Document 8OworO5KL3qvd9JzZRQqXLbok
EPA REGION 6 Enforcement Division
INSPECTION REPORT
Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program
11/06/2024 12:25 (CT) 11/06/2024 13:40 (CT) RCRA
Type of Inspection Focused Compliance Inspection (FCI)
Announced: No (tenants and related facilities) Access: Granted
Facility or Site Name Enterprise Refined Products, LLC
Facility/Site
TXD074189671
Identifier
Facility/Site Physical 6275 Hwy 347 Beaumont, TX 77705
Address
City, State, Zip Code Beaumont, TX 77705
County/Borough Jefferson County
Generator Status VSQG
NAICS
493190
Type of Operation
Geographic Coordinates
Enterprise operates as a storage terminal facility for customers to store refined oil products in their tanks and move products by pipelines, barges, and ships. 30.0337, -94.1022
Additional Persons Participating in Inspection:
Name
Title
Organization Email
Angela Hays
Inspector
EPA REGION 6 Hays.Angela@epa.gov
Sandesh Thapa
Inspector
EPA REGION 6 Thapa.Sandesh@epa.gov
Jon Herbay
Contractor
Eastern Research Jon.Herbay@erg.com Group (ERG)
Phone (214) 665-2285 (214) 665-2265 (412) 780-9931
Lead Inspector: Vince Damiano
Chemical Engineer ERG
Vincent Damiano
Digitally signed by Vincent Damiano Date: 2025.02.06 10:59:44 -05'00'
Vince.Damiano@erg.com
02/06/2025 (703) 633-1732
Page 1 of 4
Enterprise Products / Seaway
Inspection Date: 11/06/2024
SECTION I - INTRODUCTION
Site Entry and Purpose of the Inspection
The Port of Beaumont 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, portrelated facilities, and records including photographs take, verbal or written statements made during or after the on-site inspection, and/or materials shown, demonstrated, or submitted to the Environmental Protection Agency (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 Inspector/Enforcement Officer/EPA Region 6 Inspector/Enforcement Officer/EPA Region 6 RCRA Inspector/ Contractor/ERG Enterprise Products
Enterprise Products
Enterprise Products
Enterprise Products
Enterprise Products
Name
Phone
Vince (703) 633-1732 Damiano
Angela (214) 665-2285 Hays
Sandesh (469) 616-8578 Thapa
Jon
(412) 780-9931
Herbay
Kim (832) 256-5197 Stratton
Angela (409) 656-6675 Warren
Rachel (409) 853-0749 Cuevas
Brandon (281) 229-8013 Rowland
Coby Goos
(409) 344-2153
Email Vince.Damiano@erg.com Hays.Angela@epa.gov Thapa.Sandesh@epa.gov Jon.Herbay@erg.com KAStratton@eprod.com AWarren@ensolum.com RLCuevas@eprod.com BCRowland@eprod.com CGroos@eprod.com
Opening Closing Conf. Conf.
Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes
Page 2 of 4
Enterprise Products / Seaway Facility General Description
Inspection Date: 11/06/2024
Tenant/Area Enterprise Products
Inspection Date
11/06/24
Process Description Enterprise Refined Products, LLC (Enterprise) operates as a storage facility for customers to store refined oil products in their tanks and move products by pipelines, barges, and ships. The facility maintains a MARPOL COA for Annexes I and V but does not receive waste from vessels.
Area of Concern
No
SECTION II - OBSERVATIONS
Tenant: Enterprise Products
Section: 2.1
Date: 11/06/24, 12:25 PM Contains AOC: No
Lead Inspector: Vince Damiano Attendees: Casey Cowley (EPROD OPS SUP)
Contains CBI: No
Enterprise, also known as Enterprise Beaumont Marine West, operates as a terminal for loading and unloading refined products via pipelines, ships, and barges. Enterprise is not associated with a port and owns its dock spaces and its operation area. The products Enterprise handles consist of gasoline, naphtha, jet fuel, diesel, and methyl tertiary butyl ether (MTBE). Enterprise receives these products from customers and stores them in one of its 37 tanks; 30 tanks were in use at the time of the inspection. Enterprise's storage tanks range in storage capacity from 20,000 barrels to 150,000 barrels. Enterprise will also handle crude oil but only transfer crude through pipelines and not store it in their tanks. Enterprise has a MARPOL Annexes I and V COA (see Appendix 1). Enterprise personnel stated they do not accept waste from ships at their docks. Enterprise is registered as a very small quantity generator (VSQG) with the EPA (TXD074189671). Enterprise does not typically generate RCRA-regulated waste but when the facility does generate hazardous waste, it is from tank cleanouts. Most tank cleanouts generate oily waste given the nature of the products stored on site.
Upon finishing the opening conference, the inspection team observed Enterprise's dock areas and drum storage area. The inspection team observed Dock 1 and Dock 2 and did not observe any areas of concern (AOCs). Each dock has a rain collection sump that is visually inspected to verify there is no sheen on the water collected before releasing it. Next, the inspection team observed the drum storage area which was not storing any waste at the time of the inspection. The inspection team did not observe any AOCs at the time of the inspection. However, further EPA review may add to their potential AOCs. A closing conference was conducted at approximately 1:36 PM with Enterprise.
Following the inspection, Enterprise provided the inspection team with an electronic copy of their MARPOL COA (see Appendix 1) and a certificate of proper recycling from EcoWerks for shipment of naphtha and alkylate tank wash water that was recycled (see Appendix 2).
Page 3 of 4
Enterprise Products / Seaway
Inspection Date: 11/06/2024
SECTION III - RECORDS REVIEW No RCRA-regulated records were reviewed during this focused onsite inspection.
SECTION IV - FOLLOW UP
Follow-Up Any facility follow-up items are as discussed in the observations in Section II. Documents or files provided by the facility 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. 11/22/24 Enterprise email - Rachel Cuevas provided the inspection team with a copy of their MARPOL COA and certificate of proper recycle from EcoWerks.
SECTION V - LIST OF APPENDICES Appendix 1. Enterprise COA Appendix 2. Certificate of Proper Recycling from EcoWerks
Page 4 of 4
APPENDIX 1. ENTERPRISE COA
APPENDIX 2. CERTIFICATE OF PROPER RECYCLING FROM ECOWERKS
Appendix 2 Page 1 of 4
Appendix 2 Page 2 of 4
Appendix 2 Page 3 of 4
Appendix 2 Page 4 of 4