Document zz0j4zM1qM43qXb129a8Zzyog

Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 10 Enforcement Division INSPECTION REPORT 07/10/2023 09:40 AM (AKT) Announced: No 07/12/2023 09:25 AM (AKT) Access: Granted RCRA Compliance Evaluation Inspection (CEI) 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/Secondary Address Hilcorp North Slope, LLC Hilcorp North Slope Prudhoe Bay Unit AKD000643239 Prudhoe Bay Unit Prudhoe Bay, AK 99734 North Slope Borough Large Quantity Generator and Permitted TSDF 211120 Crude oil production field 70.293892, -148.704274 Ms. Amy Peloza, Environmental Team Manager - Kenai and NS Field Teams 3800 Centerpoint Drive, Suite 1400 Anchorage, AK 99503 apeloza@hilcorp.com CC: Matt Laskey/Vic Farris AlaskaNS-PB-WasteCoord@hilcorp.com Shane Umatum /Jeff Shannon AlaskaNS-PB-WasteTech@hilcorp.com City, State, Zip Code Anchorage, AK 99503 Permit Number (If Applicable) AKD000643239 Lead Inspector: Jon Jones EPA Region 10 Supervisor Review: Matt Quarterman EPA Region 10 Jones.Jon@epa.gov (907) 271-6329 Quarterman.matthew@epa.gov (206) 553-2146 1 of 21 Bp Exploration Alaska Prudhoe Bay Inspection Date(s): SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection Type of inspection: Compliance Evaluation Inspection (CEI) 07/10/2023 - 07/12/2023 EPA Region 10 Lead Inspector, Jon Jones, arrived at the Hilcorp North Slope Prudhoe Bay Unit Facility (the "Site" or "Facility"), located at Prudhoe Bay Unit, Prudhoe Bay, AK 99734, at 09:40 AM (AKT) on 07/10/2023 for an unannounced inspection. EPA Region 10 Lead Inspector presented credentials to and informed Matt Laskey that this was an EPA Region 10 inspection to determine compliance with Resource Conservation and Recovery Act (RCRA). 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 2023. This report is based on information supplied by Hilcorp North Slope Prudhoe Bay Unit Facility representatives, observations made by the EPA Region 10 inspector, and records and reports maintained by the facility and its HQ including, but not limited to: direct observations made by the EPA Region 10 Inspector(s), photographs taken by EPA Region 10 inspector(s), physical evidence collected by the EPA Region 10 inspector(s), measurements or samples taken by EPA Region 10 inspector(s), verbal or written statements made by information supplied by the facility representatives during or subsequent to the on-site Inspection, and materials, processes, data, photographs, or documents shown, demonstrated, or submitted to the EPA Region 10 inspector(s) by the facility representatives during or subsequent to the on-site Inspection. In addition, information gathered prior to or subsequent to the Inspection from a review of USEPA, State, and public records may be included in this report. Attendees Title/Organization Name Phone Lead Inspector/EPA Jon Jones REGION 10 (907) 2716329 RCRA Inspector/EPA Region 10 Matt Quarterman (206) 5532146 RCRA Inspector-intraining/Alaska Department of Environmental Conservation (ADEC) Alan Pefley (907) 2694567 Environmental Team Manager Kenai and North Slope Field Teams/Hilcorp Alaska, LLC Amy Peloza (907) 7778348 Alaska North Slope- Shane Umatum (907) 659- Prudhoe Bay-Waste 4705 Email Jones.Jon@epa.gov Opening Conf. Yes quarterman.matthew@epa.gov No pefley.alan@alaska.gov No apeloza@hilcorp.com No AlaskaNS-PB- Yes WasteTech@hilcorp.com 2 of 21 Closing Conf. Yes Yes Yes Yes Yes Bp Exploration Alaska Prudhoe Bay Inspection Date(s): 07/10/2023 - 07/12/2023 Technician/Hilcorp North Slope Prudhoe Bay Unit Hazardous Waste Matt Laskey (907) 659- AlaskaNS-PB- Yes Yes Coordinator/Hilcorp 4810 WasteCoord@hilcorp.com North Slope Prudhoe Bay Unit Environmental Health and Safety Director/Hilcorp Alaska, LLC Laura Green No Yes Operations Manager, PBU Power and Gas/Hilcorp North Slope Prudhoe Bay Unit Tim Johnson No Yes Operations Manager, PBU East/Hilcorp North Slope Prudhoe Bay Unit Bo York No Yes Opening Conference We arrived at the Facility 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. Facility/Site Information 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. What type of generator facility verified as? What type of generator facility notified? Large Quantity Generator verified by Matt Laskey Large Quantity Generator (LQG) 3 of 21 Bp Exploration Alaska Prudhoe Bay Inspection Date(s): 07/10/2023 - 07/12/2023 Size of Facility Safety Training Provided to Inspector(s)? Operating Hours Length of Facility at Location Weather Conditions 213,543 acres No 24/7/365 Since the 1960's Day 1 - Partly cloudy, Day 2 - Sunny, Day 3 - Cloudy and raining 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 Facility's standardized RCRA permit went into effect on September 30, 2021, and shall remain in effect through September 29, 2031. According to Mr. Laskey, there have been no significant changes at the facility since the June 2021 RCRA inspection. Building(s) Building/Area/Sub-area Comm Center Drill Site L4 Flow Station 2 SAA Flow Station 3 SAA Mod 4924 Mod 4944 Weld Shop Gathering Center 3 (GC3) Skid 7 GC 2 Grind and Inject (G&I) Hazardous Waste Process Facility (HWPF) Hover craft hangar SAA L Pad Innovation Rig Prudhoe Bay Operations Center Process Description SAA SAA SAA SAA Maintenance Mod SAA SAA This is the facility's permitted hazardous waste storage building. Houses hover craft for transportation to Northstar, another Hilcorp production facility. SAA Drill Rig Area of Concern No No Yes Yes Yes Yes Yes Yes Yes No No No No No No No Yes Yes No 4 of 21 Bp Exploration Alaska Prudhoe Bay Inspection Date(s): 07/10/2023 - 07/12/2023 A209 Safety Instrumentation SAA STP 4921 Drive thru SAA Z Pad SAA SECTION II - OBSERVATIONS Building: STP/4921 Drive thru Observation #: JJ1-OB-001 Date: 07/10/2023 Person Interviewed: Bret Lambert No Yes Yes No Contains AOC: Yes Title: Operations Lead Contains CBI: No At the time of inspection, we saw a 15-gallon SAA container of waste solvent rags that was not marked with a hazard indicator that was specific to the hazard. The container was marked with a DOT Class 9 label. Hazard indicators are required to be specific to the hazard and a DOT Class 9 label does not meet this requirement. The word "TOXIC" was added to the label during the inspection. Photo(s) 1. IMG-20230710111224122469308.jpg 2. IMG-20230710111610161073126.jpg 3. IMG-20230710111852185271812.jpg Building: Flow Station 2 Observation #: JJ1-OB-005 Date: 07/10/2023 Person Interviewed: Shane Umatum Contains AOC: Yes Contains CBI: No Title: Alaska NS-Prudhoe Bay-Waste Technician While checking-in with the Operator at Flow Station 2, we saw a battery on a counter that was marked with the word "BAD." The battery was verified by facility personnel to be a waste battery. The facility manages their waste batteries as universal waste. At the time of the inspection, the battery was not labeled with either the phrase "Universal Waste - Battery," "Waste Battery," or "Used Battery." Mr. Umatum took the waste battery to the Flow Station 2 SAA and placed it into the designated universal waste container for waste batteries. Photo(s) 1. IMG-20230710144630463059575.jpg 2. IMG-20230710144636463680218.jpg Building: Flow Station 2/SAA Observation #: JJ1-OB-006 Date: 07/10/2023 Person Interviewed: Shane Umatum Contains AOC: Yes Contains CBI: No Title: Alaska NS-Prudhoe Bay-Waste Technician At the time of inspection, we saw a 15-gallon SAA container of waste solvent rags that was not marked with an appropriate hazard indicator. The container was marked with a DOT Class 9 label. Hazard indicators are required to be specific to the hazard and a DOT Class 9 label does not meet this requirement. The word "TOXIC" was added to the label during the inspection. 5 of 21 Bp Exploration Alaska Prudhoe Bay Inspection Date(s): Photo(s) 1. IMG-20230710144944494469634.jpg 2. IMG-20230710145221522162477.jpg 07/10/2023 - 07/12/2023 Building: L Pad/Innovation Rig Observation #: JJ1-OB-009 Date: 07/11/2023 Person Interviewed: Shane Umatum Contains AOC: Yes Contains CBI: No Title: Alaska NS-Prudhoe Bay-Waste Technician At the time of inspection, we saw a 55-gallon SAA container of waste glycol that was not marked with an appropriate hazard indicator. The container was marked with a DOT Class 9 label. Hazard indicators are required to be specific to the hazard and a DOT Class 9 label does not meet this requirement. The word "TOXIC" was added to the label during the inspection. Photo(s) 1. IMG-20230711091114111478049.jpg 2. IMG-20230711091233123387851.jpg 3. IMG-20230711091243124392769.jpg 4. IMG-20230711091251125192111.jpg Building: Flow Station 3/SAA/Mod 4924 Observation #: JJ1-OB-013 Date: 07/11/2023 Contains AOC: Yes Contains CBI: No Person Interviewed: Shane Umatum Title: Waste Technician At the time of inspection, we saw a 15-gallon SAA container of waste solvent rags that was not marked with an appropriate hazard indicator. The container was marked with a DOT Class 9 label. Hazard indicators are required to be specific to the hazard and a DOT Class 9 label does not meet this requirement. The word "TOXIC" was added to the label during the inspection. Photo(s) 1. IMG-20230711132714271484626.jpg 2. IMG-20230711132816281684552.jpg Building: Flow Station 3/SAA/Mod 4944 Observation #: JJ1-OB-014 Date: 07/11/2023 Person Interviewed: Shane Umatum Contains AOC: Yes Title: Waste Technician Contains CBI: No At the time of inspection, we saw a 15-gallon SAA container of waste solvent rags that was not marked with an appropriate hazard indicator. The container was marked with a DOT Class 9 label. Hazard indicators are required to be specific to the hazard and a DOT Class 9 label does not meet this requirement. The word "TOXIC" was added to the label during the inspection. Photo(s) 1. IMG-20230711134450445082200.jpg 2. IMG-20230711134520452088409.jpg 6 of 21 Bp Exploration Alaska Prudhoe Bay Inspection Date(s): 07/10/2023 - 07/12/2023 Building: Hazardous Waste Process Facility (HWPF) Observation #: JJ1-OB-015 Date: 07/11/2023 Contains AOC: No Contains CBI: No Person Interviewed: Matt Laskey Title: Waste Coordinator The areas of the floor in the HWPF that were observed during the last inspection as areas where the floor sealant was damaged and identified as an area of concern had been repaired since the last inspection. Photo(s) 1. IMG-20230711143823382395998.jpg 2. IMG-20230711143830383085256.jpg 3. IMG-20230711143836383679560.jpg 4. IMG-20230711143852385285412.jpg Building: Hilcorp North Slope Prudhoe Bay Unit Observation #: JJ1-OB-016 Date: 07/12/2023 Person Interviewed: Amy Peloza Contains AOC: Yes Contains CBI: No Title: Environmental Team Manager - Kenai and North Slope Field Teams During the closing conference on 7/12/23, I told Ms. Peloza that I had seen her facility's latest correspondence, with Ms. Xiangyu Chu, EPA, regarding the Hilcorp waste determination for waste leather gloves. In the facility's waste determination, Ms. Peloza stated that those waste leather gloves contaminated with hazardous waste would be managed as hazardous waste and those waste leather gloves contaminated with oily waste would be managed with the oily waste as non-hazardous waste. I asked Ms. Peloza if they were currently managing the waste leather gloves in this manner, and she said they were. I told Ms. Peloza that I had not seen any SAA containers that were being used to accumulate the waste leather gloves that were contaminated with hazardous waste. Ms. Peloza told me that the waste leather gloves that were contaminated with hazardous waste were being managed in the SAA containers that held waste solvent rags. The facility's oily waste is being managed as a solid waste and is being disposed of at the Oxbow Landfill. The oily waste at the facility is currently being double bagged and loaded into roll-off boxes that have a capacity of ~27 cubic yards. Following the Hilcorp inspection on 7/12/23, I conducted a RCRA inspection at the Oxbow Landfill on the same day (7/12/23). The Oxbow Landfill is owned by the North Slope Borough and operated by Ice Services. During the inspection of the landfill, I spoke with the Ice Services Landfill Supervisor about the oily waste coming from Hilcorp. I was walked through the management process for the oily waste and told that landfill personnel sort through all of the oily waste bags that come into their facility. According to the Landfill Supervisor, they receive oily waste bags that either contain very little oily waste or some that are contaminated with oily waste. The bags that appear to contain little to no oily waste contamination are removed and placed into another roll-off container and then buried in the landfill. Those bags that appear to be contaminated with varying amounts of oil waste are placed into ~1.7 cubic yard boxes. Bags that contain excess oily waste liquids are poured into a container and absorbent pads/boom are added to absorb the liquids. The waste is bagged again and placed into the 1.7 cu yd boxes. According to the Landfill Supervisor, approximately 50% of the oily waste is buried in the landfill and the other 50% is sent down to Waste to Energy facility in Spokane, WA for incineration. I asked both the Landfill Operator and Landfill Supervisor if they were seeing leather gloves in bags of oily waste that come into their facility and they told me they were. I asked the Landfill Supervisor how many they were seeing 7 of 21 Bp Exploration Alaska Prudhoe Bay Inspection Date(s): 07/10/2023 - 07/12/2023 each month and I was told they were seeing at least 50 to 100 leather gloves a month. EPA views waste leather gloves as a potential, hazardous waste and generators of waste leather gloves are finding that this waste fails TCLP for chromium. At the time of the inspection, Hilcorp NS PBU was sending unmanifested waste leather gloves to an out-of-state, unpermitted incinerator via an unpermitted local disposal facility. SECTION III - RECORDS REVIEW Record: Others Ref #: JJ1-RR-001 Reviewed By: Jon Jones AOC: Yes Reviewed Date: 07/28/2023 At the time of the inspection, I asked for records related to the procurement of leather gloves that were purchased by the facility since the last RCRA compliance inspection on 6/16-17/2021. The facility provided this information in an email, dated 7/26/2023. The spreadsheet provided by the facility lists both the type and number of gloves purchased. During my review of the spreadsheet, I highlighted those gloves that were either all leather or were comprised of other materials that included a leather palm. A review of the items on the spreadsheet showed that 4,182 pairs of gloves had been procured between 6/16/2021 and 7/12/2023. According to Ms. Peloza, waste leather gloves generated at the facility are managed as both hazardous waste in the waste solvent rag waste stream and as oily waste which is managed as solid waste. The facility's oily waste is disposed of at the Oxbow Landfill where they sorted, based on the degree of oily waste contamination, and either buried in the landfill or shipped to an Incinerator in Spokane, WA. Neither the Oxbow Landfill, in Prudhoe Bay, nor the Incinerator in Spokane, WA. are permitted hazardous waste disposal facilities. Document(s) 1. Stock Leather Gloves 07.17.2023.pdf Record: List of Waste Streams or Waste Stream tracking documents Ref #: JJ1-RR-002 Reviewed By: Jon Jones AOC: Yes Reviewed Date: 07/28/2023 During the inspection, I asked for a list of the SAAs where the facility's waste solvent rags were being generated. The list of waste solvent rag SAAs was provided in an email, dated 7/26/2023. After reviewing the list, I saw that there were a total of 38 SAAs where the waste solvents rags were being accumulated. According to Mr. Umatum, all of these satellite accumulation containers were marked with a Class 9 DOT label for a hazard indicator. I explained during the inspection that the Class 9 DOT label was not specific to the hazard. Several of these SAAs were inspected on 7/10/2023 and Mr. Umatum added a label to each of the waste solvent rag containers that included the word "TOXIC." On 7/11/2023 while inspecting another waste solvent rag SAA, I saw that the container had been marked with the word "TOXIC" as the hazard indicator. I asked Mr. Umatum about the marking, and he explained that after the first day of the inspection, he went to the remaining SAAs and applied the "TOXIC" hazard indicator to the remaining containers. Document(s) 1. PB Solvent Rag SAA Locations.pdf SECTION IV - AREA OF CONCERN The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation. 8 of 21 Bp Exploration Alaska Prudhoe Bay Inspection Date(s): Building: STP JJ1-OB-001 Area: 4921 Drive thru At the time of inspection, there was a 15-gallon SAA container of waste solvent rags that was marked with a hazard indicator that was not specific to the hazard. The container was marked with a DOT Class 9 label. Citations: Building: Flow Station 2 JJ1-OB-005 Area: A waste battery was observed on a countertop, just outside the control room, marked with the word "BAD.". At the time of the inspection, the battery was not labeled with either the phrase "Universal Waste - Battery," "Waste Battery," or "Used Battery." Citations: Building: Flow Station 2 JJ1-OB-006 Area: SAA An SAA container was not marked Citations: with a hazard indicator that was specific to the hazard. The container was marked with a DOT Class 9 label. Building: L Pad JJ1-OB-009 Area: Innovation Rig A 55-gallon SAA container of waste Citations: glycol was not marked with a hazard indicator that was specific to the hazard. The container was marked with a DOT Class 9 label. Building: Flow Station 3 JJ1-OB-013 Area: SAA At the time of inspection, there was Citations: a 15-gallon SAA container of waste solvent rags that was marked with a hazard indicator that was not specific to the hazard. The container 9 of 21 07/10/2023 - 07/12/2023 Sub-area: Sections: Sub-area: Sections: Sub-area: Sections: Sub-area: Sections: Sub-area: Mod 4924 Sections: Bp Exploration Alaska Prudhoe Bay Inspection Date(s): was marked with a DOT Class 9 label. Building: Flow Station 3 JJ1-OB-014 Area: SAA At the time of inspection, there was a 15-gallon SAA container of waste solvent rags that was marked with a hazard indicator that was not specific to the hazard. The container was marked with a DOT Class 9 label. Citations: Building: Hilcorp North Slope Prudhoe Bay Unit JJ1-OB-016 Area: At the time of the inspection, Hilcorp NS PBU was sending oily waste, with waste leather gloves, to the NSB Oxbow Landfill, an unpermitted local disposal facility. Citations: 07/10/2023 - 07/12/2023 Sub-area: Mod 4944 Sections: Sub-area: Sections: SECTION V - CLOSING CONFERENCE AND FOLLOW UP Closing Conference At the conclusion of the inspection, we conducted a closing conference that was attended by those listed in the Attendees table, in Section I of this report. We thanked everyone for their time and cooperation during the inspection and began a review of the areas of concern (listed in Section III - Areas of Concern) that we observed during the inspection of the facility. I then explained the follow-up process that would take place once I finished the report. I explained they would receive a copy of the report as would a case officer. I told them the case officer would review the report to determine if any of my areas of concern documented violations. SECTION VI - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS - No sampling was conducted. SECTION VII - LIST OF APPENDICES 1. Photo Log 2. Document Log 10 of 21 Bp Exploration Alaska Prudhoe Bay Inspection Date(s): APPENDIX 1: PHOTO LOG 07/10/2023 - 07/12/2023 [Title] IMG-20230710111224122469308.jpg 07/10/2023 11:12 AM (AKT) No CBI No PII Photographer: Jon Jones STP/4921 Drive thru 70.41267029, -148.53119565 View of a 15-gallon SAA container of solvent rags that is not marked with a hazard indicator that is specific to the hazard. The container seen here is marked with a DOT Class 9 label. [Title] 07/10/2023 11:16 AM (AKT) No CBI No PII STP/4921 Drive thru Close-up view of the hazardous waste label. IMG-20230710111610161073126.jpg Photographer: Jon Jones 70.41266399, -148.53120676 11 of 21 Bp Exploration Alaska Prudhoe Bay Inspection Date(s): 07/10/2023 - 07/12/2023 [Title] IMG-20230710111852185271812.jpg 07/10/2023 11:18 AM (AKT) No CBI No PII Photographer: Jon Jones STP/4921 Drive thru 70.41269969, -148.53122561 Close-up view of the hazardous waste label, after the word "TOXIC" was added for a hazard indicator. [Title] IMG-20230710144630463059575.jpg 07/10/2023 02:46 PM (AKT) No CBI No PII Photographer: Jon Jones Flow Station 2 70.26610757, -148.33380998 View of a waste battery that is marked as "BAD" and not labeled with either the phrase "Universal Waste Battery," "Waste - Battery," or "Used Battery." 12 of 21 Bp Exploration Alaska Prudhoe Bay Inspection Date(s): 07/10/2023 - 07/12/2023 [Title] IMG-20230710144636463680218.jpg 07/10/2023 02:46 PM (AKT) No CBI No PII Photographer: Jon Jones Flow Station 2 70.26613564, -148.33376921 Close-up view of the waste battery that is marked as "BAD" and not labeled with either the phrase "Universal Waste - Battery," "Waste - Battery," or "Used Battery." [Title] IMG-20230710144944494469634.jpg 07/10/2023 02:49 PM (AKT) No CBI No PII Photographer: Jon Jones Flow Station 2/SAA 70.26624194, -148.33393027 View of a SAA container of waste solvent rags that is not marked with a hazard indicator that is specific to the hazard. The container seen here is marked with a DOT Class 9 label. 13 of 21 Bp Exploration Alaska Prudhoe Bay Inspection Date(s): 07/10/2023 - 07/12/2023 [Title] IMG-20230710145221522162477.jpg 07/10/2023 02:52 PM (AKT) No CBI No PII Photographer: Jon Jones Flow Station 2/SAA 70.26620007, -148.33388776 View of the SAA container of waste solvent rags after being marked with the word "TOXIC" for the hazard indicator. [Title] IMG-20230711091114111478049.jpg 07/11/2023 09:11 AM (AKT) No CBI No PII Photographer: Jon Jones L Pad/Innovation Rig 70.35024693, -149.33210353 View of a SAA container of waste solvent rags that is marked with the word "TOXIC." The container was marked at some point following the first day of the inspection (7/10/23) and the beginning of the inspection on the second day (7/11/23). 14 of 21 Bp Exploration Alaska Prudhoe Bay Inspection Date(s): 07/10/2023 - 07/12/2023 [Title] IMG-20230711091233123387851.jpg 07/11/2023 09:12 AM (AKT) No CBI No PII Photographer: Jon Jones L Pad/Innovation Rig 70.3497863, -149.33066522 View of a 55-gallon SAA container of waste glycol that is not marked with a hazard indicator that is specific to the waste. [Title] IMG-20230711091243124392769.jpg 07/11/2023 09:12 AM (AKT) No CBI No PII Photographer: Jon Jones L Pad/Innovation Rig 70.3500311, -149.33304511 Close-up view of the same 55-gallon SAA container of waste glycol that is not marked with a hazard indicator that is specific to the hazard. 15 of 21 Bp Exploration Alaska Prudhoe Bay Inspection Date(s): 07/10/2023 - 07/12/2023 [Title] IMG-20230711091251125192111.jpg 07/11/2023 09:12 AM (AKT) No CBI No PII Photographer: Jon Jones L Pad/Innovation Rig 70.35009127, -149.33202664 Another close-up view of the same 55-gallon SAA container of waste glycol after being marked with the word "TOXIC" for the hazard indicator. [Title] IMG-20230711132714271484626.jpg 07/11/2023 01:27 PM (AKT) No CBI No PII Photographer: Jon Jones Flow Station 3/SAA 70.25485376, -148.57487848 View of a SAA step-can of waste solvent rags that is not marked with a hazard indicator that is specific to the hazard. 16 of 21 Bp Exploration Alaska Prudhoe Bay Inspection Date(s): 07/10/2023 - 07/12/2023 [Title] IMG-20230711132816281684552.jpg 07/11/2023 01:28 PM (AKT) No CBI No PII Photographer: Jon Jones Flow Station 3/SAA 70.25496462, -148.57475465 View of the step-can after being marked with the word "TOXIC" for the hazard indicator. [Title] IMG-20230711134450445082200.jpg 07/11/2023 01:44 PM (AKT) No CBI No PII Photographer: Jon Jones Flow Station 3/SAA 70.25481702, -148.57282977 View of a SAA step-can of waste solvent rags that is not marked with a hazard indicator that is specific to the hazard. 17 of 21 Bp Exploration Alaska Prudhoe Bay Inspection Date(s): 07/10/2023 - 07/12/2023 [Title] IMG-20230711134520452088409.jpg 07/11/2023 01:45 PM (AKT) No CBI No PII Photographer: Jon Jones Flow Station 3/SAA 70.25484075, -148.57265071 View of the step-can after being marked with the word "TOXIC" for the hazard indicator. [Title] IMG-20230711143823382395998.jpg 07/11/2023 02:38 PM (AKT) No CBI No PII Photographer: Jon Jones Hazardous Waste Process Facility (HWPF) 70.2909124, -148.69759435 View of the HWPF floor, showing the repairs that were made since the previous inspection. 18 of 21 Bp Exploration Alaska Prudhoe Bay Inspection Date(s): 07/10/2023 - 07/12/2023 [Title] IMG-20230711143830383085256.jpg 07/11/2023 02:38 PM (AKT) No CBI No PII Photographer: Jon Jones Hazardous Waste Process Facility (HWPF) 70.2909123, -148.69759427 View of the HWPF floor, showing the repairs that were made since the previous inspection. [Title] IMG-20230711143836383679560.jpg 07/11/2023 02:38 PM (AKT) No CBI No PII Photographer: Jon Jones Hazardous Waste Process Facility (HWPF) 70.29089756, -148.69753081 View of the HWPF floor, showing the repairs that were made since the previous inspection. 19 of 21 Bp Exploration Alaska Prudhoe Bay Inspection Date(s): 07/10/2023 - 07/12/2023 [Title] IMG-20230711143852385285412.jpg 07/11/2023 02:38 PM (AKT) No CBI No PII Photographer: Jon Jones Hazardous Waste Process Facility (HWPF) 70.29091415, -148.69759556 View of the HWPF floor, showing the repairs that were made since the previous inspection. 20 of 21 Bp Exploration Alaska Prudhoe Bay Inspection Date(s): 07/10/2023 - 07/12/2023 APPENDIX 2: DOCUMENT LOG Document Type Document Name Contains Contains Uploaded By Date CBI PII Received Records Review Stock Leather Gloves 07.17.2023.pdf No No Jon Jones 07/28/2023 Records Review PB Solvent Rag SAA Locations.pdf No No Jon Jones 07/28/2023 Contingency Plan AK-HSE-DOC-00120-4_PBU RCRA Contingency Plan.pdf No No Jon Jones 07/28/2023 Personnel Training DEEP Data base No No Jon Jones 07/28/2023 Prudhoe_Waste__SAA_Training_Report_as of 7.11.23.pdf Personnel Training FORMS Data Base Combined ENV Safety No No Jon Jones 07/28/2023 Portal Reports - Waste SAA Training as of 7.11.2023.pdf Personnel Training ISN Waste Handling - NMS - 2023.pdf No No Jon Jones 07/28/2023 Records Review PB Accumulation Area Inspection List No No Jon Jones 07/28/2023 (SAAs) Records Review Hilcorp PB SAA/UAA/OIC Data Sheet (Field No No Jon Jones 07/28/2023 Log) Map North Slope Overview NSB Service Area No No Jon Jones 08/11/2023 Waste Disposal Red Book October 2021 and Reuse Guide No No Jon Jones 08/11/2023 Records Review Revised Solvent Rag SAA Locations No No Jon Jones 08/06/2023 21 of 21