Document Jx4eLJG8jJbbZ8DpaNQ2pOMe
Inspection Entry Date/Time Inspection Exit Date/Time
Regulatory Program Type of Inspection
EPA REGION 6 Enforcement Division
INSPECTION REPORT
03/11/2024 14:08 (CT)
Announced: No
03/11/2024 16:30 (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
Buckeye Texas Hub LLC TXR000086148 7002 Marvin L Berry Road Corpus Christi, TX 78409 Nueces County N/A 424710 Buckeye Texas Hub LLC operates as a terminal and storage facility for crude oil and naphtha 27.827935, -97.49953
Additional Persons Participating in Inspection:
Name
Title
Organization
Joyce Johnson
Inspector
EPA REGION 6
Erin Young-Dahl
Inspector
EPA REGION 6
Andrew Gates
Contractor
Eastern Research Group (ERG)
Email Johnson.Joyce@epa.gov YoungDahl.Erin@epa.gov Andrew.Gates@erg.com
Lead Inspector: Vince Damiano
ERG
Vincent Damiano
Digitally signed by Vincent Damiano Date: 2024.07.11 18:24:11 -04'00'
Vince.Damiano@erg.com
Phone (214) 665-8548 (214) 665-3166 (657) 206-7829
07/11/2024 (703) 633-1732
Page 1 of 6
Buckeye Texas Hub LLC
Inspection Date: 03/11/2024
SECTION I - INTRODUCTION
Site Entry and Purpose of the Inspection
The Port of Corpus Christi 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
Andrew Gates (657) 206-7829 Andrew.Gates@erg.com Yes
Yes
Joyce Johnson (214) 665-8548 Johnson.Joyce@epa.gov Yes
Yes
Erin Young-Dahl (214) 665-3166 YoungDahl.Erin@epa.gov Yes
Yes
Page 2 of 6
Buckeye Texas Hub LLC
Inspection Date: 03/11/2024
Facility General Description
Tenant/Area Buckeye Texas Hub LLC
Inspection Date
03/11/24
Process Description Buckeye Texas Hub LLC (Buckeye) operates as a terminal and storage facility for crude oil and naphtha, which arrive via pipeline and truck rack. Other products, such as kerosene, jet fuel, high sulfur diesel, and atmospheric tower bottoms, are loaded directly onto ships via pipeline and are not stored on site. Marine bunker fuel arrives by vessel, is mixed onsite, and leaves by vessel. The facility operates five private docks. One dock, dock number 2, is shared with Gatefront LLC. The facility maintains a MARPOL COA for Annex I and V but does not receive waste from vessels.
Area of Concern
No
Page 3 of 6
Buckeye Texas Hub LLC
Inspection Date: 03/11/2024
SECTION II - OBSERVATIONS
Tenant: Buckeye Texas Hub LLC
Section: 2.1
Date: 03/11/24, 2:08 PM
Contains AOC: No Contains CBI: No
Lead Inspector: Vince Damiano Attendees: Anthony Cummings (Environmental Manager), Steven Hamlin (Operations Manager), David Long (Environmental Specialist)
Buckeye is located along the Port of Corpus Christi shipping channel and operates as an export terminal for crude oil, naphtha, kerosene, heavy fuel, and liquid petroleum gas (LPG). Buckeye receives crude oil and naphtha by mostly pipeline and stores it in tanks until it is loaded on vessels for transport. Kerosene and other high sulfur products are never stored onsite; these products are loaded directly onto vessels from a pipeline. Heavy fuel is received from ships, blended on site into marine bunker fuel, and loaded back onto vessels for delivery. LPG is received mostly by pipeline. Buckeye operates five private docks and maintains a MARPOL COA for Annex I and V from the USCG. Buckeye personnel stated that they do not accept waste from ships or allow third party companies to remove waste from ships across their docks. Buckeye maintains an EPA ID (TXR000086148) but is not a generator of hazardous waste.
During the inspection, the inspection team visually inspected several of Buckeye's dock spaces and its central accumulation area (CAA). At Dock #1, the inspection team observed a 55-gallon drum of oily debris which was properly labeled and in good condition and a collection sump for rainwater. Buckeye personnel said that the rainwater is pumped out via vacuum truck and sent to Western Gulf Recycling (WGR) to be treated and released. In the CAA, the inspection team observed two full 5-gallon containers of Kuridyne P-123 hydraulic fluid, which appeared to be discarded as wastes but were not labeled (see Appendix 1 - Photos 1 and 2). The inspection team requested a waste determination from Buckeye on the two hydraulic fluid containers.
The inspection team did not observe any AOCs at the time of the inspection. A closing conference was conducted at approximately 4:30 PM with Buckeye personnel. Buckeye responded via email on 03/22/2024 that the hydraulic oil was deemed to be non-hazardous and had been taken to WGR for disposal on 03/22/2024. In its email, Buckeye included analytical test results from the containers, an SDS for Kuridyne P123, and a bill of lading for the disposal of the oil at WGR (see Appendix 2, 3, and 4).
Page 4 of 6
Buckeye Texas Hub LLC
Inspection Date: 03/11/2024
SECTION III - RECORDS REVIEW No RCRA-regulated records were reviewed during this focused onsite inspection. SECTION IV - AREAS OF CONCERN No areas of concern found during inspection.
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. 03/15/24 Buckeye email - David Long provided follow-up photos of the noted hydraulic oil containers along with an update on the sampling process. 2. 03/22/24 Buckeye email - David Long provided the analytical results of the hydraulic oil, an SDS and a bill of lading.
Page 5 of 6
Buckeye Texas Hub LLC
SECTION VI - LIST OF APPENDICES Appendix 1. Photograph Log Appendix 2. Buckeye Analytical Report Appendix 3. Buckeye Kuridyne P-123 SDS Appendix 4. BOL Hydraulic Oil to WGR and Full Email
Inspection Date: 03/11/2024
Page 6 of 6
APPENDIX 1. PHOTOGRAPH LOG
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 1
Location: Buckeye Texas Hub LLC
City: Corpus Christi
County/Parish: Nueces
State: Texas
Photo File Name: DSCN7079 Date of Photo: 03/11/2024 Time of Photo: 15:10 hrs. Photographer: Vince Damiano Description: Two 5-gallon containers of unusable hydraulic fluid found in the CAA.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 2
Location: Buckeye Texas Hub LLC
City: Corpus Christi
County/Parish: Nueces
State: Texas
Photo File Name: DSCN7080 Date of Photo: 03/11/2024 Time of Photo: 15:10 hrs. Photographer: Vince Damiano Description: Two 5-gallon containers of unusable hydraulic fluid found in the CAA.
APPENDIX 2. BUCKEYE ANALYTICAL REPORT
1 2 3 4 5
ANALYTICAL REPORT 6
7 8 9
PREPARED FOR 10
11 Attn: David Long Buckeye Partners, L.P. 1501 Southern Minerals Road Corpus Christi, Texas 78409
Generated 3/18/2024 4:52:55 PM
JOB DESCRIPTION
Buckeye-Texas HUB RCI, 3/13/24
JOB NUMBER
560-116813-1
Eurofins Corpus Christi 1733 N. Padre Island Drive Corpus Christi TX 78408
See page two for job notes and contact information.
Page 1 of 15
1
Eurofins Corpus Christi
2
Job Notes
3
samples tested. For questions please contact the Project Manager at the e-mail address or telephone number listed on this This report may not be reproduced except in full, and with written approval from the laboratory. The results relate only to the 4
page. 5
The test results in this report relate only to the samples as received by the laboratory and will meet all requirements of the
methodology, with any exceptions noted. This report shall not be reproduced except in full, without the express written
6
approval of the laboratory. All questions should be directed to the Eurofins Environment Testing South Central, LLC Project
Manager.
7
8
Authorization
9
10
Generated
3/18/2024 4:52:55 PM
11
Authorized for release by Lance Tigrett, Project Manager II Lance.Tigrett@et.eurofinsus.com (979)484-9088
Eurofins Corpus Christi is a laboratory within Eurofins Environment Testing South Central, LLC, a company within Eurofins Environment Testing Group of
Companies
Page 2 of 15
3/18/2024
Client: Buckeye Partners, L.P. Project/Site: Buckeye-Texas HUB RCI, 3/13/24
Definitions/Glossary
Job ID: 560-116813-1
Qualifiers
General Chemistry
Qualifier
Qualifier Description
HF
Parameter with a holding time of 15 minutes. Test performed by laboratory at client's request. Sample was analyzed outside of hold time.
U
Indicates the analyte was analyzed for but not detected.
Glossary
Abbreviation %R CFL CFU CNF DER Dil Fac DL DL, RA, RE, IN DLC EDL LOD LOQ MCL MDA MDC MDL ML MPN MQL NC ND NEG POS PQL PRES QC RER RL RPD TEF TEQ TNTC
These commonly used abbreviations may or may not be present in this report. Listed under the "D" column to designate that the result is reported on a dry weight basis Percent Recovery Contains Free Liquid Colony Forming Unit Contains No Free Liquid Duplicate Error Ratio (normalized absolute difference) Dilution Factor Detection Limit (DoD/DOE) Indicates a Dilution, Re-analysis, Re-extraction, or additional Initial metals/anion analysis of the sample Decision Level Concentration (Radiochemistry) Estimated Detection Limit (Dioxin) Limit of Detection (DoD/DOE) Limit of Quantitation (DoD/DOE) EPA recommended "Maximum Contaminant Level" Minimum Detectable Activity (Radiochemistry) Minimum Detectable Concentration (Radiochemistry) Method Detection Limit Minimum Level (Dioxin) Most Probable Number Method Quantitation Limit Not Calculated Not Detected at the reporting limit (or MDL or EDL if shown) Negative / Absent Positive / Present Practical Quantitation Limit Presumptive Quality Control Relative Error Ratio (Radiochemistry) Reporting Limit or Requested Limit (Radiochemistry) Relative Percent Difference, a measure of the relative difference between two points Toxicity Equivalent Factor (Dioxin) Toxicity Equivalent Quotient (Dioxin) Too Numerous To Count
1 2 3 4 5 6 7 8 9 10 11
Page 3 of 15
Eurofins Corpus Christi
3/18/2024
Client: Buckeye Partners, L.P. Project: Buckeye-Texas HUB RCI, 3/13/24
Case Narrative
1 Job ID: 560-116813-1 2
Job ID: 560-116813-1
Job Narrative 560-116813-1
Eurofins Corpus Christi
3
4
Analytical test results meet all requirements of the associated regulatory program listed on the Accreditation/Certification Summary
5
Page unless otherwise noted under the individual analysis. Data qualifiers are applied to indicate exceptions. Noncompliant
quality control (QC) is further explained in narrative comments.
6
demonstrate precision and accuracy at a batch level, a LCS/LCSD may be performed, unless otherwise specified in the Matrix QC may not be reported if insufficient sample or site-specific QC samples were not submitted. In these situations, to 7
method.
Surrogate and/or isotope dilution analyte recoveries (if applicable) which are outside of the QC window are confirmed unless attributed to a dilution or otherwise noted in the narrative. 8
Regulated compliance samples (e.g. SDWA, NPDES) must comply with the associated agency requirements/permits.
9
Receipt
10
The sample was received on 3/13/2024 3:18 PM. Unless otherwise noted below, the sample arrived in good condition, and, where
required, properly preserved and on ice. The temperature of the cooler at receipt time was 31.4C. 11
General Chemistry Method 9040C: This analysis is normally performed in the field and has a method-defined holding time of 15 minutes. The following sample has been qualified with the "HF" flag to indicate analysis was performed in the laboratory outside the 15 minute timeframe: Waste Buckets (560-116813-1).
No additional analytical or quality issues were noted, other than those described above or in the Definitions/ Glossary page.
Page 4 of 15
Eurofins Corpus Christi 3/18/2024
Client: Buckeye Partners, L.P. Project/Site: Buckeye-Texas HUB RCI, 3/13/24
Client Sample ID: Waste Buckets
Detection Summary
Analyte Flashpoint pH
Result 200 7.7
Qualifier HF
RL
MDL Unit
70.0
70.0 Degrees F
0.1
0.1 SU
1
Job ID: 560-116813-1
2
Lab Sample ID: 560-116813-1 3
Dil Fac D Method
1
1010
1
9040C
4 Prep Type
Total/NA
Total/NA
5
6
7
8
9
10
11
This Detection Summary does not include radiochemical test results.
Page 5 of 15
Eurofins Corpus Christi
3/18/2024
Client: Buckeye Partners, L.P. Project/Site: Buckeye-Texas HUB RCI, 3/13/24
Client Sample ID: Waste Buckets
Date Collected: 03/13/24 14:35 Date Received: 03/13/24 15:18
Client Sample Results
General Chemistry
Analyte Flashpoint (SW846 1010) Cyanide, Reactive (SW846 9012) Sulfide, Reactive (SW846 9034) pH (SW846 9040C)
Result 200
0.0125 1.25 7.7
Qualifier
U U HF
RL 70.0 0.0250 6.25
0.1
MDL 70.0 0.0125 1.25
0.1
Unit Degrees F mg/L mg/L SU
Job ID: 560-116813-1
Lab Sample ID: 560-116813-1
Matrix: Water
D
Prepared
03/17/24 11:30 03/17/24 11:30
Analyzed 03/15/24 15:30 03/18/24 13:07 03/17/24 15:39 03/15/24 13:08
Dil Fac 1 1 1 1
1 2 3 4 5 6 7 8 9 10 11
Page 6 of 15
Eurofins Corpus Christi
3/18/2024
Client: Buckeye Partners, L.P. Project/Site: Buckeye-Texas HUB RCI, 3/13/24
QC Sample Results
Method: 1010 - Ignitability, Pensky-Martens Closed-Cup Method
Job ID: 560-116813-1
Lab Sample ID: LCS 560-213619/1 Matrix: Water Analysis Batch: 213619
Analyte Flashpoint
Spike Added
127
Client Sample ID: Lab Control Sample Prep Type: Total/NA
LCS Result 125.0
LCS Qualifier
Unit Degrees F
D %Rec 98
%Rec Limits 88 - 112
Lab Sample ID: 560-116813-1 DU Matrix: Water Analysis Batch: 213619
Analyte Flashpoint
Sample Result 200
Sample Qualifier
Method: 9012 - Cyanide, Reactive
DU Result 202.0
DU Qualifier
Unit Degrees F
Client Sample ID: Waste Buckets Prep Type: Total/NA
RPD
D
RPD Limit
1
20
Lab Sample ID: MB 860-150150/1-A Matrix: Water Analysis Batch: 150301
Analyte Cyanide, Reactive
MB Result 0.0125
MB Qualifier U
RL 0.0250
MDL Unit 0.0125 mg/L
Client Sample ID: Method Blank Prep Type: Total/NA Prep Batch: 150150
D
Prepared
03/17/24 11:30
Analyzed 03/18/24 13:03
Dil Fac 1
1 2 3 4 5 6 7 8 9 10 11
Lab Sample ID: LCS 860-150150/2-A Matrix: Water Analysis Batch: 150301
Analyte Cyanide, Reactive
Spike Added
20.0
LCS Result 3.071
LCS Qualifier
Unit mg/L
Client Sample ID: Lab Control Sample Prep Type: Total/NA Prep Batch: 150150
%Rec
D %Rec Limits
15
5 - 40
Lab Sample ID: LCSD 860-150150/3-A Matrix: Water Analysis Batch: 150301
Analyte Cyanide, Reactive
Spike Added
20.0
LCSD Result 3.226
LCSD Qualifier
Client Sample ID: Lab Control Sample Dup Prep Type: Total/NA Prep Batch: 150150
%Rec
RPD
Unit
D %Rec Limits
RPD Limit
mg/L
16
5 - 40
5
20
Lab Sample ID: 560-116813-1 DU Matrix: Water Analysis Batch: 150301
Analyte Cyanide, Reactive
Sample Result 0.0125
Sample Qualifier U
Method: 9034 - Sulfide, Reactive
DU Result 0.0125
DU Qualifier U
Unit mg/L
Client Sample ID: Waste Buckets Prep Type: Total/NA Prep Batch: 150150
RPD
D
RPD Limit
NC
20
Lab Sample ID: MB 860-150148/1-A Matrix: Water Analysis Batch: 150156
Analyte Sulfide, Reactive
MB Result
1.25
MB Qualifier U
RL
MDL Unit
6.25
1.25 mg/L
Client Sample ID: Method Blank Prep Type: Total/NA Prep Batch: 150148
D
Prepared
03/17/24 11:30
Analyzed 03/17/24 15:39
Dil Fac 1
Page 7 of 15
Eurofins Corpus Christi
3/18/2024
Client: Buckeye Partners, L.P. Project/Site: Buckeye-Texas HUB RCI, 3/13/24
QC Sample Results
Method: 9034 - Sulfide, Reactive (Continued)
Lab Sample ID: LCS 860-150148/2-A Matrix: Water Analysis Batch: 150156
Analyte Sulfide, Reactive
Spike Added
50.0
LCS Result 48.09
LCS Qualifier
Lab Sample ID: LCSD 860-150148/3-A Matrix: Water Analysis Batch: 150156
Analyte Sulfide, Reactive
Spike Added
50.0
LCSD Result 52.10
LCSD Qualifier
Lab Sample ID: 560-116813-1 DU Matrix: Water Analysis Batch: 150156
Analyte Sulfide, Reactive
Sample Result 1.25
Sample Qualifier U
Method: 9040C - Corrosivity as pH
DU Result
1.25
DU Qualifier U
Lab Sample ID: LCS 560-213613/2 Matrix: Water Analysis Batch: 213613
Analyte pH
Spike Added
5.00
LCS Result
5.0
LCS Qualifier
1
Job ID: 560-116813-1
2
3
Client Sample ID: Lab Control Sample
Prep Type: Total/NA 4
Prep Batch: 150148
%Rec
5
Unit
D %Rec Limits
mg/L
96 30 - 120
6
Client Sample ID: Lab Control Sample Dup Prep Type: Total/NA 7 %Rec RPD Prep Batch: 150148 8
Unit mg/L
D %Rec 104
Limits 30 - 120
RPD Limit
8 20 9
Client Sample ID: Waste Buckets 10
Prep Type: Total/NA
Prep Batch: 150148 11 RPD
Unit
D
RPD Limit
mg/L
NC
20
Client Sample ID: Lab Control Sample Prep Type: Total/NA
%Rec
Unit
D %Rec Limits
SU
100 98 - 102
Page 8 of 15
Eurofins Corpus Christi
3/18/2024
Accreditation/Certification Summary
Client: Buckeye Partners, L.P. Project/Site: Buckeye-Texas HUB RCI, 3/13/24
Laboratory: Eurofins Corpus Christi
The accreditations/certifications listed below are applicable to this report.
Job ID: 560-116813-1
Authority Texas
Program NELAP
Identification Number T104704210-22-30
Laboratory: Eurofins Houston
Unless otherwise noted, all analytes for this laboratory were covered under each accreditation/certification below.
Expiration Date 03-31-24
Authority Texas
Program NELAP
Identification Number T104704215
Expiration Date 06-30-24
The following analytes are included in this report, but the laboratory is not certified by the governing authority. This list may include analytes for which the agency does not offer certification .
Analysis Method 9012
Prep Method 7.3.3
Matrix Water
Analyte Cyanide, Reactive
9034
7.3.4
Water
Sulfide, Reactive
1 2 3 4 5 6 7 8 9 10 11
Page 9 of 15
Eurofins Corpus Christi
3/18/2024
Client: Buckeye Partners, L.P. Project/Site: Buckeye-Texas HUB RCI, 3/13/24
Method Summary
Method 1010 9012 9034 9040C 7.3.3 7.3.4
Method Description Ignitability, Pensky-Martens Closed-Cup Method Cyanide, Reactive Sulfide, Reactive Corrosivity as pH Cyanide, Reactive Sulfide, Reactive
Protocol SW846 SW846 SW846 SW846 SW846 SW846
Protocol References: SW846 = "Test Methods For Evaluating Solid Waste, Physical/Chemical Methods", Third Edition, November 1986 And Its Updates.
Laboratory References: EET CC = Eurofins Corpus Christi, 1733 N. Padre Island Drive, Corpus Christi, TX 78408, TEL (361)289-2471 EET HOU = Eurofins Houston, 4145 Greenbriar Dr, Stafford, TX 77477, TEL (281)240-4200
1
Job ID: 560-116813-1
2
3
Laboratory
EET CC EET HOU 4
EET HOU EET CC 5
EET HOU
EET HOU
6
7
8
9
10
11
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Eurofins Corpus Christi
3/18/2024
Client: Buckeye Partners, L.P. Project/Site: Buckeye-Texas HUB RCI, 3/13/24
Lab Sample ID 560-116813-1
Client Sample ID Waste Buckets
Sample Summary
Matrix Water
Collected 03/13/24 14:35
Received 03/13/24 15:18
1
Job ID: 560-116813-1
2 3 4 5 6 7 8 9 10 11
Page 11 of 15
Eurofins Corpus Christi
3/18/2024
1 2 3 4 5 6 7 8 9 10 11
Page 12 of 15
3/18/2024
1 2 3 4 5 6 7 8 9 10 11
Page 13 of 15
3/18/2024
Login Sample Receipt Checklist
Client: Buckeye Partners, L.P.
Login Number: 116813 List Number: 1 Creator: Stacy, Taylor
Question Radioactivity wasn't checked or is </= background as measured by a survey meter. The cooler's custody seal, if present, is intact. Sample custody seals, if present, are intact. The cooler or samples do not appear to have been compromised or tampered with. Samples were received on ice. Cooler Temperature is acceptable.
Cooler Temperature is recorded. COC is present. COC is filled out in ink and legible. COC is filled out with all pertinent information. Is the Field Sampler's name present on COC? There are no discrepancies between the containers received and the COC. Samples are received within Holding Time (excluding tests with immediate HTs) Sample containers have legible labels. Containers are not broken or leaking. Sample collection date/times are provided. Appropriate sample containers are used. Sample bottles are completely filled. Sample Preservation Verified. There is sufficient vol. for all requested analyses, incl. any requested MS/MSDs Containers requiring zero headspace have no headspace or bubble is <6mm (1/4"). Multiphasic samples are not present. Samples do not require splitting or compositing. Residual Chlorine Checked.
Job Number: 560-116813-1 List Source: Eurofins Corpus Christi
Answer N/A
True True True
True False
True True True True True True True
True True True True True True True
True
True True N/A
Comment Received same day of collection; chilling process has begun.
Check done at department level as required.
1 2 3 4 5 6 7 8 9 10 11
Eurofins Corpus Christi
Page 14 of 15
3/18/2024
Login Sample Receipt Checklist
Client: Buckeye Partners, L.P.
Login Number: 116813 List Number: 2 Creator: Baker, Jeremiah
Question The cooler's custody seal, if present, is intact. Sample custody seals, if present, are intact. The cooler or samples do not appear to have been compromised or tampered with. Samples were received on ice. Cooler Temperature is acceptable. Cooler Temperature is recorded. COC is present. COC is filled out in ink and legible. COC is filled out with all pertinent information. Is the Field Sampler's name present on COC? There are no discrepancies between the containers received and the COC. Samples are received within Holding Time (excluding tests with immediate HTs) Sample containers have legible labels. Containers are not broken or leaking. Sample collection date/times are provided. Appropriate sample containers are used. Sample bottles are completely filled. Sample Preservation Verified. There is sufficient vol. for all requested analyses, incl. any requested MS/MSDs Containers requiring zero headspace have no headspace or bubble is <6mm (1/4").
Answer True True True
True True True True True True True True True
True True True True True True True
True
Comment
1 2 Job Number: 560-116813-1 3 List Source: Eurofins Houston 4 List Creation: 03/16/24 10:31 AM 5 6 7 8 9 10 11
Eurofins Corpus Christi
Page 15 of 15
3/18/2024
APPENDIX 3. BUCKEYE KURIDYNE P-123 SDS
SDS
Safety Data Sheet
KURIDYNE P-123
Date : 9/12/2016
1 IDENTIFICATION OF THE SUBSTANCE OR MIXTURE AND OF THE SUPPLIER
Product Name: Product Use:
KURIDYNE P-123 Cleaning agent
Manufacturer:
Contact: Phone: FAX: Emergency Telephone:
Kurita America, Inc. 16850 Diana Lane, Suite B 104, Houston, Texas 77058 Chemical Group 281-998-3900 281-998-3903 CHEMTREC (Health/ Transport/ Regulatory) 1-800-424-9300 1-800-424-8802
2 HAZARDS IDENTIFICATION
Classification:
Not classified to all hazard categories.
Physical Hazard Explosives: Flammable gases: Flammable aerosols: Oxidizing gases: Gases under pressure: Flammable liquids: Flammable solids: Self-reactive substances: Pyrophoric liquids: Pyrophoric solids: Self-heating substances: Substances which in contact with water emit flammable gasses: Oxidizing liquids: Oxidizing solids: Organic peroxides: Corrosive to metals:
Health Hazard Acute toxicity Oral: Dermal: Gases: Vapors:
Not applicable Not applicable Not applicable Not applicable Not applicable Not applicable Not applicable Not applicable Not applicable Not applicable Not applicable
Not applicable Not applicable Not applicable Not applicable Not classified
Not classified Not classified Not classified Not classified
Page 1 of 5
SDS
Safety Data Sheet
KURIDYNE P-123
Dust & mists: Skin corrosion/irritation: Serious eye damage/eye irritation: Respiratory sensitization: Skin sensitization: Germ cell mutagenicity: Carcinogenicity: Reproductive toxicology: Target organ systemic toxicity - Single exposure: Target organ systemic toxicity - Repeated exposure: Aspiration toxicity: Environmental Hazard Acute aquatic toxicity: Chronic aquatic toxicity:
Not classified Not classified Not classified Not classified Not classified Not classified Not classified Not classified
Not classified
Not classified Not classified
Not classified Not classified
Signal word:
There are no signal word and no hazard statement allocated to all hazard categories.
Labeling:
There are no label element allocated to all hazard statement.
Hazard statements:
-
Precautionary statements:
-
3 COMPOSITION / INFORMATION ON INGREDIENTS
Chemical Name Organic acid Phosphonate salt Phosphoric acid
CAS No. Not disclosed Not disclosed Not disclosed
Weight % Not disclosed Not disclosed Not disclosed
4 FIRST-AID MEASURES
Inhalation :
Remove victim from exposed area immediately to fresh air. Keep warm and at rest. Get medical attention.
Skin contact:
May cause irritation. Wash the affected area with plenty of water. Take off immediately contaminated clothes. Wash it plenty of water. If burns occur, get medical attention.
Page 2 of 5
SDS
Safety Data Sheet
KURIDYNE P-123
Eye contact: Ingestion:
May causes eye irritation. Wash eyes immediately with large amount of water, occasionally lifting upper and lower eyelids for more than 15 minutes. Get medical attention immediately. Give large amount of water or milk immediately. Do not induce vomiting. Get medical attention immediately.
5 FIRE-FIGHTING MEASURES
Keep away from the source of fire or cool containers with water in case of difficult transportation. Use extinguishing media appropriate for surrounding fire.
6 ACCIDENTAL RELEASE MEASURES
Wear protective clothes. Stop leak. For small liquid spills, flush area with flooding amount of water. For large spills, stop the flow with dike, etc. without making liquid flow into sewer. Thoroughly rinse affected ground with plenty of water.
7 HANDLING AND STORAGE
Precautions for safe handling:
Operate with filter respirator, chemical safety goggles, working clothes with long sleeve and rubber globs to avoid inhalation, eye and skin contact.
Conditions for safe storage:
Store product in tightly closed containers in the cool, dry and well ventilated indoor area.
Dealing:
Do not use empty container for drinking water supply.
8 EXPOSURE CONTROL / PERSONAL PROTECTION
Exposure limits:
Acetic acid ACGIH (TLV-TWA) 25mg/m3 -
Engineering controls: Personal protective equipment
Respiratory protection: Skin protection:
Eye protection:
Not applicable
Filter respirator Wear Synthetic rubber made gloves. Wear long-sleeve clothes. Chemical safety goggles.
Page 3 of 5
SDS
Safety Data Sheet
KURIDYNE P-123
9 PHYSICAL AND CHEMICAL PROPERTIES
Appearance: Physical state: Specific gravity: Solubility: Odor: Freezing Point: Flash Point: pH: CODmn:
Colorless Liquid 1.30 - 1.36 (20 dC) Miscible at any ratio Not applicable less than - 15 Not applicable 6.2 - 7.2 (20 dC) 4.7%
10 SATBILITY AND REACTIVITY
Stability:
Stable on normal usage and handing.
11 TOXICOLOGICAL INFORMATION
Acute toxicity: LD (50) oral/rabbit:
2,100 mg/kg
Skin corrosion/irritation:
May cause irritation.
Serious eye damage/eye irritation: May causes eye irritation.
12 ECOLOGICAL INFORMATION
Aquatic toxicity: LC (50) killifish 24hrs:
18,000 mg/l
13 DISPOSAL CONSIDERATIONS
Never draw chemical directly to waste water, sewer on the ground, or into any body of water. Dispose of this material and its container to a licensed waste agency. Empty used containers completely. Consulted with local Waste Treatment Specialist before disposal.
14 TRANSPORT INFORMATION
UN Class : Not applicable
UN No. : Not applicable
Packing Group : Not applicable
Prevent destruction by keeping away from water and careless dealing.
Page 4 of 5
SDS
Safety Data Sheet
KURIDYNE P-123
15 REGULATORY INFORMATION
All components of this product are included on the TSCA inventory.
16 OTHER INFORMATION
The information contained herein is, to the best of our knowledge and belief, accurate. However, no warranty is expressed or implied regarding the accuracy of this data or the results to be obtained from the use thereof. Vendor assumes no responsibility for injury to vendee or third person proximately caused by the material if reasonable safety procedures are not adhered to as stipulated in the data sheet. Additionally, vendor assumes no responsibility for injury to vendee or third persons proximately caused by abnormal use of the material even if reasonable safety procedures are followed. Furthermore, vendee assumes the risk in this use of the material.
Page 5 of 5
APPENDIX 4. BOL HYDRAULIC OIL TO WGR AND FULL EMAIL
RE: Follow-up from EPA Visit 3/11/2024 Long, David <DLong@buckeye.com>
Fri 3/22/2024 12:19 PM To:Vince Damiano <Vince.Damiano@erg.com>;Andrew Gates <andrew.gates@erg.com>;Johnson, Joyce-R6 <johnson.joycer6@epa.gov>;Young-Dahl, Erin <YoungDahl.Erin@epa.gov> Cc:Cummings, Anthony <ACummings@buckeye.com>;Hamlin,Steven <SHamlin@buckeye.com>
3 attachments (1 MB) J116813-1 UDS Level 2 Report Final Report.pdf; SDS KURIDYNE P-123.pdf; BOL_hydraulic oil to Western Gulf.pdf;
CAUTION: Don't open links or attachments unless you recognize the sender and know they are safe. Good Morning,
We wanted to take a moment to provide an update for Buckeye Texas HUB "EPA Visit 3/11/2024." Following a review of the attached characteristic results and SDS, Buckeye confirmed the determination of this hydraulic fluid to be unused and scheduled to have this material recycled locally at Western Gulf Recycling (see attached Bill of Lading) for beneficial re-use and/or resale following separation of potential water. This material was transported to Western Gulf by Miller Environmental on 3/22/2024.
Please reach out to myself for any further questions.
Thank you and have a great weekend,
David Long
HSSE-Environmental Specialist
South Texas District
7209 UP River Rd. Corpus Christi, TX 78409 Mobile: (361) 813-6084 | Office: (361) 792-3093
DLong@buckeye.com
From: Long, David Sent: Friday, March 15, 2024 10:26 AM To: 'Vince Damiano' <Vince.Damiano@erg.com>; Cummings, Anthony <ACummings@buckeye.com>; Hamlin,Steven <SHamlin@buckeye.com> Cc: 'Andrew Gates' <andrew.gates@erg.com>; 'Johnson, Joyce-R6' <johnson.joyce-r6@epa.gov>; 'Young-Dahl, Erin' <YoungDahl.Erin@epa.gov> Subject: RE: Follow-up from EPA Visit 3/11/2024
Good Morning,
We wanted to take a minute to provide an update for Buckeye Texas HUB "EPA Visit 3/11/2024"
Appendix 4 Page 1 of 5
Below are photos of the damaged 2 5-gallon buckets of suspected un-used hydraulic fluid in the Mississippi Sands Warehouse. These items were moved to the containment area and sampled for characterization (COC attached). Base on the SDS for the material (attached), Buckeye analyzed for reactivity, corrosivity, and ignitability. Results expected by Monday (3/18) from Eurofins. A determination and final action will follow the week of 3/18.
Thankyou,
David Long
HSSE-Environmental Specialist
South Texas District
7209 UP River Rd. Corpus Christi, TX 78409 Mobile: (361) 813-6084 | Office: (361) 792-3093
DLong@buckeye.com
From: Long, David Sent: Tuesday, March 12, 2024 9:08 AM To: Vince Damiano <Vince.Damiano@erg.com>; Cummings, Anthony <ACummings@buckeye.com>; Hamlin,Steven <SHamlin@buckeye.com> Cc: Andrew Gates <andrew.gates@erg.com>; Johnson, Joyce-R6 <johnson.joyce-r6@epa.gov>; Young-Dahl, Erin <YoungDahl.Erin@epa.gov> Subject: RE: Follow-up from EPA Visit 3/11/2024
Appendix 4 Page 2 of 5
Good Morning,
We'll be working on getting these items disposed of and will send the documentation/determination/process soon. Thanks for your quick summary/response.
David Long
HSSE-Environmental Specialist
South Texas District
7209 UP River Rd. Corpus Christi, TX 78409 Mobile: (361) 813-6084 | Office: (361) 792-3093
DLong@buckeye.com
From: Vince Damiano <Vince.Damiano@erg.com> Sent: Monday, March 11, 2024 5:54 PM To: Long, David <DLong@buckeye.com>; Cummings, Anthony <ACummings@buckeye.com>; Hamlin,Steven <SHamlin@buckeye.com> Cc: Andrew Gates <andrew.gates@erg.com>; Johnson, Joyce-R6 <johnson.joyce-r6@epa.gov>; Young-Dahl, Erin <YoungDahl.Erin@epa.gov> Subject: Follow-up from EPA Visit 3/11/2024
WARNING: This email originated outside of Buckeye Partners, L.P. DO NOT CLICK links or attachments unless you recognize the sender and know the
content is safe. If you have any questions please contact the Buckeye Partners service desk.
Hello All, I am following up with a list of items and notes from our inspection today. We would like you to send us:
Follow-up on the two 5-gallon containers of hydraulic fluid found in storage area. Please provide a waste determination and information on how you decide to manage the fluid. Again, thank you for taking the time out of your day to meet with us. Please let us know if you have any questions or concerns. Any follow-up can be sent to myself and the persons attached. Thanks, Vince
Vince Damiano
Chemical Engineer, Chantilly Office Appendix 4 Page 3 of 5
Cell: (570) 956-1468 Vince.Damiano@erg.com
Appendix 4 Page 4 of 5
Appendix 4 Page 5 of 5