Document DMLOMeDqMEywvoK4k1p08dO6d

Inspection Date(s): Time: Program: Regulatory Program(s): If Access is Denied: REGION 10 Enforcement Division INSPECTION REPORT 07/26/2021 - 07/26/2021 Announced: No Entry: 09:10 AM (AKT) Exit: 10:33 AM (AKT) RCRA Title 40 - ENVIRONMENTAL PROTECTION AGENCY Company Name: Facility or Site Name: Facility/Site Physical Address: (City, state, zip code) Type of Operation: Size of Facility: Length of Facility at Location: Geographic Coordinates: Mailing address: (Secondary Address) (City, state, zip code) County: Harvest Alaska, LLC SWANSON RIVER OIL PIPELINE 48775 KENAI SPUR HWY KENAI, AK 99611 Pipeline transportation of crude oil Approximately 100 square feet Since 1960's 60.685662, -151.392717 Mr. Kijun Hong, Environmental Specialist 3800 Centerpoint Drive, Suite 1400 Anchorage, AK 99503 khong@harvestmidstream.com Facility/Site Identifier: Media Number: NAICS: AKD035419795 486110 - Pipeline Transportation of Crude Oil Lead Inspector: Jon Jones Jones, Jon REGION 10 Digitally signed by Jones, Jon Date: 2021.10.19 12:45:50 -08'00' Jones.Jon@epa.gov (907) 271-6329 Additional Persons Participating in Inspection: Supervisor Review: Jen Sullivan Jennifer A Sullivan REGION 10 Digitally signed by Jennifer A Sullivan Date: 2021.10.19 15:05:01 -07'00' Sullivan.Jennifer.A@epa.gov (206) 553-6978 SECTION I - INTRODUCTION Purpose of the Inspection/Objective Type of inspection: CEI - Compliance Evaluation Inspection This was a Resource Conservation and Recovery Act (RCRA) inspection. The facility was inspected to ensure 1 of 9 SWANSON RIVER OIL PIPELINE Inspection Date(s): 07/26/2021 - 07/26/2021 compliance with 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 2021. Attendees Title Name Lead Inspector Jon Jones Environmental Kijun Hong Specialist Safety Specialist Eric Wilcox II Lead Operator Elijah Gerow Phone Email 9072716329 Jones.Jon@epa.gov (505) 436-8457 khong@harveststream.com Present in Present in Opening Conf. Closing Conf. Yes Yes Yes Yes (907) 283-1375 ewilcox@harvestmidstream.com Yes Yes (907) 398-9976 egerow@harvestmidstream.com Yes Yes Opening Conference EPA Lead Inspector Jon Jones, arrived at the Swanson River Oil Pipeline facility at 09:10 AM (AKT) on 07/26/2021 for an inspection. I presented my credentials to Kijun Hong and informed him that this was an EPA RCRA inspection. The table above presents all the inspection 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. No universal waste or used oil was observed during the inspection. Only those areas in which I observed areas of concern or noted other pertinent issues are discussed in this inspection report. I was accompanied for the entirety of the inspection by Messrs. Hong, Wilcox, and Gerow. Facility/Site Description The site is a Pig Receiving Station within a crude oil tank farm located west of the Tesoro Alaska Company, LLC - Kenai Refinery. Facility Info Weather Conditions Operating Hours Safety Training Provided to Inspector(s)? What type of generator facility notified? What type of generator facility verified as? Clear and sunny 24/7 operation No SQG VSQG 2 of 9 SWANSON RIVER OIL PIPELINE Inspection Date(s): 07/26/2021 - 07/26/2021 Harvest Alaska, LLC maintains a Pig receiving station located within the footprint of a crude oil tank farm. The area itself is approximately 100 square feet in size. The rest of the facility is owned and operated by Marathon Oil. Marathon Oil also owns the Tesoro Alaska Company, LLC - Kenai Refinery. An inspection (RCRA) of the Marathon Oil facility was conducted on September 12, 2013 and at that time the facility was owned by Tesoro Alaska Company, LLC and operated by Kenai Pipeline Company. Process Description A pipeline pig used to scrape the inside of the pipeline is received at the pigging station, located inside the tank farm. The pig is put into the pipeline at the Swanson River Production facility and after receiving the pig at the tank farm, pig wax is removed from the pig. The pig wax is scraped off into a trough at the end of the receiving station. After scraping the pig, the pig wax or parrafin is then shoveled back into the pipeline where the pig was removed and pushed on to the tank farm and then eventually being refined at the Tesoro Alaska Company, LLC - Kenai Refinery. The pig is then taken across the street to the Kenai Pipeline (KPL) Junction where it is placed into a hot wash tank for final cleaning. This process generates waste absorbents that are contaminated with crude oil and pig wax or parrafin that is generated from cleaning the pigs in the hot wash tank. The absorbent pads are accumulated in the room where the hot wash tank is located and eventually taken to the facility's East Forelands facility and burned in a smart ash burner. Building(s) Building/Area/Sub-area Pigging Station Process Description Location where pigs are removed from the pipeline as they come in from the Swanson River Production Facility. Area of Concern Yes SECTION II - OBSERVATIONS AND RECORDS REVIEW Observations Building: Pigging Station Observation #: JJ1-OB-001 Contains CBI: No Date: 07/26/2021 Mr. Gerow said pigs generally come through the pigging station from the Swanson River Production Facility every five to ten days. According to Mr. Gerow, pigs come out and five to ten gallons of pig wax is scrapped off inside the pig trough. Mr. Gerow said the pig wax is shoveled back into the pipeline where it goes back into the crude oil that is piped across the street to Marathon's (Tesoro Alaska Company, LLC - Kenai Refinery) crude tanks before going into the refinery. Mr. Gerow said the pig is taken across the street to the Harvest Midstream - KPL Junction (AKR000203125), formerly Kenai Pipeline (KPL) Junction, located at 48780 Kenai Spur Highway. According to Mr. Gerow, the pig is placed inside of a hot wash tank. Once inside the wash tank, all the solids float up to the top and are collected on absorbent pads. The absorbents pads are collected in a trash can and then taken to the Harvest AlaskaMidstream Pipeline Division-East Forelands facility and burned in the smart ash burner. Photo(s) 1. Observation_Image-202107261002202201994341.jpg 2. Observation_Image-202107261002392391765590.jpg 3. Observation_Image-202107261003133131935576.jpg 4. Observation_Image-202107261027002701766181.jpg 5. Observation_Image-2021072610273027301969190.jpg 3 of 9 SWANSON RIVER OIL PIPELINE Inspection Date(s): 6. Observation_Image-202107261028042841609892.jpg 07/26/2021 - 07/26/2021 Records Review Record: Facility Layouts Ref #: JJ1-RR-001 Reviewed By: Jon Jones AOC: No Reviewed Date: 07/26/2021 Following the inspection, Mr. Hong provided me with a diagram of the piping system around the pigging station at the Swanson River Oil Pipeline facility. Document(s) 1. Swanson River Oil PL drawing.pdf Record: Waste Determination Documents Ref #: JJ1-RR-002 Reviewed By: Jon Jones AOC: No Reviewed Date: 07/26/2021 Following the inspection, Mr. Hong provided me with analytical results for the ash generated by the smart ash burner at their East Forelands facility. Document(s) 1. EFOR - Smart Ash Sample.pdf SECTION III - AREA OF CONCERN The presentation of areas of concern does not constitute a formal compliance determination or violation. Building: Pigging Station JJ1-OB-001 Area: Sub-area: Pig is taken across the street to the Kenai Pipeline (KPL) Junction where it's placed inside of a hot wash tank. Once inside the wash tank, all the solids float up to the top and are collected on absorbent pads. The absorbents pads are collected in a trash can and then taken to the Harvest Alaska-Midstream Pipeline Division-East Forelands facility and burned in the smart ash burner. Citations: Sections: SECTION IV - FOLLOW UP 4 of 9 SWANSON RIVER OIL PIPELINE Inspection Date(s): I observed no follow up at the time of the inspection. 07/26/2021 - 07/26/2021 Closing Conference I thanked everyone for their time and cooperation during the inspection and began a review of the areas of concern that I observed during my walk-through inspection and paperwork review while at the facility. I explained that I had not observed any areas of concern while inspecting the facility; however, I did tell Messrs. Hong, Wilcox, and Gerow that areas of concern could be still be identified after a review of the information gathered from the inspection. I answered any questions they had and explained the follow-up process that would take place after the inspection. Prior to the closing conference, I asked Mr. Hong if he would send me a piping diagram of the pigging station as well as a copy of the analytical results for the ash generated at their East Forelands facility. Following the Inspection After the leaving the facility, I sent an email to Mr. Hong, on 7/26/21, requesting the following additional information: 1. Diagram of the piping at the pigging station 2. Copies of the smart ash burner log from 2018 to the present 3. How the hot wash water was being managed following the pig cleaning 4. Generation rate for the absorbent pads generated at the KPL junction Mr. Hong responded on 7/26/21 with the following information: 1. Piping diagram 2. Smart ash analytical results 3. Pig wash water is changed out every six months. US Ecology comes and pulls/disposes of those liquids for us. 4. It takes about 2-3 weeks for the trashcan in the pig wash station to fill up. 5. Jared, one of our operators is grabbing the log from East Forelands and we should have records scanned over to you tomorrow. On 7/27/21 I received an email from Mr. Hong that included the smart ash burner logs for the period from 2018 through 2021. After reviewing the smart ash burner log, I saw that starting in 2018 the facility was logging pig wax which was classified in the log with an "H." I asked Mr. Hong what the "H" signified and he said it signified that the waste to be incinerated in the smart ash burner was hazardous. It was at that time that I identified this as an area of concern. A review of the logs for the years 2019 through 2021 show the same waste either logged in as "N" (Non-hazardous) or as an "Exempt" waste. According to facility personnel on the day of the inspection, the pig wax is coming out of transportation lines and would not be exempt. On 8/25/21 the facility updated their notification (8700-12) with a change in the facility name to Harvest Alaska - SROP Receiver. 5 of 9 SWANSON RIVER OIL PIPELINE Inspection Date(s): 07/26/2021 - 07/26/2021 SECTION V - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS - No sampling was conducted. SECTION VI - LIST OF APPENDICES Photo Log [Title] 07/26/2021 10:11 AM (AKT) Jon Jones Pigging Station No CBI No PII View of the pigging station at the Swanson River Oil Pipeline facility. [Title] 07/26/2021 10:29 AM (AKT) Jon Jones KPL Junction Pig Cleaning Area No CBI No PII View of the pigs hanging above the hot wash tank at the KPL Junction, adjacent to the trash can, full of the absorbent pads with pig wax residue. 6 of 9 SWANSON RIVER OIL PIPELINE Inspection Date(s): [Title] 07/26/2021 10:02 AM (AKT) Jon Jones Pigging Station No CBI No PII View of the pig receiver and trough at the Swanson River Oil Pipeline facility. [Title] 07/26/2021 10:02 AM (AKT) Jon Jones Pigging Station No CBI No PII View of the trough and cleaning tools used to scrape pig wax off the pig. [Title] 07/26/2021 10:03 AM (AKT) Jon Jones Pigging Station No CBI No PII Close-up view of the pig wax solids in the bucket and trough at the Swanson River Oil Pipeline facility. 07/26/2021 - 07/26/2021 7 of 9 SWANSON RIVER OIL PIPELINE Inspection Date(s): [Title] 07/26/2021 10:27 AM (AKT) Jon Jones KPL Junction Pig Cleaning Area No CBI No PII View of the hot wash tank, adjacent to the trash can full of waste absorbent pads, at the KPL Junction. [Title] 07/26/2021 10:27 AM (AKT) Jon Jones KPL Junction Pig Cleaning Area No CBI No PII View inside the hot wash tank, showing the absorbent pads floating on top of the water. 07/26/2021 - 07/26/2021 [Title] 07/26/2021 10:28 AM (AKT) Jon Jones KPL Junction Pig Cleaning Area No CBI No PII View of the trash can, showing the accumulation of waste absorbent pads from the hot wash tank. Document Log Document Type Records Review Document Name Contains Contains Uploaded By CBI PII Swanson River Oil PL drawing.pdf No No Jon Jones 8 of 9 Date Received 07/26/2021 SWANSON RIVER OIL PIPELINE Inspection Date(s): 07/26/2021 - 07/26/2021 Records Review EFOR - Smart Ash Sample.pdf No No Jon Jones Inspection Reports Field_Notes_AKD035419795v1.0.pdf No No Jon Jones Communications Harvest Alaska - RCRA Inspection.pdf No No Jon Jones Other - Smart ash Waste Generator Log - 2018.pdf No No Jon Jones burner logs for the East Forelands Facility 2018 Other - Smart ash Waste Generator Log - 2019.pdf No No Jon Jones burner logs for the East Forelands Facility 2019 Other - Smart ash Waste Generator Log - 2020.pdf No No Jon Jones burner logs for the East Forelands Facility 2020 Other - Smart ash Waste Generator Log - 2021.pdf No No Jon Jones burner logs for the East Forelands Facility 2021 Communications RE_ [EXTERNAL] Swanson River Oil No No Jon Jones Pipeline Inspection.pdf Manifests KPL Junction Manifests.pdf No No Jon Jones Communications RE_ [EXTERNAL] Swanson River Oil No No Jon Jones Pipeline Inspection.pdf 07/26/2021 07/26/2021 09/23/2021 09/23/2021 09/23/2021 09/23/2021 09/23/2021 09/23/2021 09/23/2021 09/23/2021 9 of 9