Document R4wYLk2n29pv9n8818mJaOEE

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 08/09/2024 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 Energy VI, LLC A / Matterhorn Platform (Permitted Feature 0005) Mississippi Canyon 243 A at 28.7423 degrees N, 88.8254 degrees W Gulf of Mexico - U.S. Federal Waters 5718 Westheimer Rd, Suite 700 Houston, TX 77057 Harris County (713) 624-7338 Steve Hamm VP HSE & R shamm@wtoffshore.com Complex ID: Identification/Permit Number: OSC Lease: BSEE Inspection ID No.: Facility Description: 1088 GMG290382 G19931 508808543 A Mini Tension Leg platform Personnel participating in inspection: Kerri McCabe EPA / Region 6 ECDW Mitty Garcia (lead) EPA / Region 6 ECDW Ronald McClary BSEE / Gulf of Mexico OCS Region Kimberly Ward BSEE / Gulf of Mexico OCS Region Inspector / Enforcement Officer Offshore Coordinator Water Quality Coordinator, Engineer Water Quality Coordinator, Engineer EPA Lead Inspector Signature/Date Supervisor Signature/Date KERRI MCCABE Kerri McCabe Digitally signed by KERRI MCCABE Date: 2024.11.27 09:24:55 -06'00' Date JEANNE ECKHART Date: 2024.11.27 09:56:55 -06'00' Digitally signed by JEANNE ECKHART Jeanne Eckhart Date 6ENFORM-019-R8.2 (02/12/2020) 1 Section I - INTRODUCTION W & T Energy VI, LLC (GMG290382) - A / Matterhorn (PF 0005) / CWA NPDES Inspection Date 08/09/2024 PURPOSE OF THE INSPECTION USEPA Region 6 inspectors Mitty Garcia (lead) and Kerri McCabe and Bureau of Safety and Environmental Enforcement (BSEE) inspectors Ronald McClary and Kimberly Ward arrived at the W & T Offshore, LLC (W & T) - Matterhorn Platform A facility at 9:05am on August 9, 2024, for an unannounced Compliance Evaluation Inspection (CEI) of the EPA NPDES general permit GMG290382 and the BSEE Pollution Prevention and Control Regulations. After initial facility entry, we met with the facility operator Shannon Whitaker. W & T contact is Shannon Whitaker at swhitaker3@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 USEPA and contained on their data website entitled the Integrated Compliance Information System (ICIS). Background information in support of this report was also obtained from the Technical Information Management System (TIMS) database maintained by BSEE and BOEM and the USCG National Response Center (NRC) reporting system reviewed by BSEE daily. FACILITY DESCRIPTION MC 243 Matterhorn Platform A Facility (Complex ID No. 1088) is a Mini Tension Leg platform installed in 2003 operated by W & T Offshore, LLC. The facility is located in Mississippi Canyon 243, approximately 30 miles offshore from Louisiana's coast, at an approximate water depth of 2,850 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 400 BOPD, 800 BWPD, and 195 SCF/day of gas. The facility is manned 24/7 and houses approximately 27 personnel during normal operations. The EPA general permit number for W & T Energy VI, LLC is GMG290382 and the Discharge Monitoring Report (DMR) Permitted Feature ID number for this platform is 0005. EPA assigned the DMR Limit Set Name for this facility as A Facility. For reporting, EPA has assigned DMR Limit Set Designators as follows: A / Matterhorn Platform (Permitted Feature 0005): BMP (Maintenance Best Management Plan) DD (Deck Drainage) DW (Domestic Waste) MD (Miscellaneous Discharges - Includes Packer Fluids & Pipeline Brine) PM (Produced Water Monthly Toxicity) PR (Produced Water) SW (Sanitary Waste) There is a no requirement for a CW (cooling water intake) Limit Set Designator reporting to EPA due to the age of the facility. 2 W & T Energy VI, LLC (GMG290382) - A / Matterhorn (PF 0005) / CWA NPDES Inspection Date 08/09/2024 Section II - SUMMARY OF INSPECTION The inspection consisted of: An interview of personnel as to their work practices and procedures, A thorough 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, A partial 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 testing result reports, chain-of-custody forms and sampling procedures, A review of the facility spill and release history from NRC reports, A review of BSEE environmental enforcement actions, and A partial facility tour and review of general housekeeping practices, with a special emphasis on viewing containment and any treatment systems utilized. Section III - OBSERVATIONS During this inspection, there were observed areas of potential concern related to the environmental compliance of this facility: June 2024 monthly oil and grease sample result missing from the NPDES Discharge Monitoring Report, Multiple potential bypass lines were present with many having connectors located near or directly below connection valves in pipes and some leading directly into deck drains, Facility's produced water treatment system was offline at the time of inspection and was using a temporary CETCO activated carbon treatment system, Confusion amongst the operators regarding the sampling requirements and the responsible party for sampling the temporary CETCO wastewater treatment unit, and Facility personnel were not familiar with NPDES general permit requirements for sampling methods and locations. _____________________________________________________________________________________ The official inspection report, completed by BSEE, will be sent to the U.S. EPA Region 6 within the next few weeks. Once received, the assigned enforcement officer, will evaluate the report for any compliance issues and determine if an enforcement action is necessary. 3