Document RREk2YGbOnDx3gV0Q40aYkMa

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: KNOC Eagle Ford Corporation B / Simba Facility (Permitted Feature 0002) Mississippi Canyon 21 at 28.9373N, -88.912W Gulf of America - U.S. Federal Waters 5599 San Felipe Street, Suite 725 Houston, TX 77384 Orleans Parish (936) 828-6567 Karen Vanacor Regulatory and Environmental Manager kvanacor@ankorenergy.com Complex ID: Identification/Permit Number: OSC Lease: BSEE Inspection ID No.: Facility Description: 1482 GMG29062T G28351 553203957 A tension leg platform Personnel participating in inspection: Kerri McCabe (lead) EPA / Region 6 ECDW Michael Blaha EPA / Region 6 ECDW Ronald McClary BSEE / GOA OCS Region Josh French KNOC Eagle Ford Corporation 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: 2025.07.03 12:56:02 -05'00' Date JEANNE ECKHART Date: 2025.07.08 06:01:20 -05'00' Digitally signed by JEANNE ECKHART Jeanne Eckhart Date 6ENFORM-019-R8.2 (02/12/2020) 1 KNOC Eagle Ford Corp. (GMG29062T) - B / Simba Facility (PF 0002) / 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 KNOC Eagle Ford Corp. ("KNOC") - B / Simba Facility at 9:30 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), Josh French. The KNOC point of contact is Karen Vanacor at kvanacor@ankorenergy.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 B / Simba Facility (Complex ID No. 1482) is a tension leg platform installed in 2005 and operated by KNOC. The facility is located in Mississippi Canyon 21 lease block, approximately 30 miles offshore from Louisiana's coast, at an approximate water depth of 667 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 1,390 BOPD, 3,500 BWPD, and 889 SCF/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 KNOC Eagle Ford Corp. - B / Simba Facility location. 2 KNOC Eagle Ford Corp. (GMG29062T) - B / Simba Facility (PF 0002) / CWA NPDES Inspection Date 05/20/2025 The EPA general permit number for KNOC is GMG29062T and the Discharge Monitoring Report (DMR) Permitted Feature ID number for this platform is 0002, with the facility name "B / Simba." KNOC submits DMR to EPA for the following Limit Set Designators: B / Simba Facility (Permitted Feature 0002): BMP (Maintenance Best Management Plan) CT (Chemically Treated Waters) DD (Deck Drainage) DW (Domestic Waste) HF (Hydrate Control Fluids) MD (Miscellaneous Discharges - Includes Packer Fluids & Pipeline Brine) MT (Miscellaneous Discharges - Chemically Treated) PM (Produced Water Monthly Toxicity) PR (Produced Water) SW (Sanitary Waste) Well Treatment Fluids, Completion Fluids, Workover Fluids (TC) Well Fluids (WF) 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. 4 through No. 6) and floatation cell (see Photos No. 1 through No. 3). EPA and BSEE also discussed and observed KNOC personnel collect produced water oil and grease sample (see Photos No. 7 through No. 9). Section III - AREAS OF CONCERN During this inspection, BSEE observed the following "Facility Inspection Observations" related to the environmental compliance of this facility: 3 KNOC Eagle Ford Corp. (GMG29062T) - B / Simba Facility (PF 0002) / CWA NPDES Inspection Date 05/20/2025 1.) Inspection findings for "Conditions and Performance of Pollution Prevention and Control Systems and Methods" are as follows: The MSD did not have a legible USCG certification plate (Part I, Sec. B, 7, Exception), Deck drainage sheens were observed on 9/11/2023, 9/13/2023, and 2/21/2025 (Part I, Sec. B, 3, a Free Oil)*, and Facility had an uncontrolled bypass line for produced water treatment (Part II, Sec. B, 3, a)*. 2.) Inspection findings for "Operator Competency in Sample Collection and Preservation Requirements" are as follows: The operator did not describe or demonstrate the correct procedures used for sheen sample protocol (Part II, Sec. B, 3, b), The operator did not use proper custody seals for samples (Part I, Sec. B, Note 1-2; 40 CFR 136), and Incomplete chains of custody (COC; Part I, Sec. B, Note 1-2, 40 CFR 136). Section IV - LIST OF APPENDICES Appendix 1 - Photograph Log - 9 photos taken 05/20/2025. _____________________________________________________________________________________ *Requested clarification from BSEE on 07/03/2025 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 KNOC Eagle Ford Corp. (GMG29062T) - B / Simba Facility (PF 0002) / CWA NPDES Inspection Date 05/20/2025 Appendix 1 Photograph Log 9 Photos UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: B / Simba Facility (PF 0002) platform in Mississippi Canyon 21 at 28.9373N, -88.912W. City: New Orleans County/Parish: New Orleans State: Louisiana (GoA) Photo File Name: 100-0966 Orientation: N Date of Photo: 05/20/2025 Time of Photo: 0951 Latitude: 28.937800 Longitude: -88.911917 Photographer: Kerri McCabe Description: Looking N, this photo shows an overview of the flotation cell for the facility used to treat produced water. Note: metadata did not transfer from satellite system. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: B / Simba Facility (PF 0002) platform in Mississippi Canyon 21 at 28.9373N, -88.912W. City: New Orleans County/Parish: New Orleans State: Louisiana (GoA) Photo File Name: 100-0968 Orientation: NE Date of Photo: 05/20/2025 Time of Photo: 0951 Latitude: 28.937800 Longitude: -88.911917 Photographer: Kerri McCabe Description: Looking NE, this photo shows relief pipes at the flotation cell in case of emergency. Note: metadata did not transfer from satellite system. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: B / Simba Facility (PF 0002) platform in Mississippi Canyon 21 at 28.9373N, -88.912W. City: New Orleans County/Parish: New Orleans State: Louisiana (GoA) Photo File Name: 100-0970 Orientation: 229 SW Date of Photo: 05/20/2025 Time of Photo: 0952 Latitude: 28.937800 Longitude: -88.911917 Photographer: Kerri McCabe Description: Looking SW, this photo shows an additional view of the flotation cell used to treat produced water at the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: B / Simba Facility (PF 0002) platform in Mississippi Canyon 21 at 28.9373N, -88.912W. City: New Orleans County/Parish: New Orleans State: Louisiana (GoA) Photo File Name: 100-0971 Orientation: 305 NW Date of Photo: 05/20/2025 Time of Photo: 1000 Latitude: 28.937467 Longitude: -88.912917 Photographer: Kerri McCabe Description: Looking NW, this photo shows the marine sanitation device (MSD) utilized at the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: B / Simba Facility (PF 0002) platform in Mississippi Canyon 21 at 28.9373N, -88.912W. City: New Orleans County/Parish: New Orleans State: Louisiana (GoA) Photo File Name: 100-0972 Orientation: 356 N Date of Photo: 05/20/2025 Time of Photo: 1001 Latitude: 28.937467 Longitude: -88.912917 Photographer: Kerri McCabe Description: Looking N, this photo shows the manufacture's plate for the MSD used at the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: B / Simba Facility (PF 0002) platform in Mississippi Canyon 21 at 28.9373N, -88.912W. City: New Orleans County/Parish: New Orleans State: Louisiana (GoA) Photo File Name: 100-0973 Orientation: 344 NNW Date of Photo: 05/20/2025 Time of Photo: 1001 Latitude: 28.937467 Longitude: -88.912917 Photographer: Kerri McCabe Description: Looking NNW, this photo shows chlorine tablets inside the chlorinator for the MSD for the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: B / Simba Facility (PF 0002) platform in Mississippi Canyon 21 at 28.9373N, -88.912W. City: New Orleans County/Parish: New Orleans State: Louisiana (GoA) Photo File Name: 100-0974 Orientation: NE Date of Photo: 05/20/2025 Time of Photo: 1015 Latitude: 28.937467 Longitude: -88.911950 Photographer: Kerri McCabe Description: Looking NE, this photo shows the produced water sample kit supplied by the contract lab and the port used to collect the produced water sample from the flotation cell. Note: metadata did not transfer from satellite system. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: B / Simba Facility (PF 0002) platform in Mississippi Canyon 21 at 28.9373N, -88.912W. City: New Orleans County/Parish: New Orleans State: Louisiana (GoA) Photo File Name: 100-0975 Orientation: 45 NE Date of Photo: 05/20/2025 Time of Photo: 1016 Latitude: 28.937467 Longitude: -88.911950 Photographer: Kerri McCabe Description: Looking NE, this photo shows a produced water sample collected by the operator from the flotation cell that is used as monitoring (Oil & Grease Method 5520 C; not approved for reporting purposes). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 Location: B / Simba Facility (PF 0002) platform in Mississippi Canyon 21 at 28.9373N, -88.912W. City: New Orleans County/Parish: New Orleans State: Louisiana (GoA) Photo File Name: 100-0976 Orientation: 59 ENE Date of Photo: 05/20/2025 Time of Photo: 1017 Latitude: 28.937467 Longitude: -88.911950 Photographer: Kerri McCabe Description: Looking ENE, this photo shows the produced water sample with custody label that was collected from the flotation cell for the facility; sample to be analyzed by approved method (Oil & Grease Method(s) 5520 B or 5520 G-2021; 5520 B or 5520 G-2021 and 5520 F-2021).