Document e7gZVDqevqd8gxpE4wXxoB0q4

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: Talos Petroleum, LLC Ram Powell Facility (Permitted Feature 0660) Viosca Knoll 956 at 29.0606N, -88.0917W Gulf of America - U.S. Federal Waters 333 Clay Street, Suite 3300 Houston, TX 77002 Orleans Parish (713) 328-3026 Trina Engels Trina.engels@talosenergy.com Complex ID: Identification/Permit Number: OSC Lease: BSEE Inspection ID No.: Facility Description: 24229 GMG290188 G06896 553203957 A tension leg platform Personnel participating in inspection: Kerri McCabe EPA / Region 6 ECDW Michael Blaha (lead) EPA / Region 6 ECDW Ronald McClary BSEE / GOA OCS Region Doug Eubanks Person in Charge Inspector / Enforcement Officer Inspector / Enforcement Officer Water Quality Coordinator, Engineer Facility Point of Contact EPA Lead Inspector Signature/Date Supervisor Signature/Date KERRI MCCABE Date: 2025.07.23 07:12:14 -05'00' Digitally signed by KERRI MCCABE Kerri McCabe for Michael Blaha Date Jeanne Eckhart Date 6ENFORM-019-R8.2 (02/12/2020) 1 Talos Petroleum, LLC (GMG290188) / Ram Powell Facility (PF 0660) / CWA NPDES Inspection Date 05/20/2025 Section I - INTRODUCTION PURPOSE OF THE INSPECTION Environmental Protection Agency (EPA) Region 6 inspectors Michael Blaha (lead), Kerri McCabe, and Bureau of Safety and Environmental Enforcement (BSEE) inspector Ronald McClary arrived at the Talos Petroleum, LLC - Ram Powell Facility at 12:45 PM 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), Doug Eubanks. The Talos Petroleum, LLC point of contact is Trina Engels at trina.engels@talosenergy.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 Ram Powell Facility (Complex ID No. 24229) is a tension leg platform installed in 1997 and operated by Talos Petroleum, LLC. The facility is located in the Viosca Knoll 956 lease block, approximately 55 miles offshore from Louisiana's coast, at an approximate water depth of 3,216 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 9,800 BOPD, 1,700 BWPD, and 61.5 SCF/day. The facility is manned 24/7 and houses approximately 52 personnel during normal operations. Map 1. Google Earth aerial image dated 12/31/2020 of the Talos Petroleum, LLC - Ram Powell Facility location. 2 Talos Petroleum, LLC (GMG290188) / Ram Powell Facility (PF 0660) / CWA NPDES Inspection Date 05/20/2025 The EPA general permit number for Talos Petroleum, LLC is GMG290188 and the Discharge Monitoring Report (DMR) Permitted Feature ID number for this platform is 0660, with the facility name Ram Powell Facility. Talos Petroleum, LLC submits DMR to EPA for the following Limit Set Designators: Ram Powell Facility (Permitted Feature 0660): 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) 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. 4) and floatation cell (see Photos No. 11 through No. 12). EPA and BSEE also discussed and observed Talos Petroleum, LLC personnel collect produced water oil and grease sample (see Photos No. 5 through No. 10). Section III - AREAS OF CONCERN During this inspection, BSEE observed the following "Facility Inspection Observations" related to the environmental compliance of this facility: The facility had a deck drainage sheen in July 2023 (Part I, Sec. B, 3, a); Incomplete chains of custody (Part II, Sec. C, 4, a-g); 3 Talos Petroleum, LLC (GMG290188) / Ram Powell Facility (PF 0660) / CWA NPDES Inspection Date 05/20/2025 Multiple oil and grease samples during the review focus period, received by the lab, had a pH greater than 2 (Part I, Sec. B, Note 1-2); The facility had a produced water effluent violation on October 2023 (Part I, Sec. B, 4, a); May 2023 methanol toxicity sample was received by lab without a chain of custody. The lab started a Chain of Custody upon receiving the sample (Part I, Sec. B, Note 1-2); Facility personnel is unfamiliar with sheen sampling protocols (Part I, Section B, 4, b)*; All facility discharges commingle in a caisson and discharge 400 feet below sea level (Part II, Sec. C, 2)*; October 2023 NPDES oil & grease results report the average of all samples, but not the individual samples (5) results. Received all sample results via separate excel document (Part II, Sec. D, 5); December 2023 NPDES oil and grease results report only one of the two sample results, received all sample results via separate excel document (Part II, Sec. D, 5); November 2024 NPDES oil and grease result (4.0 mg/L) reported does not match separate received Excel document (7.4 mg/L) (Part II, Sec. D, 4); and August 2023 lab checklist notes improper error correction(s) made by client (Part I, Sec. B, Note 1-2). Section IV - LIST OF APPENDICES Appendix 1 - Photograph Log - 12 photos taken 05/20/2025. _____________________________________________________________________________________ *Requested clarification from BSEE on 07/10/2025 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 Talos Petroleum, LLC (GMG290188) - Ram Powell Facility (PF 0660) / CWA NPDES Inspection Date 05/20/2025 Appendix 1 Photograph Log 12 Photos UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: Ram Powell Facility (0660) platform in Viosca Knoll 956 at 29.06085N, -88.09148W. City: New Orleans County/Parish: New Orleans State: Louisiana (GoA) Photo File Name: R0010989 Orientation: 46 NE Date of Photo: 05/20/2025 Time of Photo: 1:21 PM Latitude: 29.06085 Longitude: -88.09148 Photographer: Kerri McCabe Description: Description: Looking NE, this photo shows an overview of the marine sanitation device (MSD) utilized at the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: Ram Powell Facility (0660) platform in Viosca Knoll 956 at 29.06085N, -88.09148W. City: New Orleans County/Parish: New Orleans State: Louisiana (GoA) Photo File Name: R0010990 Orientation: 24 NNE Date of Photo: 05/20/2025 Time of Photo: 1:21 PM Latitude: 29.0609 Longitude: -88.09144 Photographer: Kerri McCabe Description: Description: Looking NNE, this photo shows the marine sanitation device (MSD) plate. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: Ram Powell Facility (0660) platform in Viosca Knoll 956 at 29.06085N, -88.09148W. City: New Orleans County/Parish: New Orleans State: Louisiana (GoA) Photo File Name: R0010991 Orientation: 13 NNE Date of Photo: 05/20/2025 Time of Photo: 1:21 PM Latitude: 28.906088 Longitude: -88.09141 Photographer: Kerri McCabe Description: Description: Looking NNE, this photo shows the marine sanitation device (MSD) USCG plate. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: Ram Powell Facility (0660) platform in Viosca Knoll 956 at 29.06085N, -88.09148W. City: New Orleans County/Parish: New Orleans State: Louisiana (GoA) Photo File Name: R0010994 Orientation: 22 NNE Date of Photo: 05/20/2025 Time of Photo: 1:22 PM Latitude: 29.0609 Longitude: -88.09155 Photographer: Kerri McCabe Description: Looking NNE, this photo shows chlorine tablets inside the chlorinator for the MSD for the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: Ram Powell Facility (0660) platform in Viosca Knoll 956 at 29.06085N, -88.09148W. City: New Orleans County/Parish: New Orleans State: Louisiana (GoA) Photo File Name: R0010995 Orientation: N/A Date of Photo: 05/20/2025 Time of Photo: 1:32 PM Latitude: 29.0609 Longitude: -88.09155 Photographer: Kerri McCabe Description: This photo shows the "NPDES Sample Point" from the flotation cell. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: Ram Powell Facility (0660) platform in Viosca Knoll 956 at 29.06085N, -88.09148W. City: New Orleans County/Parish: New Orleans State: Louisiana (GoA) Photo File Name: R0010998 Orientation: N/A Date of Photo: 05/20/2025 Time of Photo: 1:32 PM Latitude: 29.0609 Longitude: -88.09155 Photographer: Kerri McCabe Description: This photo shows the "Talos Overboard Water Sample Procedures" near the "NPDES Sample Point". UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: Ram Powell Facility (0660) platform in Viosca Knoll 956 at 29.06085N, -88.09148W. City: New Orleans County/Parish: New Orleans State: Louisiana (GoA) Photo File Name: R0010999 Orientation: N/A Date of Photo: 05/20/2025 Time of Photo: 1:36 PM Latitude: 29.0609 Longitude: -88.09155 Photographer: Kerri McCabe Description: This photo shows the produced water sample near the "NPDES Sample Point". UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: Ram Powell Facility (0660) platform in Viosca Knoll 956 at 29.06085N, -88.09148W. City: New Orleans County/Parish: New Orleans State: Louisiana (GoA) Photo File Name: R0011000 Orientation: N/A Date of Photo: 05/20/2025 Time of Photo: 1:42 PM Latitude: 29.0609 Longitude: -88.09155 Photographer: Kerri McCabe Description: This photo shows the designated fridge for "Overboard Water Samples". UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 Location: Ram Powell Facility (0660) platform in Viosca Knoll 956 at 29.06085N, -88.09148W. City: New Orleans County/Parish: New Orleans State: Louisiana (GoA) Photo File Name: R0011001 Orientation: N/A Date of Photo: 05/20/2025 Time of Photo: 1:43 PM Latitude: 29.0609 Longitude: -88.09155 Photographer: Kerri McCabe Description: This photo shows the thermometer inside the "Overboard Water Samples" fridge. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 10 Location: Ram Powell Facility (0660) platform in Viosca Knoll 956 at 29.06085N, -88.09148W. City: New Orleans County/Parish: New Orleans State: Louisiana (GoA) Photo File Name: R0011002 Orientation: N/A Date of Photo: 05/20/2025 Time of Photo: 1:43 PM Latitude: 29.0609 Longitude: -88.09155 Photographer: Kerri McCabe Description: This photo shows the TD-550/560 Oil in Water Analyzer used at the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 11 Location: Ram Powell Facility (0660) platform in Viosca Knoll 956 at 29.06085N, -88.09148W. City: New Orleans County/Parish: New Orleans State: Louisiana (GoA) Photo File Name: R0011005 Orientation: 322 NW Date of Photo: 05/20/2025 Time of Photo: 1:49 PM Latitude: 29.06169 Longitude: -88.09199 Photographer: Kerri McCabe Description: Looking NW, this photo shows the Enviro-Tech float cell at the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 12 Location: Ram Powell Facility (0660) platform in Viosca Knoll 956 at 29.06085N, -88.09148W. City: New Orleans County/Parish: New Orleans State: Louisiana (GoA) Photo File Name: R0011009 Orientation: 302 WNW Date of Photo: 05/20/2025 Time of Photo: 1:52 PM Latitude: 29.06157 Longitude: -88.09193 Photographer: Kerri McCabe Description: Looking WNW, this photo shows the plates on the Enviro-Tech float cell.