Document 1QaB999G180oQ1aprxXLJwwXZ

Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 10 Enforcement Division INSPECTION REPORT 08/30/2024 08:31 AM (PT) Announced: No 08/30/2024 10:10 AM (PT) 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 Tesoro Logistics Operations, LLC Tesoro Logistics Operations, LLC WAD000711556 2211 St Francis Ln Vancouver, WA 98660 Clark Very Small Quantity Generator (VSQG) 424710 - Petroleum Bulk Stations and Terminals Bulk Fuel Terminal 45.64054, -122.69487 539 S Main Street ATTN: TERMINALS HESS Findlay, OH 45840 Serena Lewellyn, Environmental Specialist slewellyn@marathonpetroleum.com 1100 H and H Lane North Pole, AK 99705 CC: Micah Bardin, Terminal Manager dbardin@marathonpetroleum.com Permit Number (If Applicable) Not Applicable Lead Inspector: Jon Jones EPA REGION 10 Jones.Jon@epa.gov (907) 227-4316 Supervisor Review: Matthew Quarterman EPA REGION 10 Quarterman.Matthew@epa.gov (206) 553-2146 SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection Type of inspection: Compliance Evaluation Inspection (CEI) 1 of 11 Tesoro Logistics Operations, LLC Inspection Date(s): 08/30/2024 - 08/30/2024 EPA Region 10 Lead Inspector, Jon Jones, arrived at the Tesoro Logistics Operations, LLC Facility (the "Site" or "Facility"), located at 2211 St Francis Ln, Vancouver, WA 98660, at 08:31 AM (PT) on 08/30/2024 for an unannounced inspection. EPA Region 10 Lead Inspector presented credentials to and informed Micah Bardin that this was an EPA REGION 10 inspection to determine compliance with Resource Conservation and Recovery Act (RCRA). The facility was inspected to ensure compliance with Washington's federally authorized hazardous waste regulations found at Washington Administrative Code (WAC) 173-303. Specifically, the inspection assessed compliance with WAC 173-303-573 universal waste management standards, WAC 173-303-515 requirements for management of used oil, and WAC 173-303-170 through 230 standards for hazardous waste generators. The inspection was conducted as a core program requirement for fiscal year 2024. This report is based on information supplied by Tesoro Logistics Operations, LLC Facility representatives, observations made by the EPA Region 10 inspector, and records and reports maintained by the facility, 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 Lead Inspector/EPA Jon Jones REGION 10 Terminal Micah Manager/Marathon Bardin Petroleum Phone (907) 2716329 (360) 6962390 Email Jones.Jon@epa.gov Opening Conf. Yes dbardin@marathonpetroleum.com Yes Closing Conf. Yes Yes Opening Conference After driving into the facility, I entered the facility office, met with facility personnel, and explained that this was an EPA Region 10 inspection to determine compliance with Resource Conservation and Recovery Act (RCRA). During the opening conference, I explained that the focus of the RCRA inspection was to identify types of wastes generated, points of waste generation, methods of waste management, and review relevant documents. Only those areas in which I observed potential compliance concerns or noted other pertinent issues are discussed in Section III of this inspection report. Facility/Site Information Number of employees 4 Length of Facility at Location Since 1961 Operating Hours 6:00 a.m. to 4:00 p.m., Monday through Friday Safety Training Yes Provided to Inspector(s)? 2 of 11 Tesoro Logistics Operations, LLC Inspection Date(s): 08/30/2024 - 08/30/2024 Size of Facility What type of generator facility notified? What type of generator facility verified as? Weather Conditions Approximately 6 acres Large Quantity Generator (LQG) Very Small Quantity Generator (VSQG) Sunny and warm Tesoro Logistics Operations, LLC (Tesoro) has operated at this site since 1961. The Tesoro facility is used for bulk petroleum storage. Aboveground storage tanks are used to store diesel fuel, gasoline, off-spec materials, ethanol, fuel additives, B-99 bio diesel, and dyes. Diesel fuel and gasoline are generally received via pipeline. Ethanol is primarily received by rail car and sometimes trucks. Bio diesel is primarily received by trucks and has the potential to be received by railcar. Fuel additives are received by tanker truck and dye is received either by small bulk containers or via tanker trucks. Fuels are also received at the facility by ship and barge. They also have a Facility ID under SPCC/FRP: R10-WA-00048. Process Description Mr. Bardin told me the following about the facility's processes and waste streams: Tesoro became an LQG due to sludge removal, a process known as "653," from some of the 12 aboveground storage tanks. The most recent tank cleanout took place in October 2023. Tesoro was acquired by Marathon Petroleum, but the terminal continues to operate under the Tesoro brand name. Mr. Bardin said that on 5/31/24 the facility's fire suppression system dumped AFFF due to a bad heat probe. The waste was shipped to Chemical Waste Management of the NW, Inc. in Arlington, OR. I was accompanied during the inspection by Mr. Bardin. I looked at the facility's processes, 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 did not observe any universal waste or used oil during the inspection of the facility. Building(s) Building/Area/Sub-area Tesoro Logistics CAA Process Description Area of Concern No No SECTION II - OBSERVATIONS Building: Tesoro Logistics/CAA Observation #: JJ1-OB-001 Date: 08/30/2024 Person Interviewed: Micah Bardin Contains AOC: No Contains CBI: No Title: Terminal Manager I went to inspect the facility's central accumulation area (CAA) during my facility visit and saw that there was no hazardous waste in accumulation. 3 of 11 Tesoro Logistics Operations, LLC Inspection Date(s): Photo(s) 1. IMG-2024083009440144184533.jpg 2. IMG-20240830094409449106300.jpg 08/30/2024 - 08/30/2024 SECTION III - RECORDS REVIEW Record: Personnel Training AOC: No Ref #: JJ1-RR-001 Reviewed By: Jon Jones Reviewed Date: 08/30/2024 During the inspection, I reviewed the facility's hazardous waste training plan. Photo(s) 1. IMG-20240830085055505587966.jpg 2. IMG-20240830085145514574075.jpg Record: Contingency Plan's Quick Reference Guide AOC: No Ref #: JJ1-RR-002 Reviewed By: Jon Jones Reviewed Date: 08/30/2024 During the inspection, I reviewed the facility's distribution list for their Hazardous Waste Contingency Plan. Document(s) 1. C Plan.pdf 2. Quick reference guide.pdf Photo(s) 1. IMG-20240830085454545463782.jpg Record: Personnel Training AOC: No Ref #: JJ1-RR-003 Reviewed By: Jon Jones Reviewed Date: 08/30/2024 During the inspection, I reviewed training records and saw that training for Mr. Don Dodge was close to expiring but still current as of the day of the inspection. Photo(s) 1. IMG-20240830085722572274418.jpg 2. IMG-20240830085753575386797.jpg Record: Inspections AOC: Yes Ref #: JJ1-RR-004 Reviewed By: Jon Jones Reviewed Date: 08/30/2024 I inspected the facility's weekly hazardous waste inspection logs and saw that no weekly inspection was conducted during the week of 6/16/24 through 6/22/24. During this week, the facility was a LQG of hazardous waste. Due to a release of AFFF, 4,819 gallons of waste AFFF was generated on 5/21/24. The facility managed the waste as hazardous with waste code D018 for benzene. The waste was in accumulation during the week of 6/16/24 through 6/22/24 and shipped off-site 7/1/24 on manifest #024165802 JJK. Photo(s) 1. IMG-20240830091841184178079.jpg 2. IMG-20240830091853185377467.jpg 4 of 11 Tesoro Logistics Operations, LLC Inspection Date(s): 08/30/2024 - 08/30/2024 Record: Manifests Ref #: JJ1-RR-005 Reviewed By: Jon Jones AOC: No Reviewed Date: 08/30/2024 Reviewed hazardous waste manifest for disposal of AFFF, the facility generated on 5/21/24. The AFFF was designated D018 for benzene. SECTION IV - AREA OF CONCERN The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation. Record: Inspections JJ1-RR-004 No weekly inspection was Regulation: conducted during the week of 6/16/24 through 6/22/24. The facility was an LQG during this week. Sections: SECTION V - CLOSING CONFERENCE AND FOLLOW UP Closing Conference At the conclusion of the inspection, I conducted a closing conference that was attended by those listed in the Attendees table, in Section I of this report. I thanked Mr. Bardin for his time and cooperation during the inspection and began a review of the areas of concern (listed in Section III - Areas of Concern) that I observed during my 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. Mr. Bardin asked that correspondence be sent to Ms. Serena Lewellyn with a copy sent to him. SECTION VI - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS - No sampling was conducted. SECTION VII - LIST OF APPENDICES 1. Photo Log 2. Document Log 5 of 11 Tesoro Logistics Operations, LLC Inspection Date(s): APPENDIX 1: PHOTO LOG 08/30/2024 - 08/30/2024 [Title] 08/30/2024 08:50 AM (PT) No CBI No PII [Building/Area] View of the facility's hazardous waste training plan. IMG-20240830085055505587966.jpg Photographer: Jon Jones 45.63843612, -122.69698471 [Title] IMG-20240830085145514574075.jpg 08/30/2024 08:51 AM (PT) No CBI No PII Photographer: Jon Jones [Building/Area] 45.63826136, -122.69721074 Another view of the facility's hazardous waste training plan. 6 of 11 Tesoro Logistics Operations, LLC Inspection Date(s): 08/30/2024 - 08/30/2024 [Title] IMG-20240830085454545463782.jpg 08/30/2024 08:54 AM (PT) No CBI No PII Photographer: Jon Jones [Building/Area] 45.63826111, -122.69721197 View of distribution letter for their Hazardous Waste Contingency Plan. [Title] 08/30/2024 08:57 AM (PT) No CBI [Building/Area] View of training records for Don Dodge. No PII IMG-20240830085722572274418.jpg Photographer: Jon Jones 45.63826053, -122.69720361 7 of 11 Tesoro Logistics Operations, LLC Inspection Date(s): 08/30/2024 - 08/30/2024 [Title] 08/30/2024 08:57 AM (PT) No CBI No PII [Building/Area] View of training records for Serena Lewellyn. IMG-20240830085753575386797.jpg Photographer: Jon Jones 45.63826064, -122.69720416 [Title] IMG-20240830091841184178079.jpg 08/30/2024 09:18 AM (PT) No CBI No PII Photographer: Jon Jones [Building/Area] 45.63826065, -122.69720371 View of the weekly inspection log for the week prior to the missed week of 6/16/24 through 6/22/24. 8 of 11 Tesoro Logistics Operations, LLC Inspection Date(s): 08/30/2024 - 08/30/2024 [Title] IMG-20240830091853185377467.jpg 08/30/2024 09:18 AM (PT) No CBI No PII Photographer: Jon Jones [Building/Area] 45.63833519, -122.69710656 View of the weekly inspection log for the week following the missed week of 6/16/24 through 6/22/24. [Title] 08/30/2024 09:44 AM (PT) No CBI Tesoro Logistics/CAA View of the CAA with no waste onsite. No PII IMG-2024083009440144184533.jpg Photographer: Jon Jones 45.63845879, -122.69705228 9 of 11 Tesoro Logistics Operations, LLC Inspection Date(s): 08/30/2024 - 08/30/2024 [Title] 08/30/2024 09:44 AM (PT) No CBI No PII Tesoro Logistics/CAA Another view of the CAA with no waste onsite. IMG-20240830094409449106300.jpg Photographer: Jon Jones 45.63845879, -122.69705228 10 of 11 Tesoro Logistics Operations, LLC Inspection Date(s): APPENDIX 2: DOCUMENT LOG Document Type Document Name Records Review Records Review Communications C Plan.pdf Quick reference guide.pdf Visitor Information Guide.pdf 08/30/2024 - 08/30/2024 Contains Contains Uploaded By CBI PII No No Jon Jones No No Jon Jones No No Jon Jones Date Received 11/01/2024 11/01/2024 11/01/2024 11 of 11