January 20, 2012
Becky Keogh
BHP Billiton Petroleum (Fayetteville), LLC
PO Box 1412
Searcy, AR 72145
RE:
AFIN: 23-01034
WELL NAME: Trammel 7-13, #1-8 SWDW
PERMIT NO.: 0742-WG-SW-1
COUNTY: Faulkner Co.
Ms. Keogh:
On January 17, 2012 I performed a routine compliance inspection of the surface facilities associated with a disposal
system for injection of saltwater & other oil/gas wastes in accordance with the provisions of the Arkansas Water and Air
Pollution Control Act, and the regulations promulgated thereunder. At the time of the inspection, no violations were
observed.
Please be advised, per Part III, Section A.1.e. of your general permit# 0000-WG-SW, Operators of SWD facilities
covered by the general permit that modify permitted facilities as described in Part III, Section A.1.a-d shall be in violation
of this general permit & subject to appropriate enforcement action by the Director (Part III, Section A.1.c., an increase or
decrease in the above-ground storage capacity). The facility no longer has above-ground storage containers. The
injection well is P/A per AOGC Form 12 (Record of Plugging), and the facility is no longer in operation. The most
recent modification to the general permit was submitted for the transfer of Permit# 0742-WG-SW from
Chesapeake Energy to BHP Billiton Petroleum (Fayetteville), LLC (resulting in Permit# 0742-WG-SW-1). There is
no paperwork on file submitted for the removal of the above-ground storage for Trammel 7-13, #1-8 SWDW.
Failure to attend to this matter in a timely manner could result in enforcement action.
Please refer to the “comments” section of the inspection form for any notes regarding any “areas of concern”
that may have been observed at the above referenced site. Furthermore, I have contacted Rick Spicer by phone
in regards to any potential issues concerning this site.
If I can be of any further assistance, please contact me at 501-683-2789 or via email at [email protected]
Thank you for your time,
Kerri McCabe
Oil & Gas Field Inspector
Water Division
501-683-2789
[email protected]
cc:
Water Division Enforcement Branch
Water Division Permits Branch
Rick Spicer, BHPB Senior Environmental Specialist, [email protected]
AFIN: 23-01092
ADEQ Water Industrial No Discharge
Permit #: 0781-WG-SW-1
ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY
NO DISCHARGE INDUSTRIAL PERMIT INSPECTION FORM
AFIN:
Log No.:
23-01034
Permit No.:
0742-WG-SW-1 (AOGC# 41079)
Media: WATER
Inspection Date:
Inspector:
Compliance Status:
January 17, 2012
Kerri McCabe
 IN /  OUT
1A.
Name of Facility: Trammel 7-13, #1-8 SWDW
Address: Lat: 35.264543; Long: -92.411544
County: Faulkner Co.
2A.
Name of On-Site Representative: No one onsite; facility no longer in operation.
3A.
Name of Responsible Official: Rod Skaufel
BHP Billiton Petroleum
(Fayetteville), LLC
1360 Post Oak Blvd, Suite 150
Address: Houston, TX 77056-3030
Telephone: 713-961-8500
Parent Company:
Address:
Telephone:
4A.
N/A
5A.
Description of Process (including type of industry, materials produced, and major byFacility stores/filters produced waters from other BHPB
drilling/production sites in the area & the filtered fluids are then
products): injected into the well.
6A.
Any complaints registered against this permitted facility?
If yes, give date and description of complaint:
7A.
Are there any additions, modifications, or corrections to the facility since the last
inspection?
 Yes No
Since the last inspection (June 27, 2011), BHPB has removed the
above-ground storage from the facility. The facility is no longer in
If yes, explain:
operation, and the injection well has been plugged.
Yes
No
No Discharge Industrial Report Page 2
ADEQ Water Industrial No Discharge
AFIN: 23-01092
Permit #: 0781-WG-SW-1
1B.
Furnish a simplified flow diagram of the treatment system and include main components,
flow sequence through plant, and calculated or estimated flows.
2B.
Nearest Stream:
3B.
Does wastewater from this facility cause adverse effect on the waters of the State:
 Yes No
If yes, describe:
Unnamed, perennial tributary of Greenbrier Creek
Discharge of any saltwater or other oil/gas field wastes, including
contaminated precipitation runoff, to the land or waters of the State is
prohibited at all times. NO wastewater is discharged from the site.
4B.
Are operating records kept as required by permit?
 Yes
If no, explain: The facility is no longer operating.
No N/A
5B.
Are maintenance records kept as required by permit?
If no, explain:
 Yes
No N/A
6B.
Are Samples routinely taken?
 Yes
No N/A
7B.
Does the sampling program meet the requirements of the permit?
 Yes No
If no, explain: The facility is no longer operating.
8B.
What laboratory does the facility use?
Address:
N/A
Telephone:
No Discharge Industrial Report Page 3
ADEQ Water Industrial No Discharge
AFIN: 23-01092
Permit #: 0781-WG-SW-1
1C.
Do laboratory procedures and records meet the requirements of the permit?
 Yes No N/A
If no, explain:
The facility is no longer operating.
2C.
 Yes
Is contaminated runoff a problem?
If yes, explain:
The facility is no longer operating.
No N/A
3C.
Is sludge disposal required?
If yes, describe (including final destination):
 Yes
No N/A
4C.
Is the treatment system being properly operated and maintained as required by permit?
 Yes No N/A
If no, explain The facility is no longer operating.
SUMMARY OF FINDINGS/COMMENTS
The site is a non-commercial site & only injects produced waters from BHPB drilling &
production sites. However, the facility is no longer in operation. The Operator has removed all
above-ground storage associated with the disposal system (injection well). The last modification
submitted for 0742-WG-SW-1 was for the transfer of Permit# 0742-WG-SW from Chesapeake
Energy to BHP Billiton Petroleum (Fayetteville), LLC. There has been no paperwork submitted
to ADEQ for the decrease in above-ground storage (i.e., NOI modification &/or NOT). The
injection well is plugged (per AOGC Form 12). The secondary containment (concrete berms &
receiving pit) remains onsite, and the plugged well is identified by a “P/A Well Below” sign.
The receiving pit contains fluid that is below the required freeboard limit. No personnel were
onsite during the inspection; however, the facility’s entrance is barricaded & shares a lease road
with two BHPB production pads (Hardy & Hammett), which has a lockable gate. I could not
evaluate any records associated with this facility (not located onsite). The above-ground storage
has been moved to BHPB’s SRE 8-12, #1-17 SWDW facility located in Guy, AR.
Inspector Signature:
Date of Report:
January 20, 2012
Signature of Reviewer:
Date of Review:
February 2, 2012
No Discharge Industrial Report Page 4
ADEQ Water Industrial No Discharge
AFIN: 23-01092
Permit #: 0781-WG-SW-1
Water Division No Discharge Industrial Photographic Evidence Sheet
Location:
Trammel 7-13, #1-8D SWD from Hwy 65 about 2.5 miles NxNW of Greenbrier, AR
Photographer:
Photo #
1
Kerri McCabe
Of
3
Description:
Plugged injection well
Photographer:
Kerri McCabe
Photo #
Description:
2
Of
3
Witness:
Date:
none
01-17-12
Witness:
none
Date:
01-17-12
Time:
Time:
1403
1405
Secondary containment of above-ground storage; removed from site
No Discharge Industrial Report Page 5
ADEQ Water Industrial No Discharge
AFIN: 23-01092
Permit #: 0781-WG-SW-1
Water Division No Discharge Industrial Photographic Evidence Sheet
Location:
Trammel 7-13, #1-8D SWD from Hwy 65 about 2.5 miles NxNW of Greenbrier, AR
Photographer:
Photo #
Description:
3
Kerri McCabe
Of
3
Witness:
Date:
none
01-17-12
Time:
1404
Receiving pit contains fluid; below required freeboard level
No Discharge Industrial Report Page 6
ADEQ Water Industrial No Discharge
AFIN: 23-01092
Permit #: 0781-WG-SW-1
Oil & Gas Violation Summary Sheet

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











No Violations Noted
Placing Waste
Permitting Issues
Spills & Leaks
Turbidity (Regulation #2 Violations)
Stormwater/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):
No Discharge Industrial Report Page 7