Document ZnMRxKGrORwZzGr46a6zM2g8

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 03/11/2025 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: Shell Offshore, Inc. The Salsa - Production Facility (Permitted Feature 0025) Garden Banks 172 at 27.8403 degrees N, 91.9878 degrees W Gulf of America - U.S. Federal Waters P.O. Box 61933 New Orleans, LA 70161-1933 Orleans Parish (504) 425-4929 Morris J. Jones Senior Environmental Engineer Morris.Jones@shell.com Complex ID: Identification/Permit Number: OSC Lease: BSEE Inspection ID No.: Facility Description: 90014 GMG290103 G14221 546264166 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 Kimberly Ward BSEE / GOA OCS Region Inspector / Enforcement Officer Inspector / Enforcement Officer 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: 2025.04.02 14:02:57 -05'00' Date JEANNE ECKHART Date: 2025.04.03 11:51:41 -05'00' Digitally signed by JEANNE ECKHART Jeanne Eckhart Date 6ENFORM-019-R8.2 (02/12/2020) 1 Shell Offshore, Inc. (GMG290103) - The Salsa - Production Facility (PF 0025) / CWA NPDES Inspection Date 03/11/2025 Section I - INTRODUCTION PURPOSE OF THE INSPECTION EPA Region 6 inspectors Kerri McCabe (lead) and Michael Blaha and Bureau of Safety and Environmental Enforcement (BSEE) inspectors Ronald McClary and Kimberly Ward arrived at the Shell Offshore, Inc. ("Shell") - The Salsa-Production Facility at 10:00am on March 11, 2025, for an unannounced Compliance Evaluation Inspection (CEI) of the EPA National Pollutant Discharge Elimination System (NPDES) general permit GMG290103 and the BSEE Pollution Prevention and Control Regulations. After initial facility entry, we met with the facility operator Joseph Prejean. The Shell point of contact is Morris Jones at Morris.Jones@shell.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 Salsa - Production Facility (Complex ID No. 90014) is a fixed platform installed in 1998 and operated by Shell Offshore, Inc. The facility is located in the Garden Banks 172 lease block, approximately 104 miles offshore from Louisiana's coast, at an approximate water depth of 693 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 5,000 barrels of oil per day (BOPD) and 17 MSCF/day of natural gas. The facility is manned 24/7 and houses approximately 17 personnel during normal operations. Map 1. Google Earth aerial image dated 12/31/2020 of the Shell Offshore, Inc. - Salsa - Production Facility location. 2 Shell Offshore, Inc. (GMG290103) - The Salsa - Production Facility (PF 0025) / CWA NPDES Inspection Date 03/11/2025 The EPA general permit number for Shell Offshore, Inc. is GMG290103 and the Discharge Monitoring Report (DMR) Permitted Feature ID number for this platform is 0025. EPA assigned the DMR Limit Set Name for this facility as "Salsa - Production Facility." For reporting, EPA has assigned DMR Limit Set Designators as follows: Salsa - Production Facility (Permitted Feature 0025): BMP (Maintenance Best Management Plan) CT (Chemically Treated Waters) DC (Drill Cuttings) DD (Deck Drainage) DF (Drilling Fluids) DW (Domestic Waste) HF (Hydrate Control Fluids) MD (Miscellaneous Discharges - Includes Packer Fluids & Pipeline Brine) MT (Miscellaneous Discharges Toxicity - Chemically Treated) PM (Produced Water Monthly Toxicity) PR (Produced Water) SB (Synthetic Based Mud Cuttings) SW (Sanitary Waste) TC (Well Treatment Fluids, Completion Fluids, Workover Fluids) WF (Well Fluids) 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 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 a special emphasis on viewing containment and any treatment systems utilized, including the facility's Marine Sanitation Device (MSD; see Photos No. 1 and No. 2). 3 Shell Offshore, Inc. (GMG290103) - The Salsa - Production Facility (PF 0025) / CWA NPDES Inspection Date 03/11/2025 Section III - AREAS OF CONCERN During this inspection, there were observed areas of potential concern related to the environmental compliance of this facility: At the time of inspection, foam was witnessed coming from the clothes washer line (gray water) discharge, and The facility sends their overboard water to the Shell Enchilada facility. BSEE is seeking guidance from EPA if this complies with the NPDES general permit. Section IV - LIST OF APPENDICES Appendix 1 - Photograph Log - 4 photos taken 03/11/2025. _____________________________________________________________________________________ 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. 4 Shell Offshore, Inc. (GMG290103) - The Salsa - Production Facility (PF 0025) / CWA NPDES Inspection Date 03/11/2025 Appendix 1 Photograph Log 4 Photos UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: Garden Banks 172, approximately 104 miles offshore from Louisiana's coast, at an approximate water depth of 693 feet. City: Lafayette County/Parish: Lafayette State: GOA Photo File Name: 100-0760 Orientation: 62 ENE Date of Photo: 03/11/2025 Time of Photo: 1154 Latitude: 27.840433 Longitude: -91.987417 Photographer: Kerri McCabe Description: Looking ENE, this photo shows the Marine Sanitation Device (MSD) manufacturer's plate. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: Garden Banks 172, approximately 104 miles offshore from Louisiana's coast, at an approximate water depth of 693 feet. City: Lafayette County/Parish: Lafayette State: GOA Photo File Name: 100-0761 Orientation: 93 E Date of Photo: 03/11/2025 Time of Photo: 1154 Latitude: 27.840494 Longitude: -91.987417 Photographer: Kerri McCabe Description: Looking E, this photo shows an overview of the MSD from Photo No. 1. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: Garden Banks 172, approximately 104 miles offshore from Louisiana's coast, at an approximate water depth of 693 feet. City: Lafayette County/Parish: Lafayette State: GOA Photo File Name: 100-0762 Orientation: 52 NE Date of Photo: 03/11/2025 Time of Photo: 1209 Latitude: 27.840733 Longitude: -91.987600 Photographer: Kerri McCabe Description: Looking NE, this photo shows persistent foam from a domestic (gray water) line. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: Garden Banks 172, approximately 104 miles offshore from Louisiana's coast, at an approximate water depth of 693 feet. City: Lafayette County/Parish: Lafayette State: GOA Photo File Name: 100-0764 Orientation: 47 NE Date of Photo: 03/11/2025 Time of Photo: 1209 Latitude: 27.840667 Longitude: -91.987517 Photographer: Kerri McCabe Description: Looking NE, this photo shows a closeup of the foam from Photo No. 3.