April 1, 2013 Crystal Baker, Petroleum Technician Ross Explorations, Inc. P.O. Box 2985 Fort Smith, AR 72913 RE: AFIN: 66-00000 ADEQ Reference#: 00626-W-RB Well Site: Dalmut #1-18 County: Sebastian Dear Ms. Baker: On March 13, 2013, I performed an inspection of the above referenced drilling site in accordance with the provisions of the Arkansas Water and Air Pollution Control Act and the regulations promulgated thereunder as well as the Arkansas Oil & Gas Commission’s General Rule B-17. At the time of my inspection, the site was not in compliance and the following violation was revealed: Drill cuttings were observed on top of the pit wall and to the west of the pit. I recorded a conductivity reading of 1.145 mS/cm on the outside of the pit by the drill cuttings. A conductivity reading of 0.525 mS/cm was recorded approximately 15 feet downslope of the previously mentioned reading. This discharge from the pit was never reported to ADEQ. This is in violation of Arkansas Pollution Control and Ecology Commission’s Regulation No. 34 Section 34.202, as outlined in AOGC’s Rule B-17(e). Please submit a written response to these findings to the Water Division Inspection Branch of this Department. This response should be mailed to the address at the bottom of the first page of the letter or emailed 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 April 15, 2013. Also noted on-site was a diesel tank not located in secondary containment. A spill was located by this tank (Photos 7 and 8). This issue will be referred to AOGC. Please review the “Summary and Remarks” section of the inspection form for any additional comments regarding the above referenced site. On March 15, 2013, I met with Eddie Stinnett, Drilling Manager, and Jeep Etchieson, Equipment Manager to discuss the site. If I can be of any assistance, please contact me at 479-424-0331 or by email at [email protected]. Sincerely, Angela Coats Oil & Gas Field Inspector Water Division cc: Jay Hansen, AOGC, Senior Petroleum Geologist, [email protected]
Transcript
April 1, 2013 Crystal Baker, Petroleum Technician Ross Explorations, Inc. P.O. Box 2985 Fort Smith, AR 72913 RE: AFIN: 66-00000 ADEQ Reference#: 00626-W-RB Well Site: Dalmut #1-18 County: Sebastian Dear Ms. Baker: On March 13, 2013, I performed an inspection of the above referenced drilling site in accordance with the provisions of the Arkansas Water and Air Pollution Control Act and the regulations promulgated thereunder as well as the Arkansas Oil & Gas Commission’s General Rule B-17. At the time of my inspection, the site was not in compliance and the following violation was revealed:
Drill cuttings were observed on top of the pit wall and to the west of the pit. I recorded a conductivity reading of 1.145 mS/cm on the outside of the pit by the drill cuttings. A conductivity reading of 0.525 mS/cm was recorded approximately 15 feet downslope of the previously mentioned reading. This discharge from the pit was never reported to ADEQ. This is in violation of Arkansas Pollution Control and Ecology Commission’s Regulation No. 34 Section 34.202, as outlined in AOGC’s Rule B-17(e).
Please submit a written response to these findings to the Water Division Inspection Branch of this Department. This response should be mailed to the address at the bottom of the first page of the letter or emailed 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 April 15, 2013. Also noted on-site was a diesel tank not located in secondary containment. A spill was located by this tank (Photos 7 and 8). This issue will be referred to AOGC. Please review the “Summary and Remarks” section of the inspection form for any additional comments regarding the above referenced site. On March 15, 2013, I met with Eddie Stinnett, Drilling Manager, and Jeep Etchieson, Equipment Manager to discuss the site. If I can be of any assistance, please contact me at 479-424-0331 or by email at [email protected]. Sincerely,
Angela Coats Oil & Gas Field Inspector Water Division cc: Jay Hansen, AOGC, Senior Petroleum Geologist, [email protected]
Pit Construction Pit Operation Inspection Pit Closure Inspection Follow-up Inspection
Permit Holder Ross Explorations, Inc. Well Name / No. Dalmut #1-18
Section 18 Township 4N Range 31W
GPS Well Location Latitude 35.0133 Longitude -94.3275 Field B-44 County Sebastian
CURRENT LOCATION AND PIT STATUS
Has a Form 2A been filed Y N Has drill pad been constructed Y N Pit Completed Y N Conductor Set Y N Old Site Y N
Remarks The production casing has been set, but the well has not been completed. The rig was still on location.
PIT CONSTRUCTION
48 Hr noticed received Y N Pit Type Circulation Mud Reserve Above Ground Level Below Ground Level
Are any surface waters (including streams, creeks, lakes, wetlands, any other bodies of water) impacted by construction Y N Name
Stage of Pit Construction Excavation Berms Completed Underlayment Installed Liner Installed Other (see remarks)
Reserve Pit Construction
Berm 2’ wide at top of wall Y N 2 to 1 slope on berm walls Y N Liner Type 20 mils 40 mils 4” Lap Clay Synthetic liner damage Y N Construction defects Y N Alternative liner construction Y N
Mud/Circulation Pit
Closed loop Y N NA Sand used under liner Y N NA Earthen Y N Rocky or uneven surface Y N NA Construction defects Y N Liner Type 20 mils Bentonite Concrete
Alternative liner construction Y N NA Synthetic liner damage Y N Other (see remarks)
Remarks
MUD, CIRCULATION OR RESERVE PIT OPERATION INSPECTION
Is pit being actively used Y N Pit Conditions Fluids Present Y N
Type of Fluid Water based mud Saltwater Unknown fluid type Drilling fluids Stormwater Oil based mud Produced water Frac flow-back fluid Encountered water Completion / workover flow-back fluid
Drill cuttings present Y N Adequate berm Y N NA Adequate freeboard Y N Synthetic liner damage Y N NA Breach Y N Discharge Y N
Trash / debris Y N Remarks
MUD, CIRCULATION, OR RESERVE PIT CLOSURE
Fluids removed from pit Y N Fluids pumped down well bore Y N Fluids burned on-site Y N Synthetic liner removed from pit Y N Synthetic liner removed from location Y N Site remediated Y N
Pit filled Y N Covered with topsoil Y N Returned to original grade Y N
Post Closure Form 2B filed Y N Erosion control in place Y N Seeded Y N Sufficient vegetation coverage Y N
STORMWATER EROSION AND SEDIMENT CONTROL INSPECTION
Stormwater erosion and sediment control plan Y N Are erosion and sediment controls in place Y N Are there any breaches or erosion problems Y N
SUMMARY AND REMARKS
Compliance Summary / Remarks Drill cuttings were observed on top of the pit wall and to the west of the pit. I recorded a conductivity reading of 1.145 mS/cm just on the outside of the pit wall by the drill cuttings. A conductivity reading of 0.525 mS/cm was recorded approximately 15 feet downslope of the previously mentioned reading. This discharge from the pit was never reported to ADEQ. I also observed a spill by a diesel tank located on the pad. The tank was not located in secondary containment. This issue will be referred to AOGC. Erosion controls have not been implemented. Erosion controls are needed to prevent sediment from polluting waters of the State. The well pad and pit are adjacent to a pond and natural drainage. PDS #070800
Inspected by Angela Coats Report Date March 29, 2013
NNC Issued Y N Refer for Enforcement Y N AOGC Referral Y N Date of Referral April 1, 2013
Arkansas Department of Environmental Quality (ADEQ)
Official Photograph Sheet
Location: Dalmut #1-18, located off Patterson Road southeast of Hartford, AR
Photographer: Angela Coats Witness: None
Photo # 1 Of 8 Date: 3/13/13 Time: 1327
Description: Drill cuttings observed on top and to the west of the pit.
Photographer: Angela Coats Witness: None
Photo # 2 Of 8 Date: 3/13/13 Time: 1327
Description: Location of pit and drill cuttings in relationship to a pond and drainage. The
drainage is located to the right of the pond.
Arkansas Department of Environmental Quality (ADEQ)
Official Photograph Sheet
Location: Dalmut #1-18, located off Patterson Road southeast of Hartford, AR
Photographer: Angela Coats Witness: None
Photo # 3 Of 8 Date: 3/13/13 Time: 1348
Description: Conductivity of 1.145 mS/cm recorded just to the west of the pit wall by the
drill cuttings.
Photographer: Angela Coats Witness: None
Photo # 4 Of 8 Date: 3/13/13 Time: 1348
Description: Location of where the 1.145 mS/cm conductivity reading was recorded.
Arkansas Department of Environmental Quality (ADEQ)
Official Photograph Sheet
Location: Dalmut #1-18, located off Patterson Road southeast of Hartford, AR
Photographer: Angela Coats Witness: None
Photo # 5 Of 8 Date: 3/13/13 Time: 1345
Description: A conductivity reading of 0.525 mS/cm was recorded approximately 15 feet
downslope of the previously mentioned reading.
Photographer: Angela Coats Witness: None
Photo # 6 Of 8 Date: 3/13/13 Time: 1345
Description: Location of where the 0.535 mS/cm conductivity reading was recorded.
Arkansas Department of Environmental Quality (ADEQ)
Official Photograph Sheet
Location: Dalmut #1-18, located off Patterson Road southeast of Hartford, AR
Photographer: Angela Coats Witness: None
Photo # 7 Of 8 Date: 3/13/13 Time: 1323
Description: Diesel tank on pad not in secondary containment.
Photographer: Angela Coats Witness: None
Photo # 8 Of 8 Date: 3/13/13 Time: 1324
Description: Spill around diesel tank.
Oil & Gas Violation Summary Sheet
No Violations Noted
Placing Waste
Permitting Issues
Spills & Leaks
Turbidity, Sedimentation, etc. (Regulation #2 Violations)
Stormwater &/or Erosion Issues
Notification/Reporting Violations
Unpermitted Discharges
Record Keeping/Paperwork Violations
Trash/Unauthorized Fluids in Pits
Improper Closure of Pit
Insufficient Freeboard
Poor Pit Construction
Other (Describe):
May 10, 2013 Timothy R. Smith, President Ross Explorations, Inc. P.O. Box 2985 Fort Smith, AR 72913 RE: Response Letter to ADEQ Inspection (Sebastian Co);
AFIN: 66-00000 ADEQ Reference #: 00626-W-RB Dear Mr. Smith: I have reviewed your response pertaining to my March 13, 2013, inspection of the Dalmut #1-18 well site. However, the information provided does not sufficiently address the violation referenced in my inspection report. Please provide the ADEQ Water Division Inspection Branch with photos of the work that has been completed to date, and please provide a timeline for the completion of the remaining work on the Dalmut #1-18 well site. This work should be completed as soon as possible. Please provide the photos and timeline no later than May 24, 2013. Thank you for your attention to this matter. Should you have any questions, feel free to contact me at 479-424-0331 or you may e-mail me at [email protected]. Sincerely,
Angela Coats Oil & Gas Field Inspector Water Division
June 12, 2013 Timothy R. Smith, President Ross Explorations, Inc. P.O. Box 2985 Fort Smith, AR 72913 RE: Failure to Respond to Inadequate Response Letter (Sebastian Co);
ADEQ Reference #: 00626-W-RB; AFIN: 66-00000 Dear Mr. Smith: A letter dated May 10, 2013, was sent to you by ADEQ. The letter outlined the insufficiencies of your facility’s response to my March 13, 2013, inspection of the Dalmut #1-18. The letter requested that a written response be submitted to the Water Division Inspection Branch of this Department by May 24, 2013. To date, no response has been received. Therefore, this case has been referred to our Enforcement Branch for further review. You may contact Shawn Hill, Enforcement Coordinator, ADEQ Water Division Enforcement Branch, at 501-682-0632 or via e-mail at [email protected] for additional information. Sincerely,
Angela Coats Oil & Gas Field Inspector Water Division cc: Mo Shafii, Assistant Chief, Water Division
Craig Uyeda, Enforcement Branch Manager, Water Division Shawn Hill, Enforcement Coordinator, Water Division Crystal Baker, Petroleum Technician, [email protected]
