Document Jr9b7xXN7Oa3YrV5wNvG2KRpK

Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 6 Enforcement Division INSPECTION REPORT 06/25/2024 08:25 AM (CT) Announced: No 06/25/2024 11:00 AM (CT) Access: Granted RCRA Focused Compliance Inspection (FCI) 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 Phillips 66 Freeport Terminal TXD988000204 Farm to Market 1495 and Levee Road Freeport, TX 77541 Brazoria County Large Quantity Generator (LQG) 424710 Phillips 66 Freeport Terminal operates as a terminal for importing/exporting intermediates, liquid petroleum gas (LPG), gasoline blend stocks, and crude oil. 28.929166, -95.344166 Additional Persons Participating in Inspection: Name Title Organization Elizabeth Pham Inspector EPA REGION 6 Erin Young-Dahl Inspector EPA REGION 6 Neil Rapp Contractor Eastern Research Group (ERG) Email Pham.Elizabeth@epa.gov YoungDahl.Erin@epa.gov Neil.Rapp@erg.com Lead Inspector: Vince Damiano Vincent Damiano ERG Digitally signed by Vincent Damiano Date: 2024.08.27 13:46:22 -04'00' Vince.Damiano@erg.com Phone (214) 665-8354 (214) 665-3166 (480) 450-6517 (703) 633-1732 Page 1 of 4 Phillips 66 Freeport Terminal Inspection Date: 06/25/2024 SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection The Port Freeport 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 Vince Damiano Phone Email (703) 633-1732 Vince.Damiano@erg.com Opening Conf. Yes Closing Conf. Yes Neil Rapp (480) 450-6517 Neil.Rapp@erg.com Yes Yes Elizabeth Pham (214) 665-8354 Pham.Elizabeth@epa.gov Yes Yes Erin Young-Dahl (214) 665-3166 YoungDahl.Erin@epa.gov Yes Yes Facility General Description Tenant/Area Phillips 66 Freeport Terminal Inspection Date 06/25/24 Process Description Phillips 66 Freeport Terminal (Phillips) operates as a terminal for importing/exporting intermediates, liquid petroleum gas (LPG), gasoline blend stocks, and crude oil. All transfer of materials is through pipeline. The facility maintains a MARPOL COA for Annexes I, II, and V. The facility does not allow any waste transfers across their dock space but have the capability to do so. Area of Concern No Page 2 of 4 Phillips 66 Freeport Terminal SECTION II - OBSERVATIONS Inspection Date: 06/25/2024 Tenant: Phillips 66 Freeport Terminal Section: 2.1 Date: 06/25/24, 08:25 AM Contains AOC: No Contains CBI: No Lead Inspector: Vince Damiano Attendees: Aaron Flores (Compliance Coordinator), Bryan Wagner (Terminal Team Leader), Katie Mareno (Environmental Director), and G.L. Hurta (Environmental Specialist) Phillips is located just south of Port Freeport and operates within the same shipping channel. Phillips is not a tenant of Port Freeport. Phillips operates as a terminal for importing and exporting intermediates, liquid petroleum gas (LPG), gasoline blend stocks, and crude oil for their Sweeny Refinery in Old Ocean, TX. All materials are transported via pipelines. Materials may be temporarily stored in one of the facility's 28 storage tanks ranging in storage capacity from 625,000 - 16,917,910 gallons. From the storage tanks, product is piped to the dock where it can be loaded on to barges and vessels from a loading arm. Phillips maintains a MARPOL COA for Annexes I, II, and V (see Appendix 1) and is registered with EPA as a LQG of hazardous waste (EPA ID TXD988000204). Facility personnel stated they have systems in place to allow third party transporters to remove waste and oil slops from ships at their dock space, but that this has never occurred. Facility representatives explained to the inspection teams the various waste streams generated on site. The majority of waste is non-hazardous, consisting of oily contaminated debris and soil. Tank cleanings typically produce non-hazardous waste but can sometimes produce RCRA-regulated waste. Tank cleanings are sampled by Phillips before disposal to characterize the material. Aviation fuel and aviation fuel screening filters are managed as hazardous waste and stored in Phillips' central accumulation area (CAA). The inspection team began the visual inspection at 9:45 AM. The inspection team observed Dock #2 and Dock #3. No waste or issues were found in the dock areas. The inspection team next moved to the hazardous waste CAA where five full 55-gallon drums of Aviation gas waste were observed. The drums were properly labeled as hazardous for lead and had an accumulation start date of 5/15/2024. The inspection team also observed a full 30-gallon drum of toxic lead contaminated PPE in a satellite accumulation area. No apparent areas of concern were noted during the visual inspection. Following the visual inspection, a closing conference was conducted at approximately 10:55 AM with Phillips personnel. During the closing conference, the inspection team inquired about non-hazardous Tank 115 scale/rust drums noticed during the visual inspection and asked the facility for a hazardous waste determination. Following the inspection, Phillips provided an email explanation stating they were managing the scale/rust waste as non-hazardous based on generator knowledge; however, since the waste profile with the disposal facility was out of date, Phillips stated that it had been required to sample the waste again prior to disposal (see Appendix 2). Page 3 of 4 Phillips 66 Freeport Terminal Inspection Date: 06/25/2024 SECTION III - RECORDS REVIEW No RCRA-regulated records were reviewed during this focused onsite inspection. SECTION IV - AREAS OF CONCERN Not Applicable. SECTION V - 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. 06/26/24 Phillips email - Aaron Flores provided a copy of Phillips' MARPOL COA. 2. 06/27/24 Phillips email - Katie Mareno stated the Tank 115 rust/scale is pending analysis. 3. 06/28/24 Phillips email - Katie Mareno provided an explanation as to why the Tank 115 rust/scale is managed as non-hazardous waste based on generator knowledge. SECTION VI - LIST OF APPENDICES Appendix 1. Marpol COA Appendix 2. Phillips Follow-Up Email Page 4 of 4 APPENDIX 1. MARPOL COA APPENDIX 2. PHILLIPS FOLLOW-UP EMAIL