Document 2q8a8jZDq4oakxb2KMM4EMMbg

Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 6 Enforcement Division INSPECTION REPORT 05/08/2024 09:20 AM (CT) 05/08/2024 12:00 PM (CT) RCRA Focused Compliance Inspection (FCI) Announced: No Access: Granted 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 Enterprise Houston Terminal TXD074189549 15602 Jacintoport Blvd Houston, TX 77015 Harris Very Small Quantity Generator (VSQG) 49319, 493190 Enterprise is a storage and transportation company for crude oil. 29.739111, -95.120889 Additional Persons Participating in Inspection: Name Title Organization Dedriel Gardner Inspector EPA REGION 6 John Penland Inspector EPA REGION 6 Anshul Paripati Contractor Eastern Research Group (ERG) Email Gardner.Dedriel@epa.gov Penland.John@epa.gov Anshul.Paripati@erg.com Phone (281) 983-2133 (214) 665-9717 (571) 535-1503 Lead Inspector: Cameron Tanaka Cameron Tanaka Date: 2024.07.25 23:29:41 -04'00' Digitally signed by Cameron Tanaka 07/25/2024 ERG Cameron.Tanaka@erg.com (703) 633-1632 ext. 11632 Page 1 of 7 Enterprise Houston Terminal Inspection Date(s): 05/08/2024 SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection Type of inspection: Focused Compliance Inspection (FCI) The Port of Houston and surrounding facilities were selected for inspection based on an Environmental Justice and Regional initiative to evaluate facilities at ports receiving or transporting Resource Conservation and Recovery Act (RCRA)-regulated hazardous wastes, and/or have an International Convention for the Prevention of Pollution from Ships (MARPOL) Annex V Certificate of Adequacy (COA) issued by the U.S. Coast Guard (USCG). This report is based on information supplied by the facility representatives, inspector observations, port related facilities, and records including photographs taken (see Appendix 1), verbal or written statements made during or after the on-site 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. Attendees Title/Organization Lead Inspector/ Contractor/ERG RCRA Inspector/ Contractor/ERG Inspector/Enforcement Officer/EPA Region 6 Inspector/Enforcement Officer/EPA Region 6 Name Phone Email Opening Closing Conf. Conf. Cameron Tanaka (703) 633-1632 Cameron.Tanaka@erg.com N/A N/A ext. 11632 Anshul Paripati (571) 535-1503 Anshul.Paripati@erg.com N/A N/A Dedriel Gardner (281) 983-2133 Gardner.Dedriel@epa.gov N/A N/A John Penland (214) 665-9717 Penland.John@epa.gov N/A N/A Page 2 of 7 Enterprise Houston Terminal Inspection Date(s): 05/08/2024 Facility General Description Tenant/Area Enterprise Houston Terminal Inspection Date 05/08/24 Process Description Enterprise Houston Terminal (Enterprise) is a storage and transportation company for crude oil. They have wastes including oily debris, used oil, universal waste, contaminated materials (soils) from spills, and paint waste from blasting. They pipeline their materials both in and out of their facility from vessels to their storage tanks back to vessels and occasionally to trucks. Enterprise has a MARPOL COA for Annexes I, II, and V. Area of Concern Yes Page 3 of 7 Enterprise Houston Terminal Inspection Date(s): 05/08/2024 SECTION II - OBSERVATIONS Tenant: Enterprise Houston Terminal Section: 2.1 Date: 05/08/24, 9:20 AM Contains AOC: Yes Contains CBI: No Lead Inspector: Cameron Tanaka Attendees: David Williams (Environmental), William Stubbs (Operations), Chad McCutchen (Operations), and Raymond Loftin (Operations) Enterprise is located along the Houston Ship Channel and operates as a terminal for storage and transportation. The facility stores crude oil, methyl tert-butyl ether, naphtha condensate, and diesel in storage tanks on its site. Enterprise services third party vessels and occasionally trucks that are loading and discharging material. The facility has pipelines that transport materials to and from vessels and trucks to and from its storage tanks on site. Enterprise also operates a pipeline that goes offsite under the ship channel to refineries such as Exxon and Houston Refining. Enterprise operates two facilities on the ship channel, one designated mainly for crude oil and the other for liquid petroleum gas. The location that the team inspected was the crude oil site. All the crude oil that the facility receives is tested with aniline samples for sulphur, magnesium, metals, API gravity, and sediment. The facility generates wastes including oily debris, used oil, universal waste, contaminated materials (soils) from spills, and paint waste from sandblasting tanks. These wastes are stored in containers including roll-off boxes with sliding door lids and drums in the facility's drum storage area. Universal waste is stored separately in this area. Enterprise generates oily debris such as contaminated PPE, filters, oily pigs, and wastewater. Wastewater is sent to Stolthaven for treatment. The facility does not transfer any wastes. Any waste removed from ships is handled exclusively by third parties and never stored at the Enterprise's site. Third party disposal companies perform sampling for waste determinations for wastes generated by Enterprise. These are mostly performed for contaminated soil, which is generally analyzed for benzene, toluene, ethylbenzene, and xylenes (BTEX), total petroleum hydrocarbons (TPH), and metals. The facility also has crude oil sediments in their tanks. Enterprise adds diesel to these tanks and recirculates the material in the tanks to minimize the sediment. They send this material as a product to facilities who recover and reclaim the material. The value of the sediment is based on its Basic Sediment & Water percentage. Enterprise is registered with the EPA under EPA ID TXD074189549 as a VSQG generating lab packs, aerosols, and pesticides. In Enterprise's June 3, 2024, follow-up email, Jefferson Ritcheson explained that the facility does not have any hazardous waste manifests for the last five years (see Appendix 1). Enterprise also has a MARPOL COA for Annexes I, II, and V and has third party companies taking off Annex I, II, or V wastes at its dock. This waste is never handled or stored onsite by Enterprise, as the wastes are pumped directly to third party trucks for disposal. This is arranged by the vessel's agent. Facility personnel briefly described their facility response plan (FRP). They indicated that for smaller spills (under five barrels), the local response team will assess the spill while Enterprise shuts down any operations, equipment, or pipelines associated with the spill and notifies any relevant contacts. The facility brings in vacuum trucks, which almost always stay on-site, to recover any product they can. These vacuum trucks are all owned by third party companies including Shelton Services and PCI. Finally, Enterprise places contaminated soils in drums or roll-off boxes. For larger spills, the facility must report to government agencies and document the spill in the Incident Command System, or ICS. Enterprise follows the steps set up in its Emergency Response Action Protocol, or ERAP. In Enterprise's June 3, 2024, follow-up email (see Appendix 1), Mr. Ritcheson included the facility's ERAP. Mr. Ritcheson also included documentation of a tabletop spill response exercise. During the inspection, the inspection team observed the facility's roll-off bin area and drum storage area. Observations and Areas of Concern (AOCs) are organized by section below along with facility responses Page 4 of 7 Enterprise Houston Terminal Inspection Date(s): 05/08/2024 where relevant. Roll-off Bin Area Enterprise's roll-off bin area included roll-offs with paint waste solids, a few drums of oily debris, air filters, and uncontaminated plant trash. The roll-off with paint waste solids was about a quarter full. The facility indicated that the paint waste solids are considered universal waste, but they did not have a label on the rolloff with this waste [AOC #1 - Enterprise did not clearly label or mark the universal paint waste container with the words "Universal Waste - Paint and Paint-Related Wastes" - 30 TAC 335.262(c)(2)(F)]. In his June 3 followup email, Mr. Ritcheson stated that a new label was placed on the container and also sent a picture of the facility's response (see Appendix 1 and Appendix 2). Drum Storage Area The inspection team observed Enterprise's drum storage area and noted no issues. The inspection team did not observe any other areas of concern at the time of the inspection. A closing conference was conducted at approximately 11:50 AM with Enterprise personnel. The AOC and the requested documents were communicated during the closing. Page 5 of 7 Enterprise Houston Terminal Inspection Date(s): 05/08/2024 SECTION III - RECORDS REVIEW No RCRA regulated records were reviewed during this focused onsite inspection. SECTION IV - APPARENT AREAS OF CONCERN The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation. Tenant: Enterprise Houston Terminal AOC #1 - Enterprise did not clearly label or mark the universal paint waste container with the words "Universal Waste - Paint and Paint-Related Wastes. Citation: 30 TAC 335.262(c)(2)(F) Section: 2.1 SECTION V - FOLLOW UP Follow-Up Any facility follow-up items are as discussed in each facility's observations in Section II. Documents or files provided by the facilities were transmitted via email and included responses to AOCs or provision of documents requested. Communication Log During and after the inspection, additional information was emailed to EPA including: 1. 06/03/24 Enterprise email - Jefferson Ritcheson sent an email providing the documents or clarifications requested during the inspection and a photo showing corrective action implemented for their universal paint waste container. Page 6 of 7 Enterprise Houston Terminal SECTION VI - LIST OF APPENDICES Appendix 1. Follow-Up Email from Enterprise Appendix 2. Enterprise Universal Waste Label for Paint Waste Solids Roll-off Inspection Date(s): 05/08/2024 Page 7 of 7 APPENDIX 1. FOLLOW-UP EMAIL FROM ENTERPRISE Appendix 1 Page 1 of 1 APPENDIX 2. ENTERPRISE UNIVERSAL WASTE LABEL FOR PAINT WASTE SOLIDS ROLL-OFF Appendix 2 Page 1 of 1