March 26, 2012 Jay Bartley Oilfield Services, LLC JT`s Washout

March 26, 2012
Jay Bartley Oilfield Services, LLC
JT’s Washout Facility, LLC
PO Box 1308
Greenbrier, AR 72058
RE:
Complaint Investigation of numerous facilities located in between the junctions of Hwy 25
& Hwy 107 in Quitman, AR (Faulkner Co); general concerns in regards to contaminated
runoff from O&G-related activities
Mr. Bartley:
On February 2, 2012 I performed an investigation of several facilities located on property in between Hwy
25 & Hwy 107 in Quitman, AR in response to an anonymous call to ADEQ. The complainant had general
concerns of contaminated runoff associated with O&G activities that could possibly come from the site. At
the time of the investigation, you are not in violation of the Arkansas Water and Air Pollution Control Act
and the regulations promulgated thereunder.
Please be advised, per Permit# 4982-WR-2, Part I, Condition #2 that “Wastes shall not be discharged
from this operation to the waters of the State or onto the land in any manner that may result in runoff to
the waters of the State.” During the complaint investigation, the bins used to temporarily store
solid waste cleaned from the wash bay were beyond holding capacity, and solid waste was
observed on the ground. After speaking with Mr. Bartley later in the day, he indicated this issue
would be addressed, and the cleanup was noted during the formal inspection conducted on
February 9, 2012.
Please refer to the “comments” section of the complaint form for notes regarding any “areas of
concern” that may have been observed at the above referenced site.
If you should have any questions, feel free to contact me at 501-683-2789 or via email
[email protected]
Thank you for your time,
Kerri McCabe
Oil & Gas Field Inspector
Water Division
cc:
Water Division Permits Branch
Water Division Enforcement Branch
FOR OFFICE USE ONLY:
AIR HW RST SW WATER MINING
ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY
5301 Northshore Drive, North Little Rock, AR 72118
COMPLAINT REPORT
GPS:
Lat: 35.357800; Long: -92.233779
AFIN#: 23-00962
DATE RECEIVED: Feb. 1, 2012
COUNTY: Faulkner Co.
COMPLAINANT NAME: Anonymous Caller
COMPLAINT AGAINST: JT’s Washout Facility, LLC
ADDRESS:
N/A
ADDRESS:
PO Box 1308
Greenbrier, AR 72058
PHONE: N/A
FAX: N/A
PERMIT#: 4982-WR-2
PHONE: Jay Bartley (501-514-2906)
FAX: N/A
PERSON RECEIVING REPORT:
Kerri McCabe
DATE:
Feb. 1, 2012
SUPERVISOR REFERRAL:
DATE:
INSPECTOR REFERRED:
Kerri McCabe
DATE:
Feb. 1, 2012
MEDIA SUPERVISOR REFERRAL:
DATE:
PHONE REFERRAL CONTACT:
DATE:
RECEIVING INSPECTOR:
Kerri McCabe
DATE:
2-2-12
DESCRIPTION (IN DETAIL)
The anonymous complainant called ADEQ’s Water Division with general concerns about possible contaminated
runoff generate from an unspecified facility located on property situated in between Hwy 25 & Hwy 107 in
Quitman, AR. The caller noted that the facility did O&G-related work.
LOCATION (IN DETAIL)
From Little Rock, AR take I40 west toward Conway. Take the 3rd Conway exit to Hwy 65 & continue north (right)
onto Hwy 65 toward Greenbrier, AR. At the Hwy 65/25 junction, merge right onto Hwy 25 toward Guy. Continue
toward Quitman. The groups of facilities are located on the right before the Hwy 25/107 junction.
PREVIOUS COMPLAINT?  YES  NO DATES:
DISCHARGE TO WATERS OF THE STATE?  YES  NO NAME OF WATERBODY:
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2
HOW COMPLAINT WAS RECEIVED:  PHONE  LETTER  VERBAL
 FAX
 E-MAIL
FOLLOW- UP ON COMPLAINT
COMPLAINT #:
4982-WR-2_comp_20120202
AFIN #: 23-00962
INSPECTOR: Kerri McCabe
DATE: Feb. 2, 2012
ACTION TAKEN:
PHOTOS TAKEN: YES
PDS #013862
I arrived at the general location described by the caller, which was property in between the junction of Hwy 25 &
Hwy 107 in Quitman, AR. I investigated JT’s Washout Service first because there are three O&G-related facilities
located in the area. There were no signs at JT’s Washout Facility or SweetH2O (recently moved to a different
location & currently only has cleaned pipe for water transport stored on a lot), and I performed a separate
investigation of Washita Valley Enterprises, Inc. believing all the facilities were owned/operated by a single
individual.
I spoke with a gentleman at the facility with a “JBOS” logo on his work shirt, and he informed me that the office
personnel were probably at lunch. I told him of my intentions & proceeded to investigate the facility. The facility
has two bays (observed tankers within both bays) with two frac tanks behind them, and a water tank & pressure
washer in front of the bays. Solids collected from the washing of tankers were being stored in drill cuttings boxes
onsite. These boxes were beyond capacity & solids were observed on the ground. The facility is in close-proximity
to a privately-owned pond, and there are numerous drainage ditches & pools located within the facility. The fluids
separated during tanker washing were being stored in frac tanks onsite (I opened one hatch to determine if they
contained materials; fluids were less than 12 inches from the top of the tank; hydrocarbons were present). The
frac tanks were not bermed; however, solids & fluids are routinely disposed of at approved-facilities offsite (per the
Waste Management Plan submitted by JT’s Washout Facility, LLC).
I was unaware of the permit status until I arrived back to the office (Mr. Bartley had called ADEQ); however, I
scheduled a formal inspection of the facility under the permit terms with Mr. Bartley. Therefore, I did not evaluate
any paperwork during the investigation. I informed Mr. Bartley that the solids observed on the ground needed to
be address. He informed me that the storage bins were to be transported to disposal the following day. This is a
violation of Permit# 4982-WR-2, Part I, Condition #2: “Waste shall not be discharged from this operation to the
waters of the State or onto the land in any manner that may result in runoff to the waters of the State.”
FURTHER ACTION TAKEN/TO BE TAKEN:
I will be conducting a formal inspection of the facility under the permit terms on Feb. 9, 2012.
UPDATE: During the formal inspection, it was noted that the area & bins used to temporarily store solid
waste cleaned from the wash bay had been cleaned. The soil had been disked & limed and the storage
bins had been emptied.
INSPECTOR SIGNATURE:
DATE: February
15, 2012
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3
Water Division Photographic Evidence Sheet
JT’s Washout Facility from Hwy 25 about 2.1 miles SxSW of Quitman, AR
Location:
Kerri McCabe
Photographer:
Photo #
1
Kerri McCabe
Photographer:
Description:
4
none
Date:
02-08-12
Time:
0803
Overview of general location between Hwy 25 & Hwy 107
Description:
Photo #
Of
Witness:
2
Of
4
Witness:
Date:
none
02-02-12
Time:
1242
Wash bay & cells with fresh water storage
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4
Water Division Photographic Evidence Sheet
Location:
JT’s Washout Facility from Hwy 25 about 2.1 miles SxSW of Quitman, AR
Kerri McCabe
Photographer:
Photo #
3
Kerri McCabe
Photographer:
Description:
4
none
Date:
02-02-12
Time:
1246
Storage bins beyond capacity; solid waste on ground
Description:
Photo #
Of
Witness:
4
Of
4
Witness:
Date:
none
02-02-12
Time:
1248
Frac tanks waiting to be cleaned
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5
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):
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