facility?
Yes O No If yes, give date and description of complaint: 6. Are
there any additions, modifications, or corrections to the facility
since the last inspection? O Yes No If yes, explain: The Patterson
& Leverett Battery & Lane Battery configurations do not
match current tank battery drawings.
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ADEQ Water Industrial No Discharge AFIN: Permit Tracking
No.:
No Discharge SWD Report Page 4
7. Nearest Stream: Holmes Creek
8. Is runoff or a discharge present, or evidence of runoff or a
discharge present? Yes O No If yes, describe: 9. Are there any oil
or saltwater spills at the site? Yes O No If yes, describe: 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 O No If no, describe: 12. Does the
firewall berm appear impermeable & able to contain 1.5 times
the largest vessel? Yes O No If no, describe: Firewall berms are
low at all tank battery sites. 13. Is the firewall free from
excessive vegetation? Yes O No If no, describe: Tree observed on
the firewall berm of the Howard saltwater battery. 14. If a pipe is
present through the firewall, is it capped to prevent a discharge?
O Yes No If no, explain: 15. Are the tanks & pumps free from
leaks? Yes O No If no, describe: Oil waste observed inside the
containment area of the Howard Battery. 16. Any leaks or excessive
vegetation noted at the transmission lines during the inspection?
Yes No If yes, describe:
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ADEQ Water Industrial No Discharge AFIN: Permit Tracking
No.:
No Discharge SWD Report Page 5
17. Are there any production wells associated with the SWD
system that are not listed on the
permit? Yes O No If yes, describe:
SUMMARY OF FINDINGS/COMMENTS Firewall berms are low at all tank
battery sites. Oil waste observed inside the containment area of
the Howard Battery. Tree observed on the firewall berm of the
Howard saltwater battery. The Patterson & Leverett Battery
& Kane Battery configuration does not match current tank
battery drawings. Inspector Signature:
Date of Report:
2-24-11
Signature of Reviewer:
Date of Review:
03/07/11
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ADEQ Water Industrial No Discharge AFIN: Permit Tracking
No.:
No Discharge SWD Report Page 6
Water Division No Discharge Industrial Photographic Evidence
Sheet Location: Howard SWDS SWD System Photographer: Connery Salter
Witness: None Photo No. 1 Of 7 Date: 2-22-11 Time: 1158
Description: Firewall berm is low at the Howard Battery.
Photographer: Connery Salter Witness: None Photo No. 2 Of 7
Date: 2-22-11 Time: 1200 Description: Oil waste observed inside the
containment area of the Howard Battery.
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Water Division No Discharge Industrial Photographic Evidence
Sheet Location: Howard SWDS SWD System Photographer: Connery Salter
Witness: None Photo No. 3 Of 7 Date: 2-22-11 Time: 1158
Description: Firewall berm is low at the Howard saltwater
battery.
Photographer: Connery Salter Witness: None Photo No. 4 Of 7
Date: 2-22-11 Time: 1159 Description: Tree observed on the firewall
berm of the Howard saltwater battery.
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ADEQ Water Industrial No Discharge AFIN: Permit Tracking
No.:
No Discharge SWD Report Page 8
Water Division No Discharge Industrial Photographic Evidence
Sheet Location: Howard SWDS SWD System Photographer: Connery Salter
Witness: None Photo No. 5 Of 7 Date: 2-22-11 Time: 1210
Description: The Kane Battery configuration does not match current
tank battery drawings & firewall is low.
Photographer: Connery Salter Witness: None Photo No. 6 Of 7
Date: 2-22-11 Time: 1226 Description: Firewall berm is low at the
Patterson saltwater battery.
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ADEQ Water Industrial No Discharge AFIN: Permit Tracking
No.:
No Discharge SWD Report Page 9
Water Division No Discharge Industrial Photographic Evidence
Sheet Location: Howard SWDS SWD System Photographer: Connery Salter
Witness: None Photo No. 7 Of 7 Firewall is low. Date: 2-22-11 Time:
1228 Description: The Patterson & Leverett Battery
configuration does not match current tank battery drawings.
Photographer: Connery Salter Witness: None Photo No. Of Date:
Time: Description:
N/A
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April 6, 2011 James Eubanks James and Mike Eubanks P.O. Box 516
Smackover, AR 71762 RE: Permit Tracking No. 0584-WG-SW-1 Howard
SWDS SWD System Dear Mr. Eubanks: The Department has received your
response to the February 22, 2011 inspection of your facility by
our Oil and Gas Field Inspector. Your letter appears to adequately
address the discrepancies identified during the visit. The
Department assumes 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 501-683-3469 or
you may e-mail me at [email protected]. Sincerely,
Jeffrey Sohl Enforcement Analyst Water Division Enforcement
Branch
Sincerely,Connery Salter, ADEQ InspectorWater Division, El
Dorado