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ADEQ
Details for Inspecon Number 064649
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Inspecon Date:
File List:
AFIN:
Permit Number:
Media:
Name:
County:
Address:
02/29/2012
064649-insp.pdf (/proot/Pub/WebDatabases/InspeconsOnline/064649insp.pdf)
1200000
WS - Water-SPB
XTO Energy, Inc.
Cleburne
Ballew #1-22H
210 Park Ave., Suite 2350
Oklahoma City, OK 73102
Latude:
Longitude:
Inspecon Reason:
Inspecon Status:
Inspecon Type:
Compliance Status:
Total Inspecon Score:
Scheduled
Completed
Compliance
Out of Compliance
3/16/2015 9:30 PM
2 of 2
Concerns Comment:
http://www.adeq.state.ar.us/complaints/searches/p_inspections.aspx?Com...
Ballew #1-22H I found the following violaons: Regulaon 34.202 (A), which
states, "Owners or Operators of all pits constructed during the drilling, compleon,
or tesng of an oil, gas, or oil & gas producon well, [brine producon & injecon
wells], Class II Disposal Well, Class II Commercial Disposal Well shall be deemed to
have a permit by rule pursuant to Ark. Code Ann. 8-4-203(1), for the construcon,
operaon, and closure of any pits covered under this Regulaon if the Owner or
Operator is in full compliance with Rule B-17, as adopted by the Arkansas Oil &
Gas Commission (AOGC) on October 28, 2010." The Operator has led Noces of
Terminaon for ADEQ's General Permits 00000-WG-P; however, the Operator has
not submied AOGC's Form 2A & Form 2B for reserve pits constructed/closed
under the General Permit as required by AOGC Rule B-17 (d) "Commencement of
Construcon Operaons" & (h)(1)(F)(7) "Fluid Disposal & Earthen Pit Closure
Requirements for Water-based Drilling Fluid & Encountered Water." The
informaon provided on these forms (i.e., locaon of pit, Fluid Reuse, etc.) is vital
to joint inspecons conducted by ADEQ & AOGC.
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3/16/2015 9:30 PM
RE:
AFIN: 12-00000; Permit by AOGCs Rule B-17 (no AOGC Form 2A on file)
Well Site: Ballew #1-22H; Cleburne Co.
Ms. Pollock:
On February 29, 2012 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. At the time of the investigation, it has been
revealed that you are in violation of the Arkansas Water & Air Pollution Control Act, the
federal Clean Water Act and the regulations promulgated thereunder. Specifically, I
found the following violations:
Regulation 34.202 (A), which states, Owners or Operators of all pits constructed during
the drilling, completion, or testing of an oil, gas, or oil & gas production well, [brine
production & injection wells], Class II Disposal Well, Class II Commercial Disposal Well
shall be deemed to have a permit by rule pursuant to Ark. Code Ann. 8-4-203(1), for
the construction, operation, and closure of any pits covered under this Regulation if the
Owner or Operator is in full compliance with Rule B-17, as adopted by the Arkansas Oil
& Gas Commission (AOGC) on October 28, 2010. The Operator has filed Notices of
Termination for ADEQs General Permits 00000-WG-P; however, the Operator has
not submitted AOGCs Form 2A & Form 2B for reserve pits constructed/closed
under the General Permit as required by AOGC Rule B-17 (d) Commencement of
Construction Operations & (h)(1)(F)(7) Fluid Disposal & Earthen Pit Closure
Requirements for Water-based Drilling Fluid & Encountered Water. The
information provided on these forms (i.e., location of pit, Fluid Reuse, etc.) is vital
to joint inspections conducted by ADEQ & AOGC.
The above item requires your immediate attention. Please submit a written response to
these findings to the Water Division Enforcement Branch Manager. This response
should be mailed to the address provided in the footer of this letter, or e-mailed to
Water-Enforcement-Report@adeq.state.ar.us 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 April 6, 2012.
Kerri McCabe
Oil & Gas Field Inspector
Water Division
501-683-2789
mccabe@adeq.state.ar.us
cc:
4. Has Operator prepared a storm water erosion & sediment control plan or guidance document? Note: XTO has provided ADEQ with RAPPS
Y
Y
Y
Y
5. Does it appear that the erosion & sediment controls are being maintained in good operating condition? Note: permanent & temporary BMPs in
place; recent gathering construction
Y N NA NE
6. At the time of the inspection, was there evidence that the site had any oil/fluid spills?
Y N NA NE
Y N NA NE
Y N NA NE
1. Is there evidence of sediment runoff from the drilling pad or well site observed in waters of the state?
2. At the time of inspection, was there any evidence observed of Reg. 2 turbidity standards being exceeded?
3. Has the Operator implemented erosion & sediment controls in place to minimize sediment runoff from occurring?
a. If so, were the spills properly contained, cleaned & disposed of?
b. Has the spill been reported to ADEQ?
7. Did any rerouting, filling or channelization of any water of the state occur during drilling pad or lease road construction? Note: nearest
waterbody is an unnamed, intermittent tributary (Waterfall Hollow) to Big Creek
N
N
N
N
NA
NA
NA
NA
NE
NE
NE
NE
Y N NA NE
Y N NA NE
Y N NA NE
Y N NA NE
Y N NA NE
Y N NA NE
Y N NA NE
4. At the time of inspection, is there any evidence that the pit or pits were not constructed with the appropriate liner (i.e., 20mm synthetic liner,
compacted-clay liner &/or bentonite liner)?
5. At the time of inspection, is there any evidence that the reserve pit or pits are not structurally sound? (i.e., cracks/holes in levees &/or
tears/holes in liners)?
Y N NA NE
6. Is there any indication that seepage is coming from the drilling pad or pit?
Y N NA NE
7. At the time of the inspection, was there any evidence that pit fluids had been discharged onto the ground or into waters of the state from the pit
or from drilling pad? Note: cuttings outside reserve pit on production pad side
Y N NA NE
Y N NA NE
Y N NA NE
Y N NA NE
Y N NA NE
9. At the time of inspection, is there any evidence noted that the pit contained unapproved fluids or materials (i.e., waste oil, hydraulic or
completion fluids, trash &/or any Nonhazardous Oilfield Waste)?
Y N NA NE
10. According to the onsite contact person how & where are fluids disposed? N/A
a. Carrier: not indicated on the Statement of Disposition &/or NOT
b. Destination: not indicated on the Statement of Disposition &/or NOT
c. Type of Disposal: not indicated on the Statement of Disposition &/or NOT
Y N NA NE
Y N NA NE
1. Have all drilling fluids &/or solids been removed from the reserve pit
2. Does it appear that the pit has been properly closed and seeded?
3. Has the Operator submitted a completed Statement of Disposition & NOT within 90 days of closure of the pit? Note: NOT submitted Dec. 12,
Y N NA NE
2011 for General Permit# 02122-WG-P; Operator has not submitted AOGC Form 2A
Comments: There is an OPEN pit onsite. BMPs are in place & being maintained. Vegetation is establishing in most areas surrounding the production pad. Recent
gathering work has disturbed soil along the pipeline Right of Way (BMPs along the ROW as well). No erosion issues were noted during the inspection. Cuttings are
outside the reserve pit on the production pad side as well as some small oil-based spills on the production pad. The Operator has submitted the NOT for General
Permit# 02122-WG-P; however, an AOGC Form 2A has not been filed for this OPEN reserve pit.
PDS #064649
Inspector: Kerri McCabe
Ballew #1-22H from Hwy 16 off Price Ford Rd about 6.6 miles WxSW of
Pangburn, AR
Photo #
Of
Description:
Date:
02-29-12
Time:
1122
Time:
1132
Site identification
Description:
Photo #
Witness: none
Of
Witness: none
Date:
02-29-12
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):
April 9, 2012
Juanita Pollock
XTO Energy, Inc
210 Park Ave, Suite 2350
Oklahoma City, OK 73102
RE: AFIN: 12-00000; Permit by AOGCs Rule B-17
Ballew #1-22H
Dear Ms. Pollock:
The Department has received your response to the February 29, 2012 inspection of
your facility by our District Field Inspector, Kerri McCabe. Your letter appears to
adequately address the discrepancies identified during the visit. The Department
expects 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
501-682-0667 or you may e-mail me at bolenbaughm@adeq.state.ar.us.
Sincerely,
Michelle Bolenbaugh
Enforcement Analyst
Water Division Enforcement Branch
1 of 4
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ADEQ
Details for Complaint Number 014098
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AFIN:
Permit Number:
Media:
Name:
County:
Address:
04/02/2012
014098-COMP.pdf (/proot/Pub/WebDatabases/Complaints/014098COMP.pdf)
7300000
00449-W-RB
WS - Water-SPB
XTO ENERGY, INC
Cleburne
BALLEW #1-22h
211 PANGBURN
HEBER SPRINGS, AR 72543
Latude:
Longitude:
35.402670
-91.950489
3/16/2015 9:28 PM
2 of 4
http://www.adeq.state.ar.us/complaints/searches/p_complaints.aspx?Com...
Inacve Invesgaon:
Inacve Invesgaon Reason:
Valid Complaint:
3/16/2015 9:28 PM
3 of 4
Invesgaon Comment:
http://www.adeq.state.ar.us/complaints/searches/p_complaints.aspx?Com...
Inially, I spoke with Ms. Ballew at length about the issues she was having with
the producon pad located on her property (4-3-12). She was mainly concerned
with trash le by the contractors & low-levels of NORM indicated in water
samples collected by ADH as well as improper reserve pit closure. I told her I had
been to the site in late Feb 2012 & the pit uids were well below the minimum
freeboard requirements. I informed her that I had walked the enre length of the
pipeline ROW, and that's when she told me she didn't have issues with the
pipeline ROW but the original lease road. Apparently, the contractor originally
started construcon of a lease road on Ms. Ballew's property & then decided to
put the lease road on Mr. Waldo's property. The contractor had apparently le
windrowed trees & disturbed soil along the original lease road route. I told her I
could not address the trash or events that occurred in Nov 2011, but that I would
re-visit the site during the pit closure. She was concerned about them removing
the liner because of the low-levels of NORM indicated in samples taken by ADH. I
informed her that removing the liner was standard pracce & can result in
violaons if not removed. I told her all uids were to be removed to the fullest
extent, but that solids could be buried onsite if pre-approved by ADEQ (kiln
dust/y ash method). I arrived onsite later in the day & the pit was sll being
graded/contoured. I spoke with Mr. Lance B. while onsite. He informed me that
the liner was being taken to Rolling Meadows Landll in Hazen, AR. He said that
JM Oileld Services had hauled the reserve pit contents (locaon unknown at this
me). Silt fence was installed around the former reserve pit area. Ms. Brooke
Shaw with XTO Energy informed me that the reserve pit contained shallow
groundwater & stormwater. XTO Energy did not use the reserve pit during a Frac
Flowback Reuse program. Also, I inspected the lease road (separate report). I did
not invesgate the original route because that acvity occurred on private
property & I could not see any indicaon of the acvity from the producon pad
or pipeline ROW. FURTHER ACTION TAKEN/TO BE TAKEN: I spoke with Ms.
Ballew's original landman from XTO Energy (Dean Burne). They have proclaimed
"emanate domain" on Ms. Ballew's property due to mineral rights. The decision
was based on a combinaon of secon lines & inial interest/disinterest between
two pares (Ballew & Waldo). XTO Energy & the Ballew family could not come to
an agreement with the proposed well lease. These proceedings are beyond the
scope of ADEQ, and no further acon is required. ADH & AOGC were the original
pares contacted in Nov 2011. If there was the potenal for a discharge to
surface waters, ADEQ should have been noed. NORM is under the jurisdicon
of ADH & subsurface acvies (i.e., well bore, drilling, etc.) are the jurisdicon of
AOGC. Since inial water samples were taken by ADH, follow-up samples should
be conducted by that agency. It should be noted that NORM is naturally occurring
at the surface & in shale. [Last modied by schaeer, 5/7/2012 12:25:42 PM]
3/16/2015 9:28 PM
4 of 4
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Descripon Comment:
From report provided by ADEQ's Emergency Response (ER): Caller advised ER: "
Pit has overowed in November; " Liner has been removed; " There is sludge in
pit that is being lled in; " Concerned about material seeping into the ground
since liner is removed; " When caller lmed the operaons, someone came out to
get the sludge out but a large poron had already been lled in; " Health
Department has tested the water and found radiaon; " EPA Dallas was contacted
and advised the water should be tested for radiaon; " Photos and lm
informaon is for documentary that will be presented to the State Legislature; "
Will share photos with ADEQ-ER. As caller was driving back to Lile Rock, she
requested ER call tomorrow and provide an address to send the photos to. The
main concern of the caller apparently surrounds the radiaon reportedly to have
been found in the water. There is no current report of any overow or breach or
impact to water other than potenal seepage due to the liner being removed.
Locaon Comment:
Ballew #1-22H Permit #00449-W-RB AFIN #73-00000 From NLR take Hwy 167/67
toward Cabot, AR. At the 2nd Cabot exit merge onto Hwy 5 toward Heber Springs,
AR. Hwy 5 merges with Hwy 25 connue toward the Hwy 25/16 juncon.
Connue straight (le) onto Hwy 16 toward Pangburn, AR. Good Springs Rd is o
Hwy 16 on the right. Connue on Good Springs Rd taking the 1st right onto Pine
Snag Rd. Connue to a fork in the road turning right onto Price Ford Rd. XTO
Energy's Lonesome Duck Farms & Ballew lease roads are on the le & indicated
with signs. The lease road for Ballew #1-22H is on
Close this window Print this page
3/16/2015 9:28 PM
RE:
Ms. Weathers:
On April 3, 2012 I performed a follow-up inspection of the above referenced well site & associated pit in
accordance with the provisions of the Arkansas Water & Air Pollution Control Act and the regulations
promulgated thereunder as well as AOGCs Rule B-17. At the time of the inspection, the well site &
associated pit were in compliance with the provisions of the Arkansas Water & Air Pollution Control Act
and the associated regulations as well as AOGCs Rule B-17.
Please refer to the comments section of the inspection form for notes regarding any areas of
concern that may have been observed at the above referenced site. Furthermore, I have
contacted Brooke Shaw by email in regards to any potential issues concerning this site.
Kerri McCabe
Oil & Gas Field Inspector
Water Division
501-683-2789
mccabe@adeq.state.ar.us
cc:
Oil-based
Completion
Producing
Air/Mist
SECTION B: Stormwater Erosion & Sediment Controls of the Well Pad & Lease Road
Y N NA NE
1. Is there evidence of sediment runoff from the well site or lease road observed in waters of the State?
2. At the time of the inspection was there any evidence observed of Reg. 2 water quality standards being exceeded (i.e., turbidity, sedimentation,
etc.)?
Y N NA NE
3. Has the Operator implemented erosion & sediment controls to minimize sediment runoff from occurring?
Y N NA NE
4. After further evaluation has the Operator prepared a storm water erosion & sediment control plan or guidance document? Note: XTO has
submitted RAPPS to ADEQ
5. Does it appear that the erosion & sediment controls are being maintained & are in good operating condition? Note: temporary BMPs around
closed pit area
Y N NA NE
6. During the time of the inspection was there evidence that the well site &/or pit had any fluid discharges (i.e., spills/leaks)?
Y N NA NE
Y N NA NE
Y N NA NE
a. If there was evidence of a discharge were the fluids/solids properly contained, cleaned & disposed of?
b. Has the discharge been reported to ADEQ/AOGC?
7. Did any rerouting, filling or channelization of any water of the State occur during well site or lease road construction? Note: nearest waterbody
is an unnamed, intermittent tributary of Big Creek
a. Was proper authorization received (i.e., Short-term Activity Authorization)? Note: STAA on file (separate inspection report)
b. Is there evidence of any Reg. 2 water quality standard violations due to construction of the well pad or lease road?
8. Does it appear that chemicals used during the drilling process & after well completion are being stored properly? Note: permanent, lined berm
& plastic troughs
Y N NA NE
Y N NA NE
Y N NA NE
Y N NA NE
Y N NA NE
Y N NA NE
2. At the time of the inspection did it appear the pit(s) met the construction requirements as required by AOGC Rule B-17 Section (f), Items (2) &
(3)?
Y N NA NE
3. If containers were used for circulation/mud pits (i.e., close-loop system) were they being maintained in a leak-free state?
4. During the inspection was the pit(s) constructed with the appropriate liner (i.e., 20mil synthetic liner, compacted-clay liner &/or bentonite liner)?
Y N NA NE
Y N NA NE
5. At the time of inspection was the reserve pit(s) structurally sound & capable of containing the pits contents (i.e., cracks/holes in levees &/or
tears/holes in liners)?
Y N NA NE
6. During the inspection was a 2ft-minimum freeboard being maintained in the pit?
Y N NA NE
7. At the time of inspection did the pit contain unapproved fluids or materials (i.e., waste oil, hydraulic or completion fluids, trash &/or any
Nonhazardous O&G Waste)?
Y N NA NE
8. After further evaluation was the reserve pit determined to be part of a Frac Flowback Water Recycling Program?
Y N NA NE
Y N NA NE
Y N NA NE
Y N NA NE
Y N NA NE
Y N NA NE
Comments: There is NO reserve pit onsite. The Operator was in the process of closing the pit during the inspection. BMPs were in place & being maintained around
the former pit location. The well site is establishing vegetation & the surrounding area is also well-vegetated (timber). There is one active well onsite & the produced
water tank is within a permanent, lined berm. AOGCs Form 2A is on file for General Permit# 02122-WG-P; however, the Operator has not submitted AOGCs Form 2B.
PDS #065309
Ballew #1-22H from Hwy 16 off Price Ford Rd about 6.6 miles WxSW of
Pangburn, AR
Photo #
Of
Description:
Date:
04-03-12
Time:
1134
Time:
1143
Site identification
Description:
Photo #
Witness: Lance B.
Of
Witness: Lance B.
Date:
04-03-12
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):
May 7, 2012
Heather Meek
Regulatory Analyst
XTO Energy, Inc.
211 Pangburn Rd
Heber Springs, AR 72543
Complaint Investigation of XTO Energys Ballew #1-22H Reserve Pit in
Pangburn, AR (Cleburne Co.); reserve pit discharge from Nov 2011 &
improper reserve pit closure
RE:
Ms. Meek:
On April 3, 2012 I performed an investigation of the Ballew #1-22H production pad & reserve pit
in response to a complaint received by ADEQs Water Division. The complainant allegedly
observed the reserve pit fluids discharge into surface waters in November 2011 as well as
witnessed the improper closure of the reserve pit on April 2, 2012. At the time of the
investigation, no violations were observed.
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 Brooke Shaw by email with any potential issues regarding
this site.
If you should have any questions, feel free to contact me at 501-683-2789 or via email
mccabe@adeq.state.ar.us
Kerri McCabe
Oil & Gas Field Inspector
Water Division
cc:
AFIN#: 12-00000
ADDRESS:
N/A
ADDRESS:
211 Pangburn Rd
Heber Springs, AR 72543
PHONE: 501-551-5515
FAX: N/A
PERMIT#: N/A
FAX: N/A
SUPERVISOR REFERRAL:
Steve Johnson
DATE:
April 2, 2012
DATE:
April 2,
2012
INSPECTOR REFERRED:
Kerri McCabe
DATE:
April 2, 2012
DATE:
DATE:
RECEIVING INSPECTOR:
Kerri McCabe
DATE:
04-02-12
FAX
AFIN #: 12-00000
ACTION TAKEN:
Initially, I spoke with Ms. Ballew at length about the issues she was having with the production pad
located on her property (4-3-12). She was mainly concerned with trash left by the contractors & lowlevels of NORM indicated in water samples collected by ADH as well as improper reserve pit closure. I
told her I had been to the site in late Feb 2012 & the pit fluids were well below the minimum freeboard
requirements. I informed her that I had walked the entire length of the pipeline ROW, and thats when
she told me she didnt have issues with the pipeline ROW but the original lease road. Apparently, the
contractor originally started construction of a lease road on Ms. Ballews property & then decided to put
the lease road on Mr. Waldos property. The contractor had apparently left windrowed trees & disturbed
soil along the original lease road route. I told her I could not address the trash or events that occurred in
Nov 2011, but that I would re-visit the site during the pit closure. She was concerned about them
removing the liner because of the low-levels of NORM indicated in samples taken by ADH. I informed
her that removing the liner was standard practice & can result in violations if not removed. I told her all
fluids were to be removed to the fullest extent, but that solids could be buried onsite if pre-approved by
ADEQ (kiln dust/fly ash method).
I arrived onsite later in the day & the pit was still being graded/contoured. I spoke with Mr. Lance B.
while onsite. He informed me that the liner was being taken to Rolling Meadows Landfill in Hazen, AR.
He said that JM Oilfield Services had hauled the reserve pit contents (location unknown at this time).
Silt fence was installed around the former reserve pit area. Ms. Brooke Shaw with XTO Energy informed
me that the reserve pit contained shallow groundwater & stormwater. XTO Energy did not use the
reserve pit during a Frac Flowback Reuse program. Also, I inspected the lease road (separate report). I
did not investigate the original route because that activity occurred on private property & I could not see
any indication of the activity from the production pad or pipeline ROW.
Page
INSPECTOR SIGNATURE:
Page
Location:
Kerri McCabe
Photographer:
Photo #
Kerri McCabe
Photographer:
Description:
Date:
Lance B.
04-03-12
Time:
1134
Site Identification
Description:
Photo #
Of
Witness:
Of
Witness:
Date:
Lance B.
04-03-12
Time:
1143
Page
Location:
Kerri McCabe
Photographer:
Photo #
Kerri McCabe
Photographer:
Description:
Date:
Lance B.
04-03-12
Time:
1143
Removed liner on production pad; going to Rolling Meadows Landfill (Hazen, AR)
Description:
Photo #
Of
Witness:
Of
Witness:
Date:
Lance B.
04-03-12
Time:
1144
Silt fence along intermittent stream near reserve pit location; vegetation establishing
Page
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):
Page
Due to the excessive nature of the above-mentioned item as well as the impact the
intentional discharges have had on the environment and may continue to have on the
environment, the aforementioned item(s) requires your immediate attention. Based upon
the inspection findings, this matter has been referred to the Enforcement Branch of the
Water Division.
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 e-mailed to Water-Inspection-report@adeq.state.ar.us 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 August 13, 2012.
If I can be any assistance, please contact me at mccabe@adeq.state.ar.us or 501-682-0642.
Sincerely,
Kerri McCabe
Oil & Gas Field Inspector Supervisor
Water Division
cc:
ADDRESS:
XTO Energy, Inc.
211 Pangburn Rd
Heber Springs, AR 72543
ADDRESS:
211 Pangburn Rd
Heber Springs, AR 72543
PHONE: 501-757-0967
FAX: N/A
DATE:
June 28,
2012
INSPECTOR REFERRED:
FAX: N/A
SUPERVISOR REFERRAL:
DATE:
DATE:
DATE:
DATE:
RECEIVING INSPECTOR:
Kerri McCabe
DATE:
June 28,
2012
Since June 14, 2012 XTO Energy has self-reported several intentional discharges believed to be performed by a
third party contractor paid to haul E&P wastes generated from natural gas production sites. The first self-report
by XTO Energy was at the OB Moss #1-32H production pad in Cleburne Co (investigated by Robert Long).
Subsequently, XTO Energy began to identify several discharge sites at various production pads &/or lease roads
issued to the contractor. XTO Energy has taken preliminary soil samples from each possible discharge site at 20
different locations within four counties. These results have been provided to ADEQs Emergency Response
(Michael Parette). The soil sample results indicate excessive chloride concentrations (greater than 3000ppm)
compared to background levels, which is an indicator of frac flowback &/or produced fluids.
Page
FAX
ACTION TAKEN:
ADEQ O&G Field Inspector Robert Long & I conducted a total of nine investigations at locations reported by
XTO Energy. The locations were believed to be possible sites where a third party contractor intentionally
discharged E&P wastes onto the ground or within waters of the state. These sites encompassed four different
counties within watersheds designated by ADEQ as ERWs. At least one site from each county was
investigated to represent the individual county. The sites varied in time from discharge (within 24 hours & as
long ago as 8 months); however, XTO Energy conducted soil samples at each potential discharge location as
well as sampled from point source to furthest distance from point source that was potentially impacted. XTO
Energy took background soil samples to get an idea of the chloride concentrations in the areas. Due to the
fact that E&P wastes such as frac flowback & produced fluids are high in chlorides, XTO Energy tested for
chlorides only. Preliminary results from the soil samples taken at some sites indicate that chloride levels
exceed 3000ppm, which is an acceptable concentration for permitted land application sites approved by
ADEQ. It should be noted that frac flowback as well as produced water are not acceptable for land
application and can only be disposed of at approved facilities (i.e., commercial/non-commercial injection
wells, reuse during hydraulic fracturing, etc.). XTO Energy is responsible for the containment, removal,
transportation & disposal of all E&P wastes generated during natural gas drilling & completions.
Joel Dunlap was able to direct me to discharge sites at the locations investigated. The areas were
distinguished by eroded spots where hosing had been placed and high pressure & volume had caused the soil
to be displaced as well as discoloration to substrate (rusty color). Vegetation had died where E&P wastes had
pooled.
Page
DATE:
July 23, 2012
Page
Sammie Smith #1,2-15H from Hwy 310 off Morris School Rd about 3.4 miles SXSW of Letona, AR
(White Co)
Kerri McCabe
Photographer:
Photo #
Of
14
Witness:
Date:
Time:
Description:
Photographer:
Kerri McCabe
Photo #
Description:
Of
14
Witness:
Date:
1326
Time:
1327
Page
Sammie Smith #1,2-15H from Hwy 310 off Morris School Rd about 3.4 miles SXSW of Letona, AR
(White Co)
Kerri McCabe
Photographer:
Photo #
Of
14
Witness:
Date:
Time:
Description:
Photographer:
Kerri McCabe
Photo #
Description:
Of
14
Witness:
Date:
1328
Time:
1329
Page
Glass #1,2,3,4-28H from Hwy 36 off Foster Chapel Rd about 2.1 miles NE of Center Hill, AR (White
Co)
Kerri McCabe
Photographer:
Photo #
Of
14
Witness:
Date:
Description:
Photographer:
Kerri McCabe
Photo #
Description:
Of
14
Witness:
Date:
Time:
1408
Time:
1415
Eroded area where high pressure & volume displaced sediment; behind produced water tank
Page
Glass #1,2,3,4-28H from Hwy 36 off Foster Chapel Rd about 2.1 miles NE of Center Hill, AR (White
Co)
Kerri McCabe
Photographer:
Photo #
Of
14
Description:
Photographer:
Kerri McCabe
Photo #
Description:
Of
14
Witness:
Date:
Witness:
Date:
Time:
1415
Time:
1416
Page
Moffitt #1,2,4,5,6-32H from Hwy 36 off Bloodworth Rd about 0.6 miles N of Center Hill, AR (White
Co)
Kerri McCabe
Photographer:
Photo #
Of
14
Witness:
Date:
Description:
Photographer:
Kerri McCabe
Photo #
Description:
10
Of
14
Witness:
Date:
Time:
1435
Time:
1433
Eroded area from high pressure & volume displacing sediment; behind produced water tank
Page 10
Tanner #1,2,3,4-31H from Hwy 36 off Tanner Rd about 0.7 miles NW of Center Hill, AR (White Co)
Kerri McCabe
Photographer:
Photo #
11
Of
14
Witness:
Date:
07-03-12
Description:
Photographer:
Kerri McCabe
Photo #
Description:
12
Of
14
Witness:
Date:
Time:
1129
Time:
1132
Eroded area from high pressure & volume displacing sediment; behind produced water tank
Page 11
Barnett #1-32H from Hwy 107 off Tanyard Rd about 5.0 miles NW of Enola, AR (Faulkner Co)
Kerri McCabe
Photographer:
Photo #
13
Of
14
Witness:
Date:
Robert Long
07-09-12
Description:
Photographer:
Kerri McCabe
Photo #
Description:
14
Of
14
Witness:
Date:
Time:
0939
Robert Long
07-09-12
Time:
0943
Page 12
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):
Page 13
Douglas C. Schultze
Vice President of Operations
XTO Energy, Inc.
210 Park Avenue, Suite 2350
Oklahoma City, OK 73102
RE:
XTO Energy
August 22, 2012
Page 2
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
501-682-0642 or you may e-mail me at mccabe@adeq.state.ar.us
Sincerely,
Kerri McCabe
O&G Field Inspector Supervisor
Water Division
cc:
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ADEQ
Details for Inspecon Number 067566
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Inspecon Date:
File List:
AFIN:
Permit Number:
Media:
Name:
County:
Address:
08/17/2012
067566-INSP.pdf (/proot/Pub/WebDatabases/InspeconsOnline/067566INSP.pdf)
1200000
WS - Water-SPB
XTO ENERGY
Cleburne
BALLEW 1-22H
210 PARK AVE, STE 2350
OKLAHOMA CITY, OK 73102
Latude:
Longitude:
35.402670
-91.950489
Inspecon Reason:
Inspecon Status:
Inspecon Type:
Compliance Status:
Total Inspecon Score:
Scheduled
Completed
Compliance
In Compliance
3/16/2015 9:24 PM
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