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Inspection Date(s): Time: Program: Regulatory Program(s): If Access is Denied: REGION 10 Enforcement Division INSPECTION REPORT 06/16/2021 - 06/17/2021 Announced: No Entry: 07:29 AM (AKT) Exit: 03:30 PM (AKT) RCRA Title 40 - ENVIRONMENTAL PROTECTION AGENCY Company Name: Facility or Site Name: Facility/Site Physical Address: (City, state, zip code) Type of Operation: Size of Facility: Length of Facility at Location: Geographic Coordinates: Mailing address: (Secondary Address) (City, state, zip code) County: Hilcorp North Slope, LLC HILCORP NORTH SLOPE PRUDHOE BAY UNIT PRUDHOE BAY UNIT PRUDHOE BAY, AK 99734 Crude oil production field 213,543 acres Since the 1960's 70.293892, -148.704274 Mr. Chuck Wheat, Waste Program Lead Hilcorp Alaska, LLC 3800 Centerpoint Drive, Suite 1400 Anchorage, AK 99503 cwheat@hilcorp.com CC: Matt Laskey/Vic Farris AlaskaNS-PB-WasteCoord@hilcorp.com Jeff Shannon/Shane Umatum AlaskaNS-PB-WasteTech@hilcorp.com Anchorage, AK 99503 Facility/Site Identifier: Media Number: NAICS: AKD000643239 Permitted Facility 211120 - CRUDE PETROLEUM EXTRACTION Lead Inspector: Jon Jones Jones, Jon REGION 10 Digitally signed by Jones, Jon Date: 2021.09.23 08:46:24 -08'00' Jones.Jon@epa.gov (907) 271-6329 Additional Persons Participating in Inspection: Supervisor Review: Jen Sullivan Jennifer A Sullivan REGION 10 1 of 36 Digitally signed by Jennifer A Sullivan Date: 2021.09.23 10:53:40 -07'00' Sullivan.Jennifer.A@epa.gov (206) 553-6978 BP EXPLORATION ALASKA PRUDHOE BAY Inspection Date(s): 06/16/2021 - 06/17/2021 SECTION I - INTRODUCTION Purpose of the Inspection/Objective Type of inspection: CEI - Compliance Evaluation Inspection This was a Resource Conservation and Recovery Act (RCRA) inspection. The facility was inspected to ensure compliance with the facility's RCRA permit, as well as the standards for hazardous waste generators and universal waste management (40 C.F.R. Part 262 through 273) and used oil management (40 C.F.R. Part 279). The inspection was conducted as part of a Core Program requirement for FY 2021. Attendees Title Lead Inspector Hazardous Waste Coordinator Alaska North Slope-Prudhoe Bay-Waste Technician Waste Program Lead Prudhoe Bay West Environmental Specialist Prudhoe Bay West Environmental Specialist Name Jon Jones Matt Laskey Jeff Shannon Chuck Wheat Omar Ramirez Eric Van Dongen Phone 9072716329 (907) 659-4810 (907) 659-4705 (907) 777-8556 (907) 659-4789 (907) 659-4789 Email Jones.Jon@epa.gov Present in Opening Conf. Yes AlaskaNS-PB- Yes WasteCoord@hilcorp.com AlaskaNS-PB- Yes WasteTech@hilcorp.com cwheat@hilcorp.com No alaskans-pbw- No envirospec@hilcorp.com alaskans-pbw- No envirospec@hilcorp.com Present in Closing Conf. Yes Yes Yes Yes Yes Yes Opening Conference EPA Lead Inspector Jon Jones arrived at the HILCORP NORTH SLOPE PRUDHOE BAY UNIT at 07:29 AM (AKT) on 06/16/2021 for the inspection. I presented my credentials to Mr. Matt Laskey and informed him that this was an EPA RCRA inspection. The table above presents all the inspection opening and closing conference participants. During the inspection I looked at the facility's processes, in addition to hazardous waste management practices, generation points, and accumulation areas. I looked for wastes that facility representatives had not yet identified or designated as hazardous. I also observed the facility's universal waste and used oil management. Only those areas in which I observed areas of concern or noted other pertinent issues are discussed in this inspection report. 2 of 36 BP EXPLORATION ALASKA PRUDHOE BAY Inspection Date(s): 06/16/2021 - 06/17/2021 Facility/Site Description Hilcorp North Slope Prudhoe Bay Unit (hereafter referred to as Hilcorp or facility) is a crude oil production field located on the North Slope of Alaska, just north of Deadhorse, AK, with no nearby residential or other noncommercial properties. Facility Info At the time of the inspection, the owners and operator of the facility were: Owner State of Alaska Department of Natural Resources 3700 Airport Way Fairbanks, AK 99709 Owner and Operator Hilcorp North Slope, LLC 3800 Centerpoint Drive, Suite 1400 Anchorage, AK 99503 According to facility personnel, the Hilcorp North Slope Prudhoe Bay Unit operates North Slope oil fields and pipelines with a gross production rate of approximately 520,000 barrels of oil equivalent per day. The Prudhoe Bay Unit consists of a West Operating Area and an East Operating Area. These areas have Satellite Accumulation Areas for hazardous wastes, non-hazardous wastes, universal wastes, and recyclable materials. A list of these SAA/UAA/RAA locations is included in the document log. Process Description The Hilcorp North Slope Prudhoe Bay Unit is a Large Quantity Generator (LQG) of hazardous waste, a large quantity handler of universal waste, and a permitted hazardous waste storage facility. The facility is not a commercial storage facility; the permit was issued so that Hilcorp could store the waste they generate for more than 90 days. The permit in effect at the time of this inspection was the administratively-continued 2009 Hazardous Waste Management Facility Standardized Permit and a new standardized RCRA permit will go into effect on September 30, 2021. Changes since the last inspection: Upgraded fire suppression system in the Hazardous Waste Process Facility (HWPF) RCRA storage unit Removed the white hazardous waste storage bins - the bins were removed due to their fire suppression systems being old and outdated. Company ownership change - BPXA to Hilcorp NS, LLC on July 1, 2020 Hilcorp NS, LLC has not made a waste determination on leather gloves - Mr. Shannon stated that he sometimes sees waste leather gloves comingled with solvent rags. He told me that the facility issues approximately 2,500 pairs of leather gloves annually. Building(s) Building/Area/Sub-area ACS WOA shop Base Operations Center (BOC) C Pad Warehouse Process Description Satellite Accumulation Area (SAA) SAA SAA 3 of 36 Area of Concern No No No BP EXPLORATION ALASKA PRUDHOE BAY Inspection Date(s): 06/16/2021 - 06/17/2021 Central Compression Plant-CCP SAA No Central Gas Facility (CGF) SAA No Central Power Station (CPS) SAA Yes Hallway 128 SAA Yes Field Operations Complex (FOC) General maintenance shop No Halon shop SAA No Maintenance shop SAA No Flow Station 3 SAA No Gathering Center 3 (GC3) SAA Yes Skid 7 Maintenance Mod Yes Hazardous Waste Process Facility Permitted hazardous waste storage unit. Yes (HWPF) Hover craft hangar Houses hovercraft used for transportation to Yes Northstar, another Hilcorp production facility. Kakivik Warehouse Tool room No Entry way SAA SAA No Lisburne Production Facility -LPF SAA No MCC Clinic SAA No MCC Kitchen SAA No MCC Wing 12- Room 112 SAA No Mukluk Pad (Central Dispatch) Dispatch vehicles and heavy equipment for various No projects. Entry way SAA - North entrance door SAA No STP SAA No U11 - I&E Instrumentation and Electrical SAA Yes U-11 Scaffold Shop SAA No U-13 Light equipment shop SAA No U-21 Excavation Shop SAA No U5A CPS T&D Shop Transmission and distribution SAA No SECTION II - OBSERVATIONS AND RECORDS REVIEW Observations Building: C Pad Warehouse Observation #: JJ1-OB-029 Contains CBI: No Date: 06/17/2021 While at the C Pad Warehouse, I saw a board that was used to display the various work gloves that are issued to Hilcorp workers at the North Slope facility. At the time of the inspection, there were several styles of gloves that were leather and some that contained leather parts. According to Mr. Shannon there has been no waste determination made for the waste leather gloves that are generated when worn out or damaged. 4 of 36 BP EXPLORATION ALASKA PRUDHOE BAY Inspection Date(s): 06/16/2021 - 06/17/2021 Photo(s) 1. Observation_Image-202106171154225422547221.jpg Building: Central Power Station (CPS)/Hallway 128 Contains CBI: No Observation #: JJ1-OB-008 Date: 06/16/2021 While inspecting the SAA, I saw a yellow poly step-can that was labeled to identify that it held lead acid batteries for recycling. Upon further inspection, I saw that the container held three NiCad batteries, used in battery operated power tools, and a fluorescent light ballast that contained a NiCad battery. There were also four small Duracell lithium batteries and three C size alkaline batteries. The NiCad and lithium batteries were not labeled as universal waste. Mr. Shannon removed the batteries from the container during the inspection, repackaged them, and labeled the new container during the inspection. Photo(s) 1. Observation_Image-202106161128262826387974.jpg 2. Observation_Image-202106161128462846450711.jpg 3. Observation_Image-202106161130443044455528.jpg 4. Observation_Image-202106161133373337347511.jpg 5. Observation_Image-202106161133413341355342.jpg 6. Observation_Image-20210616113406346440371.jpg 7. Observation_Image-20210616114509459275790.jpg Building: Gathering Center 3 (GC3)/Skid 7 Contains CBI: No Observation #: JJ1-OB-007 Date: 06/16/2021 While inspecting the maintenance mod I saw a red step-can that was labeled, "Hazardous Waste - Solvent rags." The step-can was being utilized as a SAA container for solvent rags. At the time of the inspection, the container lid was not making a complete seal with the container when closed. This is a common problem when using stepcans. When we opened the lid to see what was inside, I saw that it contained waste aerosols. The hazard indicator was a Department of Transportation (DOT) Class 9 N.O.S. label for solvent rags instead of a Class 3 ignitable hazard indicator. Upon further inspection I saw a few waste rags inside the container and approximately 20- 25 waste aerosol cans. Mr. Shannon removed the waste aerosol cans from the waste solvent rags SAA and placed them inside of the waste aerosol SAA, that was located just upstairs, during the inspection. Photo(s) 1. Observation_Image-202106161057515751622588.jpg 2. Observation_Image-20210616105801581575592.jpg 3. Observation_Image-202106161058125812634093.jpg 4. Observation_Image-20210616110533533418969.jpg 5. Observation_Image-20210616110539539430112.jpg Building: Hazardous Waste Process Facility (HWPF) Contains CBI: No Observation #: JJ1-OB-001 Date: 06/16/2021 While inspecting the HWPF, I saw a 55-gallon container located in the area on the floor adjacent to storage area CS-5 and just beneath Pallet 08. The container had a label on it that was marked with the words "NonHazardous Waste." The label had an additional description of, "PCB CAP/BAL (LIQ & SOLID), it was dated 6/13/21 and the MR# 61649, and it was also marked with the words, "Caution Contains PCBs." Another label 5 of 36 BP EXPLORATION ALASKA PRUDHOE BAY Inspection Date(s): 06/16/2021 - 06/17/2021 on the container also stated "Caution - Contains PCBs." According to the HWPF inventory log the container held PCB ballast/capacitor/trans Liquid & Solid. The inventory listed a profile number, CH610356. I asked Mr. Laskey for a copy of the profile and he said he would email it to me. The waste profile is included in the document log. Photo(s) 1. Observation_Image-20210616090650650353432.jpg 2. Observation_Image-2021061609070070292003.jpg 3. Observation_Image-20210616090711711296547.jpg Building: Hazardous Waste Process Facility (HWPF) Contains CBI: No Observation #: JJ1-OB-002 Date: 06/16/2021 At the time of the inspection, while in the HWPF, I saw an 85-gallon overpack drum with a drum ring that was not fully closed. According to the labeling on the overpack, it held "PAINT AND THINNERS/FUEL W/EMPTY AEROSOLS." According to Mr. Laskey, they overpack all of their hazardous waste liquids and this container held aerosol can residues. He said that the containers holding the aerosol can residue have vented bung caps installed to relieve any pressure. He said that just prior to being shipped, the overpack lids are closed with a lid that has a plastic bung installed so that, if needed, the pressure can be relieved by the transporter while the container is in transit. There were two of these overpacks that contained the same waste and had these venting valves. Photo(s) 1. Observation_Image-202106160937393739498106.jpg 2. Observation_Image-202106160937543754521633.jpg 3. Observation_Image-20210616093809389533492.jpg Building: Hazardous Waste Process Facility (HWPF) Contains CBI: No Observation #: JJ1-OB-003 Date: 06/16/2021 At the time of the inspection, I observed a second container that held PCB ballasts for incineration. Photo(s) 1. Observation_Image-202106160942154215427325.jpg 2. Observation_Image-202106160942254225341397.jpg 3. Observation_Image-202106160942374237476915.jpg Building: Hazardous Waste Process Facility (HWPF) Contains CBI: No Observation #: JJ1-OB-004 Date: 06/16/2021 While in the HWPF I observed that the facility was now using spill pallets as secondary containment since removal of the large white storage bins. Photo(s) 1. Observation_Image-20210616094702472413242.jpg 2. Observation_Image-202106160947224722449135.jpg 3. Observation_Image-202106160948234823504508.jpg Building: Hazardous Waste Process Facility (HWPF) Contains CBI: No Observation #: JJ1-OB-005 Date: 06/16/2021 6 of 36 BP EXPLORATION ALASKA PRUDHOE BAY Inspection Date(s): 06/16/2021 - 06/17/2021 While still inspecting the HWPF, I documented the condition of the floor with photographs. Photo(s) 1. Observation_Image-20210616095107517253744.jpg 2. Observation_Image-202106160951185118299737.jpg 3. Observation_Image-202106160951585158301192.jpg 4. Observation_Image-202106160954425442489055.jpg 5. Observation_Image-202106160954525452392391.jpg 6. Observation_Image-20210616095508558375723.jpg Building: Hazardous Waste Process Facility (HWPF) Contains CBI: No Observation #: JJ1-OB-006 Date: 06/16/2021 There were several areas where it looked as though there was some damage to the coating on the floor of the HWPF. Mr. Laskey said it looked as though there was still some coating underneath some of the damaged areas; however, I observed that concrete was visible in the smaller of two holes, as shown in photograph # (you need to figure out which photo this is since the title is missing in the photo log, but it's the 5th photo in the lineup so probably 6880) . The size of the smaller hole in the coating was approximately the size of a quarter. I observed another tear in the coating adjacent to the CS-4 pallet which contained drums holding waste corrosives-basic. Mr. Laskey viewed the tear in the coating and commented that there was exposed concrete beneath the tear. There was another area right next to the tear where one of the storage bins used to be bolted down to the floor, just between pallets CS-3and CS-4, both holding containers of waste corrosives-basic. Some of the pins that anchored the cabinets to the floor had been ripped out of the floor, revealing obvious damage to the floor seal as well as the concrete. Photo(s) 1. Observation_Image-202106160959415941279540.jpg 2. Observation_Image-202106160959515951198827.jpg 3. Observation_Image-2021061610000606184498.jpg 4. Observation_Image-2021061610030636257993.jpg 5. Observation_Image-20210616100314314236880.jpg 6. Observation_Image-20210616100747747355172.jpg 7. Observation_Image-20210616100756756228932.jpg 8. Observation_Image-20210616100812812266328.jpg 9. Observation_Image-20210616101402142329651.jpg 10. Observation_Image-202106161014111411312595.jpg 11. Observation_Image-202106161014241424383048.jpg Building: Hover craft hangar Observation #: JJ1-OB-022 Contains CBI: No Date: 06/17/2021 While inspecting the hover craft hanger, I saw a gray cabinet that was marked as a waste aerosol SAA and a universal waste (UAA) accumulation area. I opened the cabinet and saw four waste aerosol containers on the middle shelf, next to a container that was labeled, "Aerosol cans only" and "Return to Hovercraft." The four waste aerosol cans were not containerized, not labeled as hazardous waste (HW), and were not marked with a hazard indicator. The facility manages aerosols as hazardous waste rather than universal waste. The container that was labeled "Aerosol cans only" and "Return to Hovercraft" was adjacent to the waste 7 of 36 BP EXPLORATION ALASKA PRUDHOE BAY Inspection Date(s): 06/16/2021 - 06/17/2021 aerosol cans and was empty. I saw that the other side of the container was labeled as HW and had hazard indicators for both Flammable and Non-flammable gases. Mr. Shannon placed the waste aerosol cans into the container during the inspection. According to Mr. Shannon, the Operators in Charge (OICs) at the hovercraft Hangar were contractors with Northern Energy Services (NES) and had been trained in hazardous waste management, but other NES employees (Ken Dassel, Rachelle Dabling) at the Hovercraft Hangar have not had any training. Photo(s) 1. Observation_Image-202106170850335033499900.jpg 2. Observation_Image-20210617085104514443072.jpg 3. Observation_Image-202106170851235123385017.jpg 4. Observation_Image-20210617090631631336754.jpg Building: Hover craft hangar Contains CBI: No Observation #: JJ1-OB-023 Date: 06/17/2021 While still inspecting the contents of the gray cabinet, in the hovercraft hangar, I also saw seven waste lithium batteries on the top shelf. The waste batteries were not labeled as UW batteries. Mr. Shannon placed the lithium batteries in a UW container during the inspection. Photo(s) 1. Observation_Image-202106170856275627455200.jpg 2. Observation_Image-202106170856545654273695.jpg 3. Observation_Image-202106170857215721386730.jpg 4. Observation_Image-20210617090024024358939.jpg 5. Observation_Image-20210617090831831401558.jpg Building: Hover craft hangar Contains CBI: No Observation #: JJ1-OB-024 Date: 06/17/2021 While still inspecting the hovercraft hangar, I saw a 250-gallon steel tote. I asked what was in the tote and Mr. Shannon asked Mr. Dassel about the contents of the tote. Mr. Dassel said he thought they were using it as a used oil storage tote. The facility operator, Luke Niemela, Onshore Operator who works for NES, arrived onsite while we were there and confirmed that the tote held used oil. The tote that contained used oil was not labeled with the words "Used Oil." Mr. Niemela labeled the tote, with the words "Used Oil," during the inspection. Photo(s) 1. Observation_Image-202106170917281728516202.jpg 2. Observation_Image-202106170917391739515316.jpg 3. Observation_Image-20210617091801181413216.jpg 4. Observation_Image-202106170922332233432400.jpg Building: MCC Clinic Contains CBI: No Observation #: JJ1-OB-033 Date: 09/22/2021 While inspecting the clinic, I observed waste that was being accumulated in the clinic SAA. During a file review, prior to the inspection, I saw that the facility had not notified as being a healthcare facility, in accordance with 8 of 36 BP EXPLORATION ALASKA PRUDHOE BAY Inspection Date(s): 06/16/2021 - 06/17/2021 the Subpart P regulations. I asked clinic personnel how hazardous waste and hazardous waste pharmaceuticals were being managed at the facility and I was told that any hazardous wastes generated at the clinic was being managed as hazardous waste and taken to the facility's HWPF. Clinic personnel told me that nothing is managed through a reverse distributor. I brought this up at the closing conference and following the inspection, Mr. Wheat submitted a new notification form 8700-12 with the updated information. Mr. Wheat sent and email to me, dated 8/24/21, which stated "Please see an updated submission to EPA that addressed the medical facilities within the Prudhoe Bay Unit. This information was submitted via the EPA's RCRA Info web page. As you noted, the "box" was missed during the biennial report that was submitted by BPXA (previous Operator) in the 2019." Document(s) 1. AKD000643239_Update.pdf 2. Hilcorp HWPF.pdf Building: U11 - I&E Observation #: JJ1-OB-012 Contains CBI: No Date: 06/16/2021 While inspecting the UAA, I saw an open container of UW lamps. At the time of the inspection, the lid was not placed on the container properly and was cock-eyed, leaving an open gap at the top of the container. Mr. Shannon closed the container during the inspection. Photo(s) 1. Observation_Image-20210616130857857509771.jpg 2. Observation_Image-20210616130924924381186.jpg 3. Observation_Image-20210616130952952327088.jpg 4. Observation_Image-20210616131205125250511.jpg Records Review Record: Contingency Plan Ref #: JJ1-RR-001 Reviewed By: Jon Jones AOC: Yes Reviewed Date: 08/19/2021 The contingency plan was emailed to me on the first day of the inspection, June 16, 2021. I reviewed the facility's hazardous waste contingency plan following the inspection and discovered that personnel that have retired (Larry Raburn, retired July 2020) is still listed as an alternate emergency coordinator. Mr. Raburn was once one of the waste coordinators at the facility. The revision date of the contingency plan was 7/25/2020. At the time of the inspection, Mr. Laskey, who had previously been a waste technician, had moved into Mr. Raburn's position as the new waste coordinator and Mr. Shannon had been hired as the new waste technician. Mr. Shannon was not listed in the contingency plan as the alternate emergency coordinator and Mr. Laskey was still listed in the plan as the waste technician. Document(s) 1. Prudhoe Bay Unit RCRA Contingency Plan.docx Record: Personnel Training Ref #: JJ1-RR-002 Reviewed By: Jon Jones AOC: Yes Reviewed Date: 08/19/2021 9 of 36 BP EXPLORATION ALASKA PRUDHOE BAY Inspection Date(s): 06/16/2021 - 06/17/2021 Following the inspection, I reviewed the training records for OIC's at the various SAA, UAA, and Recycling Accumulation Area (RAA) locations. As per the training provided by the facility, SAA, UAA, and RAA OIC's have the option of taking their wastes to the Hilcorp Central Accumulation Area (CAA)/HWPF. Since OIC's can, and sometimes do, take their wastes to the CAA/HWPF, they are required to take applicable annual hazardous waste training. While reviewing the training records for 73 SAA, UAA, and RAA locations, I saw that there were only 15 locations in which OIC training was current and up to date. I saw that there were 38 SAA, UAA, and RAA locations which showed that OIC training had expired. I also saw 20 SAA, UAA, and RAA locations which showed that alternate OIC's training had expired. Document(s) 1. 2021 SAA Log 6-16-21.pdf 2. BPXA GPB OIC Training Archive.pdf 3. Hilcorp OIC Training Log 6-16-21.pdf 4. Hilcorp Waste Accumulation Area Training (SAA.RAA.UAA) - FINAL.pptx 5. SAA Training Report.xlsx 6. Training Records for employees bringing us waste.pdf Record: Inspections Ref #: JJ1-RR-003 Reviewed By: Jon Jones AOC: Yes Reviewed Date: 09/08/2021 During the inspection, I reviewed the facility's weekly inspection logs and saw that the facility was not inspecting the integrity of the sealed concrete floor in the HWPF. There were several areas on the HWPF floor where the seal on the concrete floor had been damaged and were showing the bare concrete. There were also several areas on the HWPF floor that were damaged when the hazardous waste storage cabinets were removed. Some of the pins that anchored the cabinets to the floor had been ripped out of the floor, revealing obvious damage to the floor seal as well as the concrete. According to annotations on the weekly inspection log, floor integrity was not being checked/inspected prior to the 6/16/21 RCRA CEI. Document(s) 1. Weekly HWPF inspection logs 210908102608_0001.pdf Record: Personnel Training Ref #: JJ1-RR-004 Reviewed By: Jon Jones AOC: Yes Reviewed Date: 09/08/2021 Following the inspection, I reviewed the training records for both Matt Laskey and Vic Farris, the HW Coordinators, as well as Shane Umatum and Jeff Shannon, the HW Technicians. During this review of the training records, I saw that Mr. Shannon had RCRA training in June of 2020. I also saw that the RCRA training for Messrs. Laskey, Farris and Umatum had lapsed. The training records provided indicated that the last training was received on the following dates: Matt Laskey 2/28/20 (RCRA Basic & Advanced training) Vic Farris 2/28/20 (RCRA Basic & Advanced training) Shane Umatum 2/28/20 (RCRA Basic & Advanced training) When I contacted the facility to discuss this area of concern regarding the training, Mr. Farris provided me with additional information and documentation. Mr. Farris indicated that the facility's contingency plan was 10 of 36 BP EXPLORATION ALASKA PRUDHOE BAY Inspection Date(s): 06/16/2021 - 06/17/2021 reviewed, along with the waste analysis plan, SAA/UAA/RAA procedures, emergency response plan and HWPF procedures, and as such counts as annual RCRA training. The email chains and documentation indicate this was a review of the information to ensure that references made to BPXA were changed to Hilcorp NS, LLC as opposed to a review for training purposes. The information was not provided with the initial training documentation and was not logged in as training in their training spreadsheet. The document review information provided by Mr. Farris is included in the document log. Document(s) 1. BPXA Training History - Farris, Laskey, Shannon, Umatum.xlsx 2. Corrected Facility Training Records.pdf 3. Hilcorp Hazardous Waste Facility Personnel Training-Detailed.pdf 4. Training Records.pdf SECTION III - AREAS OF CONCERN The presentation of areas of concern does not constitute a formal compliance determination or violation. Building: JJ1-RR-001 Area: I reviewed the facility's hazardous waste contingency plan following the inspection and identified personnel that have retired (Larry Raburn, retired July 2020) is still listed as an alternate emergency coordinator. Mr. Raburn was once one of the waste coordinators at the facility. The revision date of the contingency plan was 7/25/2020. Citations: Sub-area: Sections: JJ1-RR-002 There were 38 SAA/UAA/RAA locations which showed that OIC training had expired. There were also 20 SAA/UAA/RAA locations which showed that alternate OIC's training had expired. Citations: Sections: JJ1-RR-003 During the inspection, I reviewed the facility's weekly inspection logs and saw that Citations: Sections: 11 of 36 BP EXPLORATION ALASKA PRUDHOE BAY Inspection Date(s): the facility was not inspecting the integrity of the sealed concrete floor in the HWPF. JJ1-RR-004 RCRA training for Messrs. Laskey, Farris and Umatum had lapsed. The training records provided indicated that the last training was received on the following dates: Citations: Matt Laskey 2/28/20 (RCRA Basic & Advanced training) Vic Farris 2/28/20 (RCRA Basic & Advanced training) Shane Umatum 2/28/20 (RCRA Basic & Advanced training) Building: C Pad Warehouse JJ1-OB-029 Area: According to Mr. Shannon, not waste determination has been made on waste leather gloves that are generated when damaged or worn out. Citations: Building: Central Power Station (CPS) JJ1-OB-008 Area: Hallway 128 While inspecting the SAA, I saw a yellow poly step-can for recycled lead-acid batteries that held three NiCad batteries, a fluorescent light ballast containing another NiCad battery, and four lithium batteries. At the time of the inspection, the NiCad and lithium batteries were not labeled as UW. Citations: 12 of 36 06/16/2021 - 06/17/2021 Sections: Sub-area: Sections: Sub-area: Sections: BP EXPLORATION ALASKA PRUDHOE BAY Inspection Date(s): Building: Gathering Center 3 (GC3) JJ1-OB-007 Area: Skid 7 There was step-can being utilized as a SAA container for waste solvent rags that was not closed. At the time of the inspection, the container lid was not making a complete seal with the container when closed. When we opened the lid to see what was inside, I saw that it contained waste aerosols. The hazard indicator was a Class 9 label for solvent rags instead of a Class 3 ignitable hazard indicator. Upon further inspection I saw a few waste rags inside the container and approximately 20- 25 waste aerosol cans. Citations: Building: Hazardous Waste Process Facility (HWPF) JJ1-OB-006 Area: There were several areas where it looked as though there was some damage to the coating on the floor inside of the HWPF. Mr. Laskey said it looked as though there was still some coating underneath the damaged areas however, concrete was visible in a smaller hole that was approximately the size of a quarter. Citations: I observed another tear in the coating adjacent to the CS-4 pallet which contained drums holding waste corrosives-basic. Mr. Laskey viewed the tear in the coating and commented that it was exposed concrete beneath the tear. 13 of 36 06/16/2021 - 06/17/2021 Sub-area: Sections: Sub-area: Sections: BP EXPLORATION ALASKA PRUDHOE BAY Inspection Date(s): Building: Hover craft hangar JJ1-OB-022 While inspecting the hovercraft hanger, I saw four waste aerosol cans were not containerized, not labeled as HW, and were not marked with a hazard indicator. Area: Citations: JJ1-OB-023 While inspecting the hovercraft hanger, I saw seven waste lithium batteries on the top shelf of a cabinet. The waste batteries were not labeled as UW batteries. Citations: JJ1-OB-024 While inspecting the hover craft hanger, I saw a 250gallon steel tote containing used oil, that was not labeled with the words "Used Oil." Citations: Building: MCC Clinic JJ1-OB-033 Area: The facility had not notified as being a healthcare facility, in accordance with the Subpart P regulations. Citations: Building: U11 - I&E JJ1-OB-012 Area: Citations: While inspecting the UAA I saw a container of UW lamps that was not closed. SECTION IV - FOLLOW UP I observed no follow up at the time of the inspection. 14 of 36 06/16/2021 - 06/17/2021 Sub-area: Sections: Sections: Sections: Sub-area: Sections: Sub-area: Sections: BP EXPLORATION ALASKA PRUDHOE BAY Inspection Date(s): 06/16/2021 - 06/17/2021 Closing Conference At the end of the inspection, I held a closing conference to discuss the findings of my inspection with Hilcorp North Slope Prudhoe Bay Unit personnel. I explained that I had inspected the facility looking at areas where solid, hazardous, and universal wastes were managed and that I had also inspected areas where used oil was being managed. I discussed all the areas of concern that are identified in Section III. SECTION V - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS - No sampling was conducted. SECTION VI - LIST OF APPENDICES Photo Log [Title] 06/17/2021 11:54 AM (AKT) Jon Jones C Pad Warehouse No CBI No PII A view of the various styles of gloves that are provided to Hilcorp employees and contractors at the Prudhoe Bay Unit. [Title] 06/16/2021 11:28 AM (AKT) Jon Jones Central Power Station (CPS)/Hallway 128 No CBI No PII View of a yellow poly step-can that, according to the labeling, held lead acid batteries. 15 of 36 BP EXPLORATION ALASKA PRUDHOE BAY Inspection Date(s): [Title] 06/16/2021 11:28 AM (AKT) Jon Jones Central Power Station (CPS)/Hallway 128 No CBI No PII View looking into the same yellow poly stepcan, showing that the container held three NiCad batteries, a fluorescent light ballast that contained a NiCad battery, and four small lithium batteries. [Title] 06/16/2021 11:30 AM (AKT) Jon Jones Central Power Station (CPS)/Hallway 128 No CBI No PII View of the NiCad and lithium batteries after Mr. Shannon removed them from the yellow step-can. [Title] 06/16/2021 11:33 AM (AKT) Jon Jones Central Power Station (CPS)/Hallway 128 No CBI No PII View of NiCad batteries that were not labeled as UW. 06/16/2021 - 06/17/2021 16 of 36 BP EXPLORATION ALASKA PRUDHOE BAY Inspection Date(s): [Title] 06/16/2021 11:33 AM (AKT) Jon Jones Central Power Station (CPS)/Hallway 128 No CBI No PII Another view of NiCad batteries that were not labeled as UW. [Title] 06/16/2021 11:34 AM (AKT) Jon Jones Central Power Station (CPS)/Hallway 128 No CBI No PII View of lithium batteries that were not labeled as UW. [Title] 06/16/2021 11:45 AM (AKT) Jon Jones Central Power Station (CPS)/Hallway 128 No CBI No PII View of the UW container that Mr. Shannon used to repackage the NiCad and lithium batteries during the inspection. 06/16/2021 - 06/17/2021 17 of 36 BP EXPLORATION ALASKA PRUDHOE BAY Inspection Date(s): [Title] 06/16/2021 10:57 AM (AKT) Jon Jones Gathering Center 3 (GC3)/Skid 7 No CBI No PII View of a red SAA step-can that was labeled, "Hazardous Waste - Solvent rags." The container lid was not making a complete seal with the container when closed. [Title] 06/16/2021 10:58 AM (AKT) Jon Jones Gathering Center 3 (GC3)/Skid 7 No CBI No PII Close-up view of the same SAA container seen in the previous photo. [Title] 06/16/2021 10:58 AM (AKT) Jon Jones Gathering Center 3 (GC3)/Skid 7 No CBI No PII Another view of the same SAA container seen in the previous two photos. After being opened, I saw that it contained waste aerosols. The hazard indicator was a Class 9 label for solvent rags instead of a Class 3 ignitable hazard indicator. Upon further inspection I saw a few waste rags inside the container and approximately 20- 25 waste aerosol cans. 18 of 36 06/16/2021 - 06/17/2021 BP EXPLORATION ALASKA PRUDHOE BAY Inspection Date(s): [Title] 06/16/2021 11:05 AM (AKT) Jon Jones Gathering Center 3 (GC3)/Skid 7 No CBI No PII Mr. Shannon removed the waste aerosol cans from the waste solvent rags SAA and placed them inside of the waste aerosol SAA, that was located just upstairs, during the inspection. This is a view of that waste aerosol SAA seen here to the right of the yellow step-can. [Title] 06/16/2021 11:05 AM (AKT) Jon Jones Gathering Center 3 (GC3)/Skid 7 No CBI No PII Close-up view of the waste aerosol SAA seen in the previous photo. [Title] 06/16/2021 09:06 AM (AKT) Jon Jones Hazardous Waste Process Facility (HWPF) No CBI No PII View of black 55-gallon container of PCB ballasts adjacent to CS-5 and just beneath pallet 08. 06/16/2021 - 06/17/2021 19 of 36 BP EXPLORATION ALASKA PRUDHOE BAY Inspection Date(s): [Title] 06/16/2021 09:07 AM (AKT) Jon Jones Hazardous Waste Process Facility (HWPF) No CBI No PII Close-up view of the same black 55-gallon container of PCB ballasts seen in the previous photo. [Title] 06/16/2021 09:07 AM (AKT) Jon Jones Hazardous Waste Process Facility (HWPF) No CBI No PII Close-up view of the labeling on the 55-gallon container of PCB ballasts. [Title] 06/16/2021 09:37 AM (AKT) Jon Jones Hazardous Waste Process Facility (HWPF) No CBI No PII View of vented, overpacked container of waste aerosol residue in storage at the HWPF. 06/16/2021 - 06/17/2021 20 of 36 BP EXPLORATION ALASKA PRUDHOE BAY Inspection Date(s): [Title] 06/16/2021 09:37 AM (AKT) Jon Jones Hazardous Waste Process Facility (HWPF) No CBI No PII View of a second vented container of the same waste aerosol residue, seen here at the top of the photo. [Title] 06/16/2021 09:38 AM (AKT) Jon Jones Hazardous Waste Process Facility (HWPF) No CBI No PII Close-up view of the same container seen in the previous photo. [Title] 06/16/2021 09:42 AM (AKT) Jon Jones Hazardous Waste Process Facility (HWPF) No CBI No PII View of another container that held PCB ballasts for incineration that was located in the HWPF. 06/16/2021 - 06/17/2021 21 of 36 BP EXPLORATION ALASKA PRUDHOE BAY Inspection Date(s): [Title] 06/16/2021 09:42 AM (AKT) Jon Jones Hazardous Waste Process Facility (HWPF) No CBI No PII View of the labeling on top of the PCB container, seen in the previous photo. [Title] 06/16/2021 09:42 AM (AKT) Jon Jones Hazardous Waste Process Facility (HWPF) No CBI No PII Close-up view of the labeling on top of the PCB container, seen in the previous photo. [Title] 06/16/2021 09:47 AM (AKT) Jon Jones Hazardous Waste Process Facility (HWPF) No CBI No PII View of the secondary containment spill pallets being used in place of the large white storage bins that were removed on 11/2/20. 06/16/2021 - 06/17/2021 22 of 36 BP EXPLORATION ALASKA PRUDHOE BAY Inspection Date(s): [Title] 06/16/2021 09:47 AM (AKT) Jon Jones Hazardous Waste Process Facility (HWPF) No CBI No PII Another view of the secondary containment spill pallets being used in place of the large white storage bins that were removed on 11/2/20. [Title] 06/16/2021 09:48 AM (AKT) Jon Jones Hazardous Waste Process Facility (HWPF) No CBI No PII Another view of the secondary containment spill pallets being used in place of the large white storage bins that were removed on 11/2/20. [Title] 06/16/2021 09:51 AM (AKT) Jon Jones Hazardous Waste Process Facility (HWPF) No CBI No PII View of the floor inside the HWPF. 06/16/2021 - 06/17/2021 23 of 36 BP EXPLORATION ALASKA PRUDHOE BAY Inspection Date(s): [Title] 06/16/2021 09:51 AM (AKT) Jon Jones Hazardous Waste Process Facility (HWPF) No CBI No PII Another view of the floor inside the HWPF. [Title] 06/16/2021 09:51 AM (AKT) Jon Jones Hazardous Waste Process Facility (HWPF) No CBI No PII Another view of the floor inside the HWPF. [Title] 06/16/2021 09:54 AM (AKT) Jon Jones Hazardous Waste Process Facility (HWPF) No CBI No PII Additional views of the floor inside the HWPF. 06/16/2021 - 06/17/2021 24 of 36 BP EXPLORATION ALASKA PRUDHOE BAY Inspection Date(s): [Title] 06/16/2021 09:54 AM (AKT) Jon Jones Hazardous Waste Process Facility (HWPF) No CBI No PII Additional views of the floor inside the HWPF. [Title] 06/16/2021 09:55 AM (AKT) Jon Jones Hazardous Waste Process Facility (HWPF) No CBI No PII Additional views of the floor inside the HWPF. [Title] 06/16/2021 09:59 AM (AKT) Jon Jones Hazardous Waste Process Facility (HWPF) No CBI No PII View of several areas on the floor where there was some damage to the coating on the floor inside of the HWPF. 06/16/2021 - 06/17/2021 25 of 36 BP EXPLORATION ALASKA PRUDHOE BAY Inspection Date(s): [Title] 06/16/2021 09:59 AM (AKT) Jon Jones Hazardous Waste Process Facility (HWPF) No CBI No PII Close-up view of several areas on the floor where there was some damage to the coating on the floor inside of the HWPF. [Title] 06/16/2021 10:00 AM (AKT) Jon Jones Hazardous Waste Process Facility (HWPF) No CBI No PII Another view of several areas on the floor where there was some damage to the coating on the floor inside of the HWPF. [Title] 06/16/2021 10:03 AM (AKT) Jon Jones Hazardous Waste Process Facility (HWPF) No CBI No PII Another view of several areas on the floor where there was some damage to the coating on the floor inside of the HWPF. 06/16/2021 - 06/17/2021 26 of 36 BP EXPLORATION ALASKA PRUDHOE BAY Inspection Date(s): [Title] 06/16/2021 10:03 AM (AKT) Jon Jones Hazardous Waste Process Facility (HWPF) No CBI No PII Close-up view of a smaller hole where the concrete was visible. [Title] 06/16/2021 10:07 AM (AKT) Jon Jones Hazardous Waste Process Facility (HWPF) No CBI No PII View of another tear in the coating adjacent to the CS-4 pallet which contained drums holding waste corrosives-basic. [Title] 06/16/2021 10:07 AM (AKT) Jon Jones Hazardous Waste Process Facility (HWPF) No CBI No PII Close-up view of the tear in the coating, from the previous photo, adjacent to the CS-4 pallet which contained drums holding waste corrosives-basic. 06/16/2021 - 06/17/2021 27 of 36 BP EXPLORATION ALASKA PRUDHOE BAY Inspection Date(s): [Title] 06/16/2021 10:08 AM (AKT) Jon Jones Hazardous Waste Process Facility (HWPF) No CBI No PII Another close-up view of the damage to the floor seen in the previous photo. [Title] 06/16/2021 10:14 AM (AKT) Jon Jones Hazardous Waste Process Facility (HWPF) No CBI No PII Another close-up view of the damage to the floor seen in the previous photo. [Title] 06/16/2021 10:14 AM (AKT) Jon Jones Hazardous Waste Process Facility (HWPF) No CBI No PII Another close-up view showing damage to the floor and exposed concrete. 06/16/2021 - 06/17/2021 28 of 36 BP EXPLORATION ALASKA PRUDHOE BAY Inspection Date(s): [Title] 06/16/2021 10:14 AM (AKT) Jon Jones Hazardous Waste Process Facility (HWPF) No CBI No PII Another close-up view showing damage to the floor and exposed concrete seen in the previous photo. [Title] 06/17/2021 08:50 AM (AKT) Jon Jones Hover craft hangar No CBI No PII View of a cabinet marked as an SAA/UAA/RAA. [Title] 06/17/2021 08:51 AM (AKT) Jon Jones Hover craft hangar No CBI No PII View inside the cabinet, seen in the previous photo. Photo shows four waste aerosol cans on the shelf adjacent to the SAA container for waste aerosols. 06/16/2021 - 06/17/2021 29 of 36 BP EXPLORATION ALASKA PRUDHOE BAY Inspection Date(s): [Title] 06/17/2021 08:51 AM (AKT) Jon Jones Hover craft hangar No CBI No PII View of the labeling on the SAA container. [Title] 06/17/2021 08:56 AM (AKT) Jon Jones Hover craft hangar No CBI No PII Close-up view of the gray SAA/UAA/RAA cabinet. [Title] 06/17/2021 08:56 AM (AKT) Jon Jones Hover craft hangar No CBI No PII Close-up view of the labeling on the outside of the gray cabinet. 06/16/2021 - 06/17/2021 30 of 36 BP EXPLORATION ALASKA PRUDHOE BAY Inspection Date(s): [Title] 06/17/2021 08:57 AM (AKT) Jon Jones Hover craft hangar No CBI No PII View of seven waste lithium batteries on the top shelf of the same gray cabinet seen in the previous photo. The waste batteries were not labeled as UW batteries. [Title] 06/17/2021 09:00 AM (AKT) Jon Jones Hover craft hangar No CBI No PII Close-up view of one of the seven waste lithium batts that were not labeled as UW. [Title] 06/17/2021 09:06 AM (AKT) Jon Jones Hover craft hangar No CBI No PII View of the labeling on the waste aerosol SAA container and UAA battery container inside the gray cabinet. 06/16/2021 - 06/17/2021 31 of 36 BP EXPLORATION ALASKA PRUDHOE BAY Inspection Date(s): [Title] 06/17/2021 09:08 AM (AKT) Jon Jones Hover craft hangar No CBI No PII Another view of the labeling on the waste aerosol SAA container and UAA battery container inside the gray cabinet. [Title] 06/17/2021 09:17 AM (AKT) Jon Jones Hover craft hangar No CBI No PII View of a 250-gallon steel tote containing used oil that is not labeled with the words "Used Oil." [Title] 06/17/2021 09:17 AM (AKT) Jon Jones Hover craft hangar No CBI No PII Another view of a 250-gallon steel tote containing used oil that is not labeled with the words "Used Oil." 06/16/2021 - 06/17/2021 32 of 36 BP EXPLORATION ALASKA PRUDHOE BAY Inspection Date(s): [Title] 06/17/2021 09:18 AM (AKT) Jon Jones Hover craft hangar No CBI No PII Another view of a 250-gallon steel tote containing used oil that is not labeled with the words "Used Oil." [Title] 06/17/2021 09:22 AM (AKT) Jon Jones Hover craft hangar No CBI No PII View of the 250-gallon steel tote containing used oil after being labeled with the words "Used Oil." [Title] 06/16/2021 01:08 PM (AKT) Jon Jones U11 - I&E No CBI No PII View of container of UW lamps that is not closed. 06/16/2021 - 06/17/2021 33 of 36 BP EXPLORATION ALASKA PRUDHOE BAY Inspection Date(s): [Title] 06/16/2021 01:09 PM (AKT) Jon Jones U11 - I&E No CBI No PII Another view of container of UW lamps that is not closed. [Title] 06/16/2021 01:09 PM (AKT) Jon Jones U11 - I&E No CBI No PII View of the waste lamps inside the container. 06/16/2021 - 06/17/2021 [Title] 06/16/2021 01:12 PM (AKT) Jon Jones U11 - I&E No CBI No PII View of the UAA container of waste lamps after being closed. Document Log Document Type Records Review Document Name Contains Contains Uploaded By CBI PII Prudhoe Bay Unit RCRA Contingency No No Jon Jones 34 of 36 Date Received 08/19/2021 BP EXPLORATION ALASKA PRUDHOE BAY Inspection Date(s): 06/16/2021 - 06/17/2021 Plan.docx Records Review 2021 SAA Log 6-16-21.pdf No No Jon Jones Records Review BPXA GPB OIC Training Archive.pdf No No Jon Jones Records Review Hilcorp OIC Training Log 6-16-21.pdf No No Jon Jones Records Review Hilcorp Waste Accumulation Area No No Jon Jones Training (SAA.RAA.UAA) - FINAL.pptx Records Review SAA Training Report.xlsx No No Jon Jones Records Review Training Records for employees No No Jon Jones bringing us waste.pdf Records Review BPXA Training History - Farris, No No Jon Jones Laskey, Shannon, Umatum.xlsx Records Review Corrected Facility Training Records.pdf No No Jon Jones Records Review Hilcorp Hazardous Waste Facility No No Jon Jones Personnel Training-Detailed.pdf Records Review Training Records.pdf No No Jon Jones Other - Alternative FW procedures for update.msg No No Jon Jones training documentation Other - Alternative Hazardous Waste Process Facility No No Jon Jones training and Office Emergency Response documentation Plan.docx Other - Alternative Hazardous Waste Process Facility No No Jon Jones training Waste Analysis Plan.docx documentation Other - Alternative training documentation Procedure updates.msg No No Jon Jones Other - Alternative training documentation procedures for update.msg No No Jon Jones Other - Alternative Prudhoe Bay Unit RCRA Contingency No No Jon Jones training Plan.docx documentation Records Review Weekly HWPF inspection logs 210908102608_0001.pdf No No Jon Jones Other - Waste profile CH610356-1.pdf PCB ballasts for incineration No No Jon Jones Other - Waste profile CH1031105-1.pdf for aerosol residue No No Jon Jones Communications Hilcorp Profiles Requested PCB and No No Jon Jones Paint email.pdf Other - Accumulation Accumulation Area Inspection List 6- No No Jon Jones 35 of 36 09/08/2021 09/08/2021 09/08/2021 09/08/2021 09/08/2021 09/08/2021 09/08/2021 09/08/2021 09/08/2021 09/08/2021 09/08/2021 09/08/2021 09/08/2021 09/08/2021 09/08/2021 09/08/2021 09/08/2021 09/08/2021 09/08/2021 09/08/2021 09/08/2021 BP EXPLORATION ALASKA PRUDHOE BAY Inspection Date(s): 06/16/2021 - 06/17/2021 Area List 16-21.pdf Records Review Job Descriptions.pdf No No Jon Jones Communications MCC Wing 12 Room 112 - Area of No No Jon Jones Concern Clarification1.pdf Communications RE_ MCC Wing 12 Room 112 - Area No No Jon Jones of Concern Clarification.pdf Communications Corrections to Previous Email for No No Jon Jones Training Documents and C-Plan.pdf Communications Hilcorp Accumulation Area Documents to EPA.pdf No No Jon Jones Other - Waste inventory in HWPF In shop list.pdf No No Jon Jones Inspection Reports Field_Notes_AKD000643239v1.0.pdf No No Jon Jones Other - 8700-12 information AKD000643239_Update.pdf No No Jon Jones Communications Hilcorp HWPF.pdf No No Jon Jones 09/08/2021 09/08/2021 09/08/2021 09/08/2021 09/08/2021 09/08/2021 09/08/2021 09/22/2021 09/22/2021 36 of 36