Boyd Fugo ServicesLLC No Discharge Industrial Report Page 2 - PDF document

1 Boyd, Fugo Services,LLC. No Discharge In
Boyd, Fugo Services,LLC. No Discharge Industrial Report Page 2 se contact me at 479-452-4822 ext. 11 Sincerely, District 4 Field Inspector Water Division cc: Water Division Enforcement Branch Water Division Permits Branch ADEQ Water Industrial No Discharge AFIN: 24-00202 4500-W No Discharge Industrial Report Page 3 ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY NO DISCHARGE INDUSTRIAL PERMIT INSPECTION FORM AFIN: 24-00202 Log No.: N/A Permit No.: 4500-W Inspection Date: October 10, 2008 Media: Water Inspector: Jeff Tyler Compliance Status: 1A. Name of Facility: Fugo Services, LLC. Address: Hwy. 309 near Roseville County: Franklin 2A. Name of On-Site Representative:

2 None 3A. Name of Responsible Offici
None 3A. Name of Responsible Official: Justin Boyd Address: P.O. Box 1492 McAlister, OK Telephone: 405-831-1758 4A. Parent Company: N/A Address: N/A Telephone: N/A uding type of industry, materials produced, and major by- 5A. products): Land application site for drilling fluids from reserve pits. 6A. Any complaints registered against this permitted facility? No description of complaint: Arkansas Oil and Gas Commission contacted me by email and stated that I mi 7A. corrections to the facility since the last inspection? Yes No If yes, explain: Frac Tanks have been added to the site. ADEQ Water Industrial No Discharge AFIN: 24-00202 4500-W No Discharge Industri

3 al Report Page 4 1B. Furnish a simpl
al Report Page 4 1B. Furnish a simplified flow diagram of the treatment system and include main components, flow sequence through plant, and calculated or estimated flows. N/A 2B. Nearest Stream: Arkansas River 3B. Does wastewater from this facility cause adverse effect on the waters of the State: Yes No If yes, describe: 4B. as required by permit? Yes No N/E If no, explain: Operator was not available at the site. 5B. Are maintenance records kept as required by permit? Yes No N/A If no, explain: 6B. Are Samples routinely taken? Yes No N/E 7B. Does the sampling program meet the requirements of the permit? Yes No N/A

4 If no, explain: 8B. What l
If no, explain: 8B. What laboratory does the facility use? N/A Address: N/A Telephone: N/A ADEQ Water Industrial No Discharge AFIN: 24-00202 4500-W No Discharge Industrial Report Page 5 1C. Do laboratory procedures and records meet the requirements of the permit? Yes No N/A If no, explain: 2C. Is contaminated runoff a problem? Yes No N/A If yes, explain: There appears to be runoff from the land application field draining to an existing fresh water pond on the site. 3C. Is sludge disposal required? Yes No N/A If yes, describe (including final destination): 4C. Is the treatment system being properly operated and maintained as required by perm

5 it? Yes No N/A If no, expl
it? Yes No N/A If no, explain It was apparent that fluids are no land application fields and runoff from frac tank area is draining to a pond. SUMMARY OF FINDINGS/COMMENTS ontainment. Fugo Services March 11, 2008, response letter stated that the frac tanks would be located within a secondary containment berm. Runoff from this location response letter also stated that dikes would be built and setbacks met which would protect the pond. I did not observe any dikes or berms on evidence observed at the site, it appears that fluischarged to the fields rather than being spread evenly with a spreader bar. Coordinates: N 35û24’37.7” W 93 Inspector Signature: Jeff T

6 yler Date of Report: October 23, 2008
yler Date of Report: October 23, 2008 Signature of Reviewer: Date of Review: October 28, 2008 ADEQ Water Industrial No Discharge AFIN: 24-00202 4500-W No Discharge Industrial Report Page 6 Water Division No Discharge Industrial Photographic Evidence Sheet Location: Fugo Services, LLC.- Hwy. 309 near Roseville in Franklin County Photographer: Jeff Tyler Witness: None Photo # 1 Of 6 Date: 10-10-08 Time: 1417 Description: View of frac tanks and application field at the site. Photographer: Jeff Tyler Witness: None Photo # 2 Of 6 Date: 10-10-08 Time: 1419 Description: Application field with apparent signs of heavy loading. ADEQ Water Industrial No Discharge AFIN: 24-00202 4500-W No Discharge Industria

7 l Report Page 7 Water Division No Disch
l Report Page 7 Water Division No Discharge Industrial Photographic Evidence Sheet Location: Fugo Services, LLC. Hwy. 309 near Roseville in Franklin County Photographer: Jeff Tyler Witness: None Photo # 3 Of 6 Date: 10-10-08 Time: 1427 Description: Evidence of runoff from frac tank storage area, with no containment draining west. Photographer: Jeff Tyler Witness: None Photo # 4 Of 6 Date: 10-10-08 Time: 1429 Description: Runoff with signs of drilling fluids draining down slope from frac tanks. ADEQ Water Industrial No Discharge AFIN: 24-00202 4500-W No Discharge Industrial Report Page 8 Water Division No Discharge Industrial Photographic Evidence Sheet Location: Fugo Services, LLC. Hwy. 309 near Roseville

8 in Franklin County Photographer: Jeff
in Franklin County Photographer: Jeff Tyler Witness: None Photo # 5 Of 6 Date: 10-10-08 Time: 1432 Description: Runoff from frac tank storage area with signs of drilling fluids draining to fresh water pond. Photographer: Jeff Tyler Witness: None Photo # 6 Of 6 Date: 10-10-08 Time: 1458 Description: Application field with 4 inch hose and apparent evidence of direct discharge of drilling fluids. October 23, 2008 Justin Boyd Fugo Services, LLC. P.O. Box 1492 McAlister, OK 74502 RE: AFIN: 24-00202 Permit No.: 4500-W Dear Mr. Boyd: On October 10, 2008, I performed a routine compliance inspection of the waste treatment and disposal facility in accordance with the provisions of the Arkansas W

9 ater and Air Pollution Control Act and t
ater and Air Pollution Control Act and the regulations promulgate It was apparent from my inspecrds indicate that your mo 11, 2008, response letter you stated that all frac tanks would be located within secondary containment. rms within this area to protect this body of The above items require your immediate attention. Please submit a written response to these findings to the Water Division Enforcement Branch of this Department at the following address: Water Division Enforcement Branch Arkansas Department of Environmental Quality 5301 Northshore Drive North Little Rock, AR 72118-5317 This response should contain detailed documentacorrect the items noted. This corrective action shwritten response is due by November 14, 200

10 8. For additional information you ma
8. For additional information you may contact the enforcement branch by telephone at 501-682-0639 December 30, 2008 You may recall that at our December 4, 2008 meeting we discussed the Corrective Action Report (Order and Agreement, Paragraph 1) or Corrective Action Plan (Order and Agreement, Paragraph 2) Fugo will be required to submit under the proposed CAO. Though we are not including the October 10, 2008 inspection violations in the CAO, Fugo will need to make certain isions designed to eliminate those violations and prevent their taken the liberty of sending a copy of this letter and attachments to your consultant, Mr. Rob Stallings, with whom we met. Thank you for your attention to this matter. Shoulme by phone at 501-682-0

11 632 or e-mail at . Please remember to
632 or e-mail at . Please remember to refer to Permit No. 4500-W and AFIN 24-00202 in any written correspondence to this Department. Enforcement Administrator Enforcement Branch cc: Mr. Rob Stallings Envirotech Engineering & Consulting, Inc. Enid, OK 73701 December 30, 2008 Enid, OK 73702 RE: Permit No. 4500-W, AFIN 24-00202 Proposed Consent Administrative Order (CAO) Pursuant to our phone conversation this morning, I am enclosing the CAO we have tentatively agreed upon. I made the deletions we talked about during our December 4, 2008 meeting, and, al penalty amount of $9,300 is retained. If, after careful review and consultation you wish to accept the terms of the CAO, please sign, date, and return it by January 9, 2009 I

12 t will then be signed by our Director an
t will then be signed by our Director and you will be provided with a final copy along with information about the effectivto contact us by this date will constitute rejection of our settlement offer and we will proceed with unilateral enforcement I am also enclosing a copy of ADEQ Field reflect the address you gave me today, P.O. Box and submit a written response as directed As you and I discussed, ADEQ agrees to not adons will not be pursued in this enforcement this letter or in the enclosed CAO shall be construed as a waiver by ADEQ of its enforcement reserves the right to pursue enforcement for the violations from the Octcommit further violations warranting action by ADEQagreement to sign the CAO and pay the full $9,300 proposed penalty