Document 4J21V0Gn16NEaoMYozbQD07nR

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 05/20/2025 Water (CWA) NPDES Offshore Program Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: W&T Offshore VI, LLC A / Virgo Facility (Permitted Feature 0008) Viosca Knoll 823 at 29.1819N, -88.1677W Gulf of America - U.S. Federal Waters 5718 Westheimer Rd, Suite 700 Houston, TX 77057 Orleans Parish (713) 624-7338 John C. Poole Vice President, HSE&R jpoole@wtoffshore.com Complex ID: Identification/Permit Number: OSC Lease: BSEE Inspection ID No.: Facility Description: 113 GMG290382 G10942 553203928 A fixed platform Personnel participating in inspection: Kerri McCabe (lead) EPA / Region 6 ECDW Michael Blaha EPA / Region 6 ECDW Ronald McClary BSEE / GOA OCS Region Eddy Burger W&T Offshore VI, LLC Inspector / Enforcement Officer Inspector / Enforcement Officer Water Quality Coordinator, Engineer Facility Point of Contact EPA Lead Inspector Signature/Date Supervisor Signature/Date KERRI MCCABE Kerri McCabe Digitally signed by KERRI MCCABE Date: 2025.06.18 10:49:12 -05'00' Date JEANNE ECKHART Date: 2025.06.18 12:48:19 -05'00' Digitally signed by JEANNE ECKHART Jeanne Eckhart Date 6ENFORM-019-R8.2 (02/12/2020) 1 W&T Offshore VI, LLC (GMG290382) - A / Virgo Facility (PF 0008) / CWA NPDES Inspection Date 05/20/2025 Section I - INTRODUCTION PURPOSE OF THE INSPECTION Environmental Protection Agency (EPA) Region 6 inspectors Kerri McCabe (lead) and Michael Blaha and Bureau of Safety and Environmental Enforcement (BSEE) inspector Ronald McClary arrived at the W&T Offshore VI, LLC ("W&T") - A / Virgo Facility at 11:30 am on 05/20/2025, for an announced Compliance Evaluation Inspection (CEI) of the EPA National Pollutant Discharge Elimination System (NPDES) general permit GMG290000 and the BSEE Pollution Prevention and Control Regulations. After initial facility entry, we met with the facility point of contact (PIC) Eddy Burger. The W&T point of contact is Deepu Dethan at ddethan@wtoffshore.com. All observations recorded for this inspection were stated verbally by the facility personnel in the inspection interview, obtained from the facility written records, or obtained from records submitted to EPA and contained on the data website entitled the Integrated Compliance Information System (ICIS). Background information in support of this report was obtained from the Technical Information Management System (TIMS) database maintained by BSEE and the Bureau of Ocean Energy Management (BOEM) and the United States Coast Guard (USCG) National Response Center (NRC) reporting system reviewed by BSEE daily. FACILITY DESCRIPTION The A / Virgo Facility (Complex ID No. 113) is a fixed platform installed in 1999 and operated by W&T Offshore VI, LLC. The facility is located in Viosca Knoll 823 lease block, approximately 50 miles offshore from Louisiana's coast, at an approximate water depth of 1,130 feet. The facility presently supports oil and gas processing equipment, pumping equipment, fuel and chemical storage, and living quarters. This facility processed, on average, approximately 360 BOPD, 285 BWPD, and 5 MMSCF/day. The facility is manned 24/7 and houses approximately 16 personnel during normal operations. Map 1. Google Earth aerial image dated 12/31/2020 of the W&T Offshore VI, LLC - A / Virgo Facility location. 2 W&T Offshore VI, LLC (GMG290382) - A / Virgo Facility (PF 0008) / CWA NPDES Inspection Date 05/20/2025 The EPA general permit number for W&T Offshore VI, LLC is GMG290382 and the Discharge Monitoring Report (DMR) Permitted Feature ID number for this platform is 0008, with the facility name "A / Virgo." W&T submits DMR to EPA for the following Limit Set Designators: A / Virgo Facility (Permitted Feature 0008): Maintenance Best Management Plan (BMP) (BM) Chemically Treated Waters (CT) Deck Drainage (DD) Domestic Waste (DW) Miscellaneous Discharges (Includes Packer Fluids & Pipeline Brine) (MD) Produced Water Monthly Toxicity (PM) Produced Water (PR) Sanitary Waste (SW) There is no requirement for a CW (cooling water intake) Limit Set Designator reporting to EPA due to the age of the facility. The CW limit set applies if the facility was constructed after July 17, 2006. Section II - SUMMARY OF BSEE INSPECTION The inspection consisted of: An interview of personnel about their work practices and procedures, A records review of facility data and observation logs, A review of the reporting history to EPA for facility discharge data and values based on the facility raw data records and the certified values reported on official DMRs to EPA, An observation of any in-house, on-site procedures, and methodology, A review of facility plans and documentation, A review of the facility's Uniform Waste Manifests for removal of materials and solids from the facility for proper disposal, A review of the facility spill and release history from NRC reports, A review of BSEE environmental enforcement actions, A facility tour and review of general housekeeping practices, with an emphasis on viewing containment and treatment systems utilized, including the facility's Marine Sanitation Device (MSD; see Photos No. 1 through No. 3), floatation cell (see Photos No. 4 through No. 6), and deck sump (see Photos No. 8 and No. 9). EPA and BSEE also discussed and observed W&T personnel collect a produced water oil and grease sample (see Photo No. 7). Section III - AREAS OF CONCERN During this inspection, BSEE observed the following inspection findings related to the environmental compliance of this facility: 1.) Inspection findings for "Onsite Records for Produced Water Discharges" are as follows: W&T had incomplete Chains of Custody [COC; Part I, Section B, Note 2 (40 CFR 136)], Most oil and grease samples reviewed for the focus period (07/01/2023-02/28/2025) were received by the lab with a pH value greater than 2 standard units (s.u.). [Part I, Section B, Note 2 (40 CFR 136)], 3 W&T Offshore VI, LLC (GMG290382) - A / Virgo Facility (PF 0008) / CWA NPDES Inspection Date 05/20/2025 The November 2024 lab report notates that the COC was not received with the sample; the lab received COC later from the facility [Part I, Section B, Note 1 (40 CFR 136)], The records maintained by the operator are not consistent in the way that produced water discharges are reported. The operator is reporting either "no sheen" or "no discharge" as documentation of monitoring. If there is no discharge, there is no sheen to report. "No sheen" should be used during produced water discharges to document the presence/absence of sheen events (Part I, Sec. B, 4, b, Visual Sheen), Multiple DMR produced water monthly averages are incorrect (Part II, Section D, 4), and The facility failed to analyze produced water temperatures for multiple months (Part I, Section B, 4, b). 2.) Inspection finding for "Sandblasting and Maintenance Plan" is as follows: The BMP Plan will need the 5-year review/revision at the end of 2025 (Part II, Section B, 2, c, 2, Best Management Practices, d). 3.) Inspection findings for "Operator Competency in Sample Collection and Preservation Requirements" are as follows: Facility personnel are unfamiliar with sheen sampling protocols, and the facility did not have any sheen sampling bottles onsite (Part I, Section B, 4, b; Part II, Sec. B, 3, a), Facility personnel analyze the temperature of the produced water samples by placing the thermometer directly in the lab sample [Part I, Section B, Note 1 (40 CFR 136)], and The facility does not use custody seals on the produced water samples submitted to the lab [Part I, Section B, Note 1 (40 CFR 136)]. Section IV - LIST OF APPENDICES Appendix 1 - Photograph Log - 9 photos taken 05/20/2025. _____________________________________________________________________________________ The official inspection report, completed by BSEE, has been sent to the U.S. EPA Region 6. Once received, the assigned enforcement officer will evaluate the report for any compliance issues and determine if an enforcement action is necessary. 4 W&T Offshore VI, LLC (GMG290382) - A / Virgo Facility (PF 0008) / CWA NPDES Inspection Date 05/20/2025 Appendix 1 Photograph Log 9 Photos UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: A / Virgo platform in Viosca Knoll 823 at 29.1819N, -88.1677W City: New Orleans County/Parish: Orleans Parish State: Louisiana (GOA) Photo File Name: 100-0977 Orientation: 266 W Date of Photo: 05/20/2025 Time of Photo: 1151 Latitude: 29.181733 Longitude: -88.167583 Photographer: Kerri McCabe Description: Looking W, this photo shows the manufacture's plate for the Marine Sanitation Device (MSD). Note: this is not the same as the USGS plate. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: A / Virgo platform in Viosca Knoll 823 at 29.1819N, -88.1677W City: New Orleans County/Parish: Orleans Parish State: Louisiana (GOA) Photo File Name: 100-0978 Orientation: 280 W Date of Photo: 05/20/2025 Time of Photo: 1151 Latitude: 29.181733 Longitude: -88.167550 Photographer: Kerri McCabe Description: Looking W, this photo shows an overview of the Type II MSD. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: A / Virgo platform in Viosca Knoll 823 at 29.1819N, -88.1677W City: New Orleans County/Parish: Orleans Parish State: Louisiana (GOA) Photo File Name: 100-0979 Orientation: 357 N Date of Photo: 05/20/2025 Time of Photo: 1152 Latitude: 29.181718 Longitude: -88.167565 Photographer: Kerri McCabe Description: Looking N, this photo shows the tablet chlorinator for the MSD; chlorine tablets are present. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: A / Virgo platform in Viosca Knoll 823 at 29.1819N, -88.1677W City: New Orleans County/Parish: Orleans Parish State: Louisiana (GOA) Photo File Name: 100-0980 Orientation: 51 NE Date of Photo: 05/20/2025 Time of Photo: 1156 Latitude: 29.182267 Longitude: -88.167467 Photographer: Kerri McCabe Description: Looking NE, this photo shows the floatation cell used to separate fine oil droplets from produced water at the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: A / Virgo platform in Viosca Knoll 823 at 29.1819N, -88.1677W City: New Orleans County/Parish: Orleans Parish State: Louisiana (GOA) Photo File Name: 100-0982 Orientation: 336 NNW Date of Photo: 05/20/2025 Time of Photo: 1156 Latitude: 29.182300 Longitude: -88.167350 Photographer: Kerri McCabe Description: Looking NNW, this photo shows an additional view of the floatation cell at the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: A / Virgo platform in Viosca Knoll 823 at 29.1819N, -88.1677W City: New Orleans County/Parish: Orleans Parish State: Louisiana (GOA) Photo File Name: 100-0983 Orientation: 219 SW Date of Photo: 05/20/2025 Time of Photo: 1157 Latitude: 29.182366 Longitude: -88.167383 Photographer: Kerri McCabe Description: Looking SW, this photo shows an additional view of the floatation cell at the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: A / Virgo platform in Viosca Knoll 823 at 29.1819N, -88.1677W City: New Orleans County/Parish: Orleans Parish State: Louisiana (GOA) Photo File Name: 100-0984 Orientation: 101 ESE Date of Photo: 05/20/2025 Time of Photo: 1202 Latitude: 29.182150 Longitude: -88.167250 Photographer: Kerri McCabe Description: Looking ESE, this photo shows a produced water sample taken from the floatation cell for the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: A / Virgo platform in Viosca Knoll 823 at 29.1819N, -88.1677W City: New Orleans County/Parish: Orleans Parish State: Louisiana (GOA) Photo File Name: 100-0985 Orientation: 176 S Date of Photo: 05/20/2025 Time of Photo: 1208 Latitude: 29.181750 Longitude: -88.167833 Photographer: Kerri McCabe Description: Looking S, this photo shows the deck sump for the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 Location: A / Virgo platform in Viosca Knoll 823 at 29.1819N, -88.1677W City: New Orleans County/Parish: Orleans Parish State: Louisiana (GOA) Photo File Name: 100-0987 Orientation: 179 S Date of Photo: 05/20/2025 Time of Photo: 1208 Latitude: 29.181750 Longitude: -88.167818 Photographer: Kerri McCabe Description: Looking S, this photo shows the secondary containment and drainpipe for the deck sump.