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Click or tap here to enter text. Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 6 Enforcement Division INSPECTION REPORT 09/03/2024 09:30 AM (CT) 09/03/2024 02:45 PM (CT) RCRA RCRA Compliance Evaluation Inspection Announced: No Access: Granted Company Name Facility or Site Name Facility/Site Identifier Facility/Site Physical Address City, State, Zip Code County/Borough Generator Status NAICS Type of Operation Geographic Coordinates Mailing Address City, State, Zip Code BP Exploration & Production Mississippi Canyon 778 A Thunder Horse XFR982310252 Latitude: 28.187698 Longitude: -88.490685 United States (Federal Waters) Not Applicable Large Quantity Generator 211120 Crude Petroleum Extraction 211130 Natural Gas Extraction Oil and gas production offshore platform. Latitude: 28.187698 Longitude: -88.490685 501 Westlake Park Blvd Houston, TX 77079 Permit Number (If Applicable) Not Applicable Additional Persons Participating in Inspection: Name Title Organization Erin Young-Dahl Inspector EPA Region 6 Ronald McClary Engineer Bureau of Safety and Environmental Enforcement (BSEE) Email Phone Youngdahl.erin@epa.gov (214) 665-3166 ronald.mcclary@bsee.gov --- Lead Inspector: Dedriel Gardner Digitally signed by DEDRIEL DEDRIEL GARDNER GARDNER Date: 2024.11.01 10:25:59 -05'00' EPA REGION 6 Gardner.Dedriel@epa.gov (281) 983-2133 Supervisor Review: Debra Pandak DEBRA PANDAK Date: 2024.11.01 13:56:36 -05'00' Digitally signed by DEBRA PANDAK EPA REGION 6 Pandak.debra@epa.gov 1 of 8 Mississippi Canyon 778 A Thunder Horse, XFR982310252 Inspection Date(s): 09/03/2024 Click or tap here to enter text. SECTION I - INTRODUCTION Purpose of the Inspection Type of inspection: Compliance Evaluation Inspection On September 3, 2024, I, Dedriel Gardner, conducted an unannounced inspection of the Mississippi Canyon 778 A Thunder Horse (Thunder Horse) facility located at Latitude: 28.187698 Longitude: 88.490685 in federal waters, for compliance with the Resource Conservation and Recovery Act (RCRA). I was accompanied by Erin Young-Dahl, EPA Inspector, and Ronald McClary, Bureau of Safety and Environmental Enforcement (BSEE) Engineer. The EPA has been conducting a Port Initiative that focuses on RCRA hazardous waste management and compliance with inland facilities that accept RCRA regulated waste from offshore. Typically, hazardous waste determinations are made at the offshore point of generation prior to waste arrival onshore, which prompted this inspection at Thunder Horse with BSEE. The goals of the inspection were to observe and gather information on offshore platform wastegenerating operations and waste management prior to the wastes being shipped to shore. William Ferrel, Offshore Installation Manager, acted as the primary facility representative. I informed him this inspection would evaluate waste management activities. This report is based on information supplied by Mr. Ferrel and other attendees, inspector observations, and records including photographs taken (see Appendix 1), verbal or written statements made during or after the onsite inspection, and/or materials shown, demonstrated, or submitted to the EPA during or after the on-site inspection. In addition, information gathered prior to or after the inspection from a review of EPA, State, and public records may be included in this report. Document transfer was facilitated through the use of an electronic secure online drive. These documents are accessible by the EPA Enforcement Officer for review. Attendees Title/Organization Name Phone Email Lead Inspector/ Enforcement Officer/EPA Region 6 Dedriel Gardner (913) 551-7049 gardner.dedriel@epa.gov Inspector/EPA Region 6 Erin Young-Dahl (214) 665-3166 youngdahl.erin@epa.gov Opening Closing Conf. Conf. Yes Yes Yes Yes Engineer/BSEE Ronald McClary --- ronald.mcclary@bsee.gov Yes Yes BP Offshore Installation William Ferrel 979-235-2860 william.farrell2@bp.com Yes Yes Manager/Thunder Horse BP Health, Safety, Environment (HSE) Josh Wyatt 979-35-28572 josh.wyatt@bp.com Yes Yes BP Marine Team Lead Ed Hadden 979-235-2886 haeerl@bp.com Yes Yes BP Production Team Brandon Hilliard 979-235-2944 brandon.hilliard@bp.com Yes Yes Lead 2 of 8 Mississippi Canyon 778 A Thunder Horse, XFR982310252 Inspection Date(s): 09/03/2024 Click or tap here to enter text. BP Maintenance Team Michael A 979-235-2671 michael.cernuska@bp.com Yes Yes Lead Cernuska (Big Mac) Valaris Drilling Lance J Guillory 979-235-2871 lance.guillory@bp.com Yes Yes Contractor Offshore Installation Manager BP Site Services Lead Michael Ardoir 979-235-2853 michael.ardoir@bp.com Yes Yes BP Lead Well Site Leader Danos OLC Shawn 832-2489-7761 shawn.southworth@bp.com Yes Yes Southworth Ryan Nelson 985-498-8308 ryan.nelson@bp.com Yes Yes BP Well Site Leader Randall Reed 832-248-7761 randall.reed@bp.com Yes Yes SECTION II - OPENING CONFERENCE On September 3, 2024, Ms. Young-Dahl, Mr. McClary, and I arrived at the Thunder Horse platform. We met William Ferrel, Offshore Installation Manager, who acted as the primary facility representative and other attendees as listed on the sign-in sheet included as Appendix 2. We presented our credentials to Mr. Ferrel. I informed Mr. Ferrel that we were there to conduct an inspection of the facility under the authority of Section 3007 of RCRA and that this inspection would focus on waste management. I discussed EPA Region 6's Confidentiality Notice (40 CFR Section 2.203) for any potential Business Confidentiality Information claims by CHESI. I informed him that the inspection would include a discussion of facility operations, waste generation, and waste management as well as a visual inspection of the facility, including waste generation and management areas. I noted that due to time limitations I would leave a list of requested documents to be provided after the inspection. I set up the electronic secure online drive for documents to be uploaded. General Information: Thunder Horse is a moored semi-submersible oil and gas production, drilling, and quarters (PDQ) platform. It began operating around 2005 and is located about 150 miles southeast of New Orleans, Louisiana in the Mississippi Canyon of the Gulf of Mexico. It is owned 75 percent by BP Exploration and Production (BP) and 25 percent by ExxonMobile. It is operated 100 percent by BP. Currently, there are about 269 employees onsite. Thunder Horse was developed using mostly clustered subsea production and water injection wells, with some satellite subsea production and water wells. Currently, Thunder Horse has 22 online wells plus three injection water wells. The water depth varies between 5700 and 6500 ft. The crude oil pumped from the reservoir is de-sanded and separated into oil, natural gas, and water. Supporting operations include wastewater treatment (production, sanitary, storm water, and contaminated drains), natural gas power plant from gas produced, analytical lab, water plant, food disposal, air emission controls, and maintenance.. According to RCRAInfo, Thunder Horse last notified as a large quantity generator (LQG) of hazardous waste on February 29, 2024, and it routinely manifests hazardous wastes offsite. Also, they are a small quantity handler of universal waste and a used oil generator. 3 of 8 Mississippi Canyon 778 A Thunder Horse, XFR982310252 Inspection Date(s): 09/03/2024 Click or tap here to enter text. Waste Streams and Management Discussion: Thunder Horse works with disposal firm Heritage, who uses the "Kabal" system (logistic type management software) to track their wastes. Thunder Horse generates many types of waste streams, including hazardous, non-hazardous, exempt exploration and production (E&P), universal, electronic, municipal, Naturally Occurring Radioactive Material (NORM), RCRA-empty containers and hoses, and foreign wastes. During the inspection, not all waste streams were observed being generated since they were not routinely generated and/or not currently accumulated onsite. This included waste streams such as produced sands, empty container rinsate that is processed in the closed wastewater drain system, and laboratory wastes, which are added back into the process stream. In addition, the facility representatives stated that the following waste streams are not generated onsite: boiler-related wastes as Thunder Horse has no boilers onsite (although they generate heat exchanger cleaning wastes which a third party comes onsite as needed and cleans with only highpressure water); gas plant cooling tower wastes; incinerator ash; and radioactive wastes. Thunder Horse does not allow any unloading of wastes from vessels at the platform. Thunder Horse's offshore waste is shipped by vessel to BP's Fourchon Supply Base (BP-FSB) located at Port of Fourchon (POF) C-Port 3. A brief overall description of their waste management process from offshore to POF C-Port 3 was explained as follows: The Logistic Coordinator calls Heritage, who is available 24 hours, seven days per week. Heritage assists with making the hazardous waste determination and tells Thunder Horse how to manage the waste onsite and where to send it. If necessary, a sample of the waste may be sent to Heritage to help with a hazardous waste determination. Thunder Horse also has an Industrial Hygienist onsite to help with hazardous waste determinations. The hazardous waste is manifested from Thunder Horse to the BP-FSB at POF C-Port 3. In order that the 10-day transfer facility requirement is met, prior to shipping the waste to the BP-FSB, the shipments are coordinated with the waste contractor to ensure that the designated facility can receive the shipment. SECTION III - OBSERVATIONS The following waste management observations were made along with related Area of Concerns (AOC) noted at the time. 1. In the chemical storage area, we observed products being stored and the machinery related contaminated drain collection system that generates hydraulic oil/water that is sent to BP-FSB. No wastes were observed accumulated in the area. 2. In the Breezeway, we observed one approximately full container of electronic waste (see Appendix 1, Photos 1 and 2). 3. In the Universal Waste Storage Area (see Appendix 1, Photos 3 and 4), we observed an accumulation tracking log of the universal waste batteries and lamps (see Appendix 1, Photos 6 and 7). Also, we observed that the containers were dated and labeled universal waste "bulbs" as opposed to universal waste "lamps" (see Appendix 1, Photo 5). The log's accumulation start date and the dates on the containers did not agree, but both were still dated within one year. I 4 of 8 Mississippi Canyon 778 A Thunder Horse, XFR982310252 Inspection Date(s): 09/03/2024 Click or tap here to enter text. discussed with the facility representatives that the length of accumulation must be documented correctly as required by 40 CFR 273.15(c). 4. In the area where the crude oil first enters the platform, we observed a red safety can of nonhazardous oily rags and absorbent pads (see Appendix 1, Photos 8 and 9). The can is emptied daily into an Omega non-hazardous waste container (see #5 below). Prior to the crude oil reaching the platform, the hydraulic oil used on the subsea equipment may discharge small amounts to the sea at the control point (at the subsea infrastructure). A Safety Data Sheet (SDS) of this marine hydraulic oil was provided during the inspection (see Appendix 3). 5. In the Riser Area, we observed a container of non-hazardous rags and other rags, including oily rags. They were being shipped to Omega Waste Management in Patterson, Louisiana, as industrial non-hazardous waste (see Appendix 1, Photos 10, 11, and 12). 6. In the High Pressure (HP)/Intermediate Pressure (IP)/Low Pressure (LP) Separator Area, we observed the contents of a partially full Omega oily debris container. Facility personnel stated it contained exempt E&P waste but could potentially be mixed with hydraulic oil (see Appendix 1, Photos 13 and 14). AOC #1a: A hazardous waste determination must be made on each individual waste stream at the POG. - 40 CFR 262.11. I discussed with facility personnel the management of exempt E&P waste mixed with other wastes. After the inspection, Thunder Horse responded that they inspected containers onsite and were not able to locate any such container of mixed used oil and E&P wastes and that there could have been a miscommunication by one of their personnel. 7. Near the HP/IP/LP Separator Area, we observed two 55-gallon drums labeled as non-hazardous waste. One contained unused Crosstrans 206 electrical insulating oil and the other used blast media (see Appendix 1, Photos 15 thru 18, and 21). The SDS for the Crosstrans 206 was provided at the time to show that it was non-hazardous waste (see Appendix 4 for SDS). 8. In the General Trash Accumulation Area, we observed several supersacks of general trash. We looked inside one that appeared to contain general trash. Also, I looked in various trash containers throughout the visual inspection and no apparent concerns were noted. 9. Near the HP/IP/LP Separator Area, we observed plastic containers put inside three unlabeled full 55-gallon drums to await disposal (see Appendix 1, Photos 19 and 20). When picked up, the containers still held residual resin materials and therefore were not RCRA-empty. AOC #1b: A hazardous waste determination must be made for each individual waste stream at the POG. - 40 CFR 262.11. After the inspection, Thunder Horse stated that these drums were labeled hazardous waste and dated 9/1/24. 10. In the Aerosol Can Puncturing Area, we observed a partially full open aerosol can puncturing unit attached to a 55-gallon aerosol accumulation drum (i.e., the cap on the puncturing unit was opened) and no waste was being added or removed (see Appendix 1, Photo 22). AOC #2: A hazardous waste satellite accumulation container must remain closed unless adding or removing wastes. - 40 CFR 262.15(a)(4). This AOC was discussed during the inspection, after which the facility personnel closed it. 5 of 8 Mississippi Canyon 778 A Thunder Horse, XFR982310252 Inspection Date(s): 09/03/2024 Click or tap here to enter text. 11. In the Paint Waste Satellite Accumulation Area (SAA), we observed greater than 55 gallons of hazardous waste. Therefore, it was considered a Central Accumulation Area (CAA) at the time of the inspection and the following was noted: a. Approximately 3/4th full, 55-gallon drum of hazardous liquid paint waste was undated, and open (unsecured lid) (see Appendix 1, Photos 23, 24 and 31). AOC #3a: A hazardous waste accumulation container must be dated and remain closed unless adding or removing wastes. - 40 CFR 262.17(a)(5)(i)(C) and 262. 17(a)(1)(iv)(A). b. An undated, open (unsecured lid) approximately full, 55-gallon drum of hazardous waste paint and solvent contaminated rags and brushes (see Appendix 1, Photos 25, 26 and 27). AOC #3b: A hazardous waste accumulation container must be dated and remain closed unless adding or removing wastes. - 40 CFR 262.17(a)(5)(i)(C) and 262. 17(a)(1)(iv)(A). c. An undated, closed, full, 55-gallon drum of hazardous paint rags (see Appendix 1, Photo 32) located just outside of the yellow satellite accumulation containment shelter seen in Photo 27. AOC #3c: A hazardous waste accumulation container must be dated. - 40 CFR 262.17(a)(5)(i)(C). The above containers were closed and dated 9/1/24 during the inspection (see Appendix 1, Photos 33 and 34). Mr. Wyatt stated that normally they would not have the excess wastes in the SAA, but the CAA was currently full (i.e., contained four drums) and the crane used to move the drums was broken. 12. In the Paint Waste CAA, we observed four undated, closed, full, 55-gallon drums labeled as hazardous waste (see Appendix 1, Photos 35 thru 38). Mr. Wyatt stated that they all contained liquid paint waste. However, I observed one labeled liquid paint waste, two labeled paint solid debris (rags, rollers, brushes), and one label I could not see fully. AOC #3d: A hazardous waste accumulation container must be dated. - 40 CFR 262.17(a)(5)(i)(C). We also discussed how the labels must be visible to read. After the inspection, Thunder Horse stated that the containers were dated. 13. In the Waste Storage Area near the Paint Waste CAA, we observed 12 full 55-gallon drums of paint chips labeled as non-hazardous waste (see Appendix 1, Photos 39, 40, and 41. Paint chips are generated when paint is removed from platform equipment (e.g., decks, support beams). 14. In the Lab, the types of analyses conducted included water quality and Infrared. We did not observe any accumulated wastes. The lab wastes which are all sample related wastes (i.e., no separate types of waste generated including solvents) are added back into the process. SECTION IV - AREA OF CONCERN The Area(s) of Concern (AOC) noted at the time are as follows, although further EPA review may change or add to these concerns. 1. AOC #1: A hazardous waste determination not made for each individual waste stream at the POG. - 40 CFR 262.11. a. Omega container of exempt E&P waste that could potentially be mixed with hydraulic oil. b. Plastic containers put inside three unlabeled full 55-gallon drums to await disposal. 6 of 8 Mississippi Canyon 778 A Thunder Horse, XFR982310252 Inspection Date(s): 09/03/2024 Click or tap here to enter text. 2. AOC #2: A partially full, open, 55-gallon satellite accumulation drum with an open aerosol can puncturing unit attached. - 40 CFR 262.15(a)(4). 3. AOC #3: A hazardous waste accumulation container must be dated and remain closed unless adding or removing wastes. - 40 CFR 262.17(a)(5)(i)(C) and 262. 17(a)(1)(iv)(A). a. An undated, open (unsecured lid), approximately 3/4th full, 55-gallon drum of hazardous liquid paint waste. b. An undated, open (unsecured lid), approximately full, 55-gallon drum of hazardous waste paint and solvent contaminated rags and brushes. c. An undated closed full 55-gallon drum of hazardous paint rags. d. Four undated closed full 55-gallon drums of paint liquid and solid wastes labeled hazardous waste. SECTION V - CLOSING CONFERENCE AND FOLLOW UP Closing Conference: I closed out the inspection with the facility representatives listed on Appendix 2. I briefly reviewed the requested documents and AOCs noted at the time of the inspection. I informed Mr. Ferrel that later that day I would follow up with an email containing this information. No confidentiality business claims were made. We left the platform about 2:45 pm. Follow Up: On September 3, 2014, I emailed Thunder Horse an initial list of AOCs and requested documents. On September 6, 2024, Thunder Horse emailed their response to the AOCs (see Section III above for the AOCs addressed). On September 18, 2024, the documents/information uploaded/emailed included the following along with several comments I noted based on my initial brief review: 1. Clarification - The SDS provided during the inspection titled Transaqua HT is the marine hydraulic fluid that is used in their subsea control systems and discharges in small quantities to the sea at the control point (at the subsea infrastructure). See Appendix 3 for SDS. 2. Waste Logs/Tracking Documents for wastes being tracked, e.g., paint waste, universal waste, garbage, etc. This included Environmental Compliance Summaries, Universal Waste Logs, and Hazardous Waste Logs for 2024. Other waste tracking reports are available upon request by EPA. 3. Waste Stream Profiles along with supporting documents from BP's waste management contractor Heritage. a. I did not see a discussion of how samples were collected for the waste streams that were analyzed. This includes for an Omega Waste Management Recertification for the nonhazardous solid waste profile "NH Solid Waste - Oil Contaminated pads, boom, fuel & oil filters, RCRA containers, 5 scrap hoses, gloves, PPE, Oily Debris" that also included a January 17, 2024, analysis. The profile was dated December 5, 2023, with an expiration date of January 17, 2027, and a renewal date of January 17, 2025. However, this waste stream appears to be a mixture of some individual waste streams that would each require a hazardous waste determination made at their individual point of generation (POG). b. I was not able to determine which waste profile was for the non-hazardous "paint chips". 7 of 8 Mississippi Canyon 778 A Thunder Horse, XFR982310252 Inspection Date(s): 09/03/2024 Click or tap here to enter text. 4. Waste Management Plans/SOP - I did not note where "used oil" was specifically discussed in the waste management documents provided. However, it is profiled and shipped offsite as used oil on non-hazardous waste shipping documents that were uploaded. 5. Arrangements/Agreements with Heritage. 6. Shipping Documents (manifests, bills of lading, etc.) for each waste stream. 7. Facility Layout with hazardous waste accumulation areas. 8. Process Descriptions to include a Simplified Process Block Flow Overview and the first two sections of the Marine Operations Manual, which includes descriptions of the Thunder Horse facility itself as well as the production, drilling, and marine systems overview. 9. Emergency Response Plan and Gulf of Mexico (GoM) Regional Spill Response Plan. 10. Excerpt of Training Matrix showing the Hazardous Waste related training courses and groups/roles to which they are assigned. 11. Inspections of hazardous waste containers. 12. A List of Incidents/Spills for the past three years on the Thunder Horse facility. 13. Biohazard/Sharps wastes are managed by their Medics on-board the Thunder Horse facility. They utilize Stericycle pre-paid 5-gallon soft waste and 2-gallon sharps disposal containers with pre-paid return/disposal packaging. I did not see any mention of pharmaceuticals. SECTION VI - LIST OF APPENDICES Appendix 1 Appendix 2 Appendix 3 Appendix 4 - Photo Log In-Brief/Out-Brief Sign-In Sheet Transaqua HT SDS Crosstrans 206 SDS 8 of 8 BP Exploration & Production - Mississippi Canyon 778 A Thunder Horse Inspection Date: 09/03/2024 Appendix 1 Photograph Log UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: BP Exploration & Production - Mississippi Canyon 778 A Thunder Horse City: Lat: 28.187698 Long: -88.490685 County/Parish: Federal Waters State: Federal Waters Photo File Name: POB_0084 Date of Photo: 09/03/2024 Time of Photo: 1146 Photographer: Erin Young-Dahl Description: Contents of e-waste container. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: BP Exploration & Production - Mississippi Canyon 778 A Thunder Horse City: Lat: 28.187698 Long: -88.490685 County/Parish: Federal Waters State: Federal Waters Photo File Name: POB_0085 Date of Photo: 09/03/2024 Time of Photo: 1146 Photographer: Erin Young-Dahl Description: Overview of approximately full e-waste container. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: BP Exploration & Production - Mississippi Canyon 778 A Thunder Horse City: Lat: 28.187698 Long: -88.490685 County/Parish: Federal Waters State: Federal Waters Photo File Name: POB_0086 Date of Photo: 09/03/2024 Time of Photo: 1148 Photographer: Erin Young-Dahl Description: Overview of Universal Waste storage area, focusing on bulb and lamp area. Containers are partially full to full. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: BP Exploration & Production - Mississippi Canyon 778 A Thunder Horse City: Lat: 28.187698 Long: -88.490685 County/Parish: Federal Waters State: Federal Waters Photo File Name: POB_0087 Date of Photo: 09/03/2024 Time of Photo: 1148 Photographer: Erin Young-Dahl Description: Overview of Universal Waste batteries/ballast area. Containers are partially full to full. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: BP Exploration & Production - Mississippi Canyon 778 A Thunder Horse City: Lat: 28.187698 Long: -88.490685 County/Parish: Federal Waters State: Federal Waters Photo File Name: POB_0088 Date of Photo: 09/03/2024 Time of Photo: 1148 Photographer: Erin Young-Dahl Description: Closeup of Universal Waste bulbs label. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: BP Exploration & Production - Mississippi Canyon 778 A Thunder Horse City: Lat: 28.187698 Long: -88.490685 County/Parish: Federal Waters State: Federal Waters Photo File Name: POB_0089 Date of Photo: 09/03/2024 Time of Photo: 1149 Photographer: Erin Young-Dahl Description: Closeup of Universal Waste batteries generation log. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: BP Exploration & Production - Mississippi Canyon 778 A Thunder Horse City: Lat: 28.187698 Long: -88.490685 County/Parish: Federal Waters State: Federal Waters Photo File Name: POB_0090 Date of Photo: 09/03/2024 Time of Photo: 1150 Photographer: Erin Young-Dahl Description: Closeup of Universal Waste bulbs generation log. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: BP Exploration & Production - Mississippi Canyon 778 A Thunder Horse City: Lat: 28.187698 Long: -88.490685 County/Parish: Federal Waters State: Federal Waters Photo File Name: POB_0091 Date of Photo: 09/03/2024 Time of Photo: 1157 Photographer: Erin Young-Dahl Description: Closeup of label on oily waste can containing rags and absorbent pads that is emptied daily into an Omega non-hazardous waste container. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 Location: BP Exploration & Production - Mississippi Canyon 778 A Thunder Horse City: Lat: 28.187698 Long: -88.490685 County/Parish: Federal Waters State: Federal Waters Photo File Name: POB_0092 Date of Photo: 09/03/2024 Time of Photo: 1157 Photographer: Erin Young-Dahl Description: Contents of oily waste can from Photo 8. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 10 Location: BP Exploration & Production - Mississippi Canyon 778 A Thunder Horse City: Lat: 28.187698 Long: -88.490685 County/Parish: Federal Waters State: Federal Waters Photo File Name: POB_0093 Date of Photo: 09/03/2024 Time of Photo: 1224 Photographer: Erin Young-Dahl Description: Overview of Omega non-hazardous oily rags container in Riser Area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 11 Location: BP Exploration & Production - Mississippi Canyon 778 A Thunder Horse City: Lat: 28.187698 Long: -88.490685 County/Parish: Federal Waters State: Federal Waters Photo File Name: POB_0094 Date of Photo: 09/03/2024 Time of Photo: 1224 Photographer: Erin Young-Dahl Description: Closeup of Omega oily rags container in Riser Area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 12 Location: BP Exploration & Production - Mississippi Canyon 778 A Thunder Horse City: Lat: 28.187698 Long: -88.490685 County/Parish: Federal Waters State: Federal Waters Photo File Name: POB_0095 Date of Photo: 09/03/2024 Time of Photo: 1224 Photographer: Erin Young-Dahl Description: Contents of Omega container in Riser Area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 13 Location: BP Exploration & Production - Mississippi Canyon 778 A Thunder Horse City: Lat: 28.187698 Long: -88.490685 County/Parish: Federal Waters State: Federal Waters Photo File Name: POB_0096 Date of Photo: 09/03/2024 Time of Photo: 12:51 Photographer: Erin Young-Dahl Description: Contents of oily debris container in HP/IP/LP Separator Area. Facility personnel stated it contained E&P waste potentially mixed with hydraulic oil. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 14 Location: BP Exploration & Production - Mississippi Canyon 778 A Thunder Horse City: Lat: 28.187698 Long: -88.490685 County/Parish: Federal Waters State: Federal Waters Photo File Name: POB_0097 Date of Photo: 09/03/2024 Time of Photo: 1251 Photographer: Erin Young-Dahl Description: Overview of oily debris container in HP/IP/LP Separator Area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 15 Location: BP Exploration & Production - Mississippi Canyon 778 A Thunder Horse City: Lat: 28.187698 Long: -88.490685 County/Parish: Federal Waters State: Federal Waters Photo File Name: POB_0098 Date of Photo: 09/03/2024 Time of Photo: 1253 Photographer: Erin Young-Dahl Description: Two 55-gallon drums containing unused CrossTrans 206 electrical insulating oil (left of photo) and used blast media (right of photo). Located near the HP/IP/LP Separator Area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 16 Location: BP Exploration & Production - Mississippi Canyon 778 A Thunder Horse City: Lat: 28.187698 Long: -88.490685 County/Parish: Federal Waters State: Federal Waters Photo File Name: POB_0100 Date of Photo: 09/03/2024 Time of Photo: 1253 Photographer: Erin Young-Dahl Description: Closeup of manufacturer's label on unopened waste oil drum seen in Photo 15. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 17 Location: BP Exploration & Production - Mississippi Canyon 778 A Thunder Horse City: Lat: 28.187698 Long: -88.490685 County/Parish: Federal Waters State: Federal Waters Photo File Name: POB_101 Date of Photo: 09/03/2024 Time of Photo: 1255 Photographer: Erin Young-Dahl Description: Contents of drum seen in Photo 15 containing used blast media. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 18 Location: BP Exploration & Production - Mississippi Canyon 778 A Thunder Horse City: Lat: 28.187698 Long: -88.490685 County/Parish: Federal Waters State: Federal Waters Photo File Name: POB_0102 Date of Photo: 09/03/2024 Time of Photo: 1256 Photographer: Erin Young-Dahl Description: Closeup of label on used blast media drum of Photos 15 and 17. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 19 Location: BP Exploration & Production - Mississippi Canyon 778 A Thunder Horse City: Lat: 28.187698 Long: -88.490685 County/Parish: Federal Waters State: Federal Waters Photo File Name: POB_0103 Date of Photo: 09/03/2024 Time of Photo: 1308 Photographer: Erin Young-Dahl Description: Plastic containers put in 55-gallon drum to await disposal. Containers still held residual resin materials. Located near the HP/IP/LP Separator Area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 20 Location: BP Exploration & Production - Mississippi Canyon 778 A Thunder Horse City: Lat: 28.187698 Long: -88.490685 County/Parish: Federal Waters State: Federal Waters Photo File Name: POB_0104 Date of Photo: 09/03/2024 Time of Photo: 1308 Photographer: Erin Young-Dahl Description: Overview of container storage area housing 3 unlabeled full drums of plastic containers with residual resins inside. Far back left container held lithium batteries. Contents of open container seen in Photo 19. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 21 Location: BP Exploration & Production - Mississippi Canyon 778 A Thunder Horse City: Lat: 28.187698 Long: -88.490685 County/Parish: Federal Waters State: Federal Waters Photo File Name: POB_0105 Date of Photo: 09/03/2024 Time of Photo: 1310 Photographer: Erin Young-Dahl Description: Another view of container storage area of Photo 17 & 18 with lid replaced on drum seen in Photo 17. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 22 Location: BP Exploration & Production - Mississippi Canyon 778 A Thunder Horse City: Lat: 28.187698 Long: -88.490685 County/Parish: Federal Waters State: Federal Waters Photo File Name: POB_0106 Date of Photo: 09/03/2024 Time of Photo: 1316 Photographer: Erin Young-Dahl Description: Overview of aerosol can puncturing area. Note that metal cap is not replaced on aerosol can tube (blue arrow) attached to a partially full 55-gallon drum. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 23 Location: BP Exploration & Production - Mississippi Canyon 778 A Thunder Horse City: Lat: 28.187698 Long: -88.490685 County/Parish: Federal Waters State: Federal Waters Photo File Name: POB_0107 Date of Photo: 09/03/2024 Time of Photo: 1320 Photographer: Erin Young-Dahl Description: Drum in paint waste satellite accumulation area (see Photo 27). Container lid was not secured. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 24 Location: BP Exploration & Production - Mississippi Canyon 778 A Thunder Horse City: Lat: 28.187698 Long: -88.490685 County/Parish: Federal Waters State: Federal Waters Photo File Name: POB_0108 Date of Photo: 09/03/2024 Time of Photo: 1321 Photographer: Erin Young-Dahl Description: Contents of approximately 3/4th full paint waste drum in SAA seen in Photo 23. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 25 Location: BP Exploration & Production - Mississippi Canyon 778 A Thunder Horse City: Lat: 28.187698 Long: -88.490685 County/Parish: Federal Waters State: Federal Waters Photo File Name: POB_0109 Date of Photo: 09/03/2024 Time of Photo: 1321 Photographer: Erin Young-Dahl Description: Paint- and solvent-contaminated rags and brushes found in a paint waste drum in SAA shown in Photo 27. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 26 Location: BP Exploration & Production - Mississippi Canyon 778 A Thunder Horse City: Lat: 28.187698 Long: -88.490685 County/Parish: Federal Waters State: Federal Waters Photo File Name: POB_0110 Date of Photo: 09/03/2024 Time of Photo: 1321 Photographer: Erin Young-Dahl Description: Closeup of label of paint- and solvent-contaminated wastes found in SAA (see Photo 25). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 27 Location: BP Exploration & Production - Mississippi Canyon 778 A Thunder Horse City: Lat: 28.187698 Long: -88.490685 County/Parish: Federal Waters State: Federal Waters Photo File Name: POB_0111 Date of Photo: 09/03/2024 Time of Photo: 1321 Photographer: Erin Young-Dahl Description: Overview of paint waste SAA containing one full drum of paint- and thinner-contaminated wastes (on left) and 3/4-full drum of liquid paint waste (on right). Neither lid was secured. Two pails of dried paint were placed between the two drums. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 28 Location: BP Exploration & Production - Mississippi Canyon 778 A Thunder Horse City: Lat: 28.187698 Long: -88.490685 County/Parish: Federal Waters State: Federal Waters Photo File Name: POB_0112 Date of Photo: 09/03/2024 Time of Photo: 1322 Photographer: Erin Young-Dahl Description: Small bucket containing dried paint in the SAA. Bucket is not the original paint packaging. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 29 Location: BP Exploration & Production - Mississippi Canyon 778 A Thunder Horse City: Lat: 28.187698 Long: -88.490685 County/Parish: Federal Waters State: Federal Waters Photo File Name: POB_0113 Date of Photo: 09/03/2024 Time of Photo: 1322 Photographer: Erin Young-Dahl Description: Small bucket of dried paint in the SAA tucked between the two drums seen in Photo 27. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 30 Location: BP Exploration & Production - Mississippi Canyon 778 A Thunder Horse City: Lat: 28.187698 Long: -88.490685 County/Parish: Federal Waters State: Federal Waters Photo File Name: POB_0114 Date of Photo: 09/03/2024 Time of Photo: 1323 Photographer: Erin Young-Dahl Description: Manufacturer's label of paint can seen in Photo 29. Found in paint waste SAA. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 31 Location: BP Exploration & Production - Mississippi Canyon 778 A Thunder Horse City: Lat: 28.187698 Long: -88.490685 County/Parish: Federal Waters State: Federal Waters Photo File Name: POB_0115 Date of Photo: 09/03/2024 Time of Photo: 1323 Photographer: Erin Young-Dahl Description: Closeup of label on paint waste drum in SAA, seen in Photos 23 & 24. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 32 Location: BP Exploration & Production - Mississippi Canyon 778 A Thunder Horse City: Lat: 28.187698 Long: -88.490685 County/Parish: Federal Waters State: Federal Waters Photo File Name: POB_0116 Date of Photo: 09/03/2024 Time of Photo: 1328 Photographer: Erin Young-Dahl Description: Closeup of label on paint rags drum seen in Photos 33 and 34. No accumulation start date noted. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 33 Location: BP Exploration & Production - Mississippi Canyon 778 A Thunder Horse City: Lat: 28.187698 Long: -88.490685 County/Parish: Federal Waters State: Federal Waters Photo File Name: POB_0117 Date of Photo: 09/03/2024 Time of Photo: 1329 Photographer: Erin Young-Dahl Description: Closeup of label on paint rags drum (see Photo 34). Drum was located just outside of containment shelter seen in Photo 27. Accumulation start date added during the inspection. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 34 Location: BP Exploration & Production - Mississippi Canyon 778 A Thunder Horse City: Lat: 28.187698 Long: -88.490685 County/Parish: Federal Waters State: Federal Waters Photo File Name: POB_0118 Date of Photo: 09/03/2024 Time of Photo: 1329 Photographer: Erin Young-Dahl Description: Paint rags drum shown in Photos 32 and 33 located just outside containment shelter seen in Photo 27. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 35 Location: BP Exploration & Production - Mississippi Canyon 778 A Thunder Horse City: Lat: 28.187698 Long: -88.490685 County/Parish: Federal Waters State: Federal Waters Photo File Name: POB_0119 Date of Photo: 09/03/2024 Time of Photo: 1330 Photographer: Erin Young-Dahl Description: Overview of paint waste central accumulation area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 36 Location: BP Exploration & Production - Mississippi Canyon 778 A Thunder Horse City: Lat: 28.187698 Long: -88.490685 County/Parish: Federal Waters State: Federal Waters Photo File Name: POB_0120 Date of Photo: 09/03/2024 Time of Photo: 1330 Photographer: Erin Young-Dahl Description: Closeup of label on a drum in the paint waste CAA. No accumulation start date noted. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 37 Location: BP Exploration & Production - Mississippi Canyon 778 A Thunder Horse City: Lat: 28.187698 Long: -88.490685 County/Parish: Federal Waters State: Federal Waters Photo File Name: POB_0121 Date of Photo: 09/03/2024 Time of Photo: 1330 Photographer: Erin Young-Dahl Description: Closeup of label on a drum in the paint waste CAA. No accumulation start date noted. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 38 Location: BP Exploration & Production - Mississippi Canyon 778 A Thunder Horse City: Lat: 28.187698 Long: -88.490685 County/Parish: Federal Waters State: Federal Waters Photo File Name: POB_0122 Date of Photo: 09/03/2024 Time of Photo: 1331 Photographer: Erin Young-Dahl Description: Closeup of label on a drum in the paint waste CAA. No accumulation start date noted. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 39 Location: BP Exploration & Production - Mississippi Canyon 778 A Thunder Horse City: Lat: 28.187698 Long: -88.490685 County/Parish: Federal Waters State: Federal Waters Photo File Name: POB_0123 Date of Photo: 09/03/2024 Time of Photo: 1334 Photographer: Erin Young-Dahl Description: Overview of collection of drums containing paint chips in waste storage area. Same drums as in Photo 40. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 40 Location: BP Exploration & Production - Mississippi Canyon 778 A Thunder Horse City: Lat: 28.187698 Long: -88.490685 County/Parish: Federal Waters State: Federal Waters Photo File Name: POB_-124 Date of Photo: 09/03/2024 Time of Photo: 1334 Photographer: Erin Young-Dahl Description: Overview of collection of nine drums containing paint chips in waste storage area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 41 Location: BP Exploration & Production - Mississippi Canyon 778 A Thunder Horse City: Lat: 28.187698 Long: -88.490685 County/Parish: Federal Waters State: Federal Waters Photo File Name: POB_0125 Date of Photo: 09/03/2024 Time of Photo: 1335 Photographer: Erin Young-Dahl Description: Overview of collection of three drums containing paint chips in waste storage area. Same type of drums as in Photo 40. The yellow drum did not contain waste. APPENDIX 2 - In-Brief/Out-Brief Sign-In Sheet APPENDIX 3 - Transaqua HT SDS APPENDIX 4 - Crosstrans 206 SDS