On March 21, 2019, the U.S. Environmental Protection Agency inspected three oil leases located in Russell and Ellis Counties, Kansas. EPA?s inspection found SPCC non-compliance at each lease, plus evidence of 2 prohibited oil discharges. RP Nixon also operates approximately 90 oil leases in Kansas. The Order requires RP Nixon to take corrective actions to address SPCC violations at the 3 leases that EPA inspected, but additionally requires the company to take and make reports on corrective actions at all active production leases in Kansas.