re: ml sumners #'s c-11 & c-12 swd inspection (union co ......inspection report: ml sumners...

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May 19, 2016 David Burnside Rebel Producing 366 Burnside Farm Rd. Spearsville, LA 71277 RE: ML Sumners #'s C-11 & C-12 SWD Inspection (Union Co) AFIN: 70-01201 State Permit No.: 0691-WG-SW-4 Dear Mr. Burnside: On May 3, 2016, I performed a Compliance 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 [email protected]. 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 June 2, 2016. If I can be of any assistance, please contact me at [email protected] or (501) 837-2077. Sincerely,

Chris Voss District 8 Oil & Gas Field Inspector Water Division

Inspection Report: ML Sumners #'s C-11 & C-12 SWD, AFIN: 70-01201, Permit #: 0691-WG-SW-4

Inspection Report of 10

WATER DIVISION INSPECTION REPORT AFIN: 70-01201 PERMIT #: 0691-WG-SW-4 DATE: 5/3/2016

COUNTY: 70 Union PDS #: 090820 MEDIA: WS

GPS LAT: 33.15256 LONG: 92.50496 LOCATION: General Area

FACILITY INFORMATION INSPECTION INFORMATION NAME:

ML Sumners #'s C-11 & C-12 SWD LOCATION:

CITY:

FACILITY TYPE:

5 - Oil Gas

INSPECTOR ID#:

26416 S - State

FACILITY EVALUATION RATING:

1 - Unsatisfactory

INSPECTION TYPE:

Other

DATE(S): ENTRY TIME: EXIT TIME:

5/3/2016

PERMIT EFFECTIVE DATE:

12/1/2011

PERMIT EXPIRATION DATE:

11/30/2016

RESPONSIBLE OFFICIAL

NAME: / TITLE

David Burnside / COMPANY: Rebel Producing MAILING ADDRESS:

366 Burnside Farm Rd. CITY, STATE, ZIP: Spearsville LA 71277 PHONE & EXT: / FAX:

870-312-2520 / EMAIL:

FAYETTEVILLE SHALE RELATED: N

FAYETTEVILLE SHALE VIOLATIONS: N INSPECTION PARTICIPANTS

NAME/TITLE/PHONE/FAX/EMAIL/ETC.:

CONTACTED DURING INSPECTION: Yes

AREA EVALUATIONS (S=Satisfactory, M=Marginal, U=Unsatisfactory, N=Not Applicable/Evaluated)

S PERMIT U NOI U REGULATION 1 N RECORDS U OPERATION & MAINTENANCE U FACILITY SITE REVIEW N INSPECTIONS U SPILLS/REPORTING N STORMWATER N OTHER:

SUMMARY OF FINDINGS 1) There was a release of saltwater from the battery through the drain during this inspection. This is a violation of Reg. 1/A. C. A. 8-4-217(a). 2) The NOI does not list the correct SWDs that are connected to this system, and a current list of all wells with GPS coordinates needs to be included. This is a violation of Part II A. 1. C. of the permit. 3) The signs located at the SWDs did not contain the ADEQ permit number. This is violation of Part II A. 3. B. of the permit. 4) The firewall berm had not been maintained to contain 1.5 times the volume of the largest vessel. There was a saltwater leak inside the battery at the time of this inspection. These are violations of Part II B. 10. A. of the permit.

GENERAL COMMENTS The NOI lists eight (8) production wells and two (2) SWDs. Eight (8) production wells, one (1) tank battery, and two (2) SWDs were inspected.

INSPECTOR’S SIGNATURE: Chris Voss DATE: 5/10/2016

SUPERVISOR’S SIGNATURE: Kerri McCabe DATE: 5/18/2016



ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY

GENERAL PERMIT 0000-WG-SW INSPECTION FORM

Inspection Date: May 3, 2016

Inspector: Chris Voss

Compliance Status: ¨ IN / OUT Permit 1. Permittee (Operator): Rebel Producing System Name: ML Sumners #’s C-11 & C-12 SWD Location: N 33.15256 W 92.50496 County: Union Co. 2. Name of On-Site Representative: N/A 3. Name of Responsible Official: David Burnside Address: 366 Burnside Farm Rd.; Spearsville, LA 71277 Telephone: 870-312-2520 4. Is the permit retained onsite? ¨ 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: Woodard Creek 7. Have pollutants entered Waters of the State? ¨ Yes No COMMENTS ON REGULATION 1/A.C.A. 8-4-217 (a): There was a release of saltwater from the battery through the drain during this inspection. 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: N/A

10. Are there any production wells associated with the SWD system that are not listed on the permit? ¨ Yes No ¨ NE If yes, describe: 11. Does a new NOI need to be submitted? Yes ¨ No COMMENTS ON NOI: The NOI does not list the correct SWDs that are connected to this system, and a current list



of all wells with GPS coordinates needs to be included. Operation and Maintenance

13. Are signs posted with the information required by the general permit? ¨ Yes ¨ No ¨ NE If no, describe: Signs listed do not contain the ADEQ permit number. 14. Does the firewall berm appear impermeable & able to contain 1.5 times the largest vessel? ¨ Yes No ¨ NE If no, describe: Firewall berm not maintained. Drain unplugged. 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 No ¨ NE If yes, describe: 18. Are the tanks & pumps free from leaks? Yes ¨ No ¨ NE If no, describe: Saltwater leak inside battery. 19. Production Wells:

Production Well Number Location Tank Battery Number ML Sumners #’s 1, 2, 4, 5, 9, A-2, B-1, C-10

COMMENTS ON OPERATION AND MAINTENANCE: 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

12. Are complaints registered against this permitted facility? ¨ Yes No ¨ NE If yes, give date and description of complaint: N/A



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:

Chris Voss Date of Report: May 10, 2016

Signature of Reviewer:

Kerri McCabe Date of Review: May 18, 2016



Water Division Photographic Evidence Sheet

Location: ML Sumners #'s C-11 & C-12 SWD Photographer: Chris Voss Date: 5/3/16 Time: 9:42 Witness: None Photo #: 1 Description: Firewall berm not maintained.

Photographer: Chris Voss Date: 5/3/16 Time: 9:43 Witness: None Photo #: 2 Description: Leak inside battery.




Location: ML Sumners #'s C-11 & C-12 SWD Photographer: Chris Voss Date: 5/3/16 Time: 9:44 Witness: None Photo #: 3 Description: Leak inside battery.

Photographer: Chris Voss Date: 5/3/16 Time: 9:44 Witness: None Photo #: 4 Description: Release through drain.




Location: ML Sumners #'s C-11 & C-12 SWD Photographer: Chris Voss Date: 5/3/16 Time: 9:45 Witness: None Photo #: 5 Description: Same as above.

Photographer: Chris Voss Date: 5/3/16 Time: 9:45 Witness: None Photo #: 6 Description: Same as above.




Location: ML Sumners #'s C-11 & C-12 SWD Photographer: Chris Voss Date: 5/3/16 Time: 9:48 Witness: None Photo #: 7 Description: ML Sumners #C-12 SWD not connected to system.

Photographer: Chris Voss Date: 5/3/16 Time: 9:49 Witness: None Photo #: 8 Description: Sign does not contain the ADEQ permit number.




Location: ML Sumners #'s C-11 & C-12 SWD Photographer: Chris Voss Date: 5/3/16 Time: 10:21 Witness: None Photo #: 9 Description: Sign at ML Sumners #A-1 SWD does not contain the ADEQ permit number.

Photographer: Chris Voss Date: 5/3/16 Time: 10:22 Witness: None Photo #: 10 Description: ML Sumners #A-1 SWD is not listed on NOI.

December 27, 2016 David Burnside Rebel Producing 366 Burnside Farm Rd Spearsville, LA 71277 RE: Response to Inspection (Union Co)

AFIN: 70-01201 State Permit No.: 0691-WG-SW-4 Dear Mr. Burnside: I have reviewed the response pertaining to my May 3, 2016, inspection of the ML Sumners #C-11 and #C-12 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 [email protected]. Sincerely,

Chris Voss District 8 Oil & Gas Field Inspector Office of Water Quality

re: ml sumners #'s c-11 & c-12 swd inspection (union co ......inspection report: ml sumners...

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