Document MoKQ2Z8VZpbqJyRB8V8mLaGpj

Inspection Date(s): Time: Program: Regulatory Program(s): If Access is Denied: REGION 10 Enforcement Division INSPECTION REPORT 06/08/2022 - 06/08/2022 Announced: No Entry: 10:49 AM (AKT) Exit: 12:45 PM (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: Alyeska Pipeline Service Company Alyeska TAPS Pump Station 4 Dalton Highway Milepost 270 Deadhorse, AK 99740 Crude oil transportation 25 acres Since 1974/1975 68.421666, -149.358637 Mr. Jan Shifflett, Environment Manager jan.shifflett@alyeska-pipeline.com Alyeska Pipeline Service Company 3700 Centerpoint West P.O. Box 196660, MS 507 CC: Ms. Gretchen Stoddard, Waste Management SME gretchen.stoddard@alyeska-pipeline.com Anchorage, AK 99519 Facility/Site Identifier: Media Number: NAICS: AKD980977318 N/A 48611 - Pipeline Transportation of Crude Oil Lead Inspector: Jon Jones Jones, Jon REGION 10 Digitally signed by Jones, Jon Date: 2022.07.22 10:46:01 -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: 2022.08.01 08:40:11 -07'00' Sullivan.Jennifer.A@epa.gov (206) 553-6978 1 of 6 ALYESKA TAPS PUMP STATION 4 Inspection Date(s): 06/08/2022 - 06/08/2022 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 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 2022. Attendees Title Lead Inspector PS04 Maintenance Supervisor PS04 Lead Technician PS01-PS04 Environmental Coordinator Name Jon Jones Mark Dahl Phone Email 9072716329 Jones.Jon@epa.gov (907) 450-4402 mark.dahl@alyeskapipeline.com Present in Present in Opening Conf. Closing Conf. Yes Yes Yes Yes Steve Barfield (907) 450-4258 stephen.barfield@alyeska- Yes Yes pipeline.com Ryan Studley (907) 450-4185 ryan.studley@alyeska- Yes Yes pipeline.com Opening Conference EPA Lead Inspector Jon Jones arrived at the Alyeska TAPS Pump Station 4 at 10:49 AM (AKT) on 06/08/2022 for an inspection. I presented my credentials to Ryan Studley and informed him that this was an EPA RCRA inspection. The table above presents all the inspection opening and closing conference participants. I was accompanied by Mr. Ratky during the inspection of the facility. 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. I also observed the facility's universal waste and used oil management. Specifically, I inspected the following areas of the facility listed below. Only those areas in which I observed areas of concern or noted other pertinent issues are discussed in this inspection report. 2 of 6 ALYESKA TAPS PUMP STATION 4 Inspection Date(s): 06/08/2022 - 06/08/2022 Facility/Site Description Alyeska TAPS PS04 (here after referred to as PS04 or facility) is in a remote area of Alaska, approximately 270 miles south of Deadhorse, Alaska on the Dalton Highway. The following information was obtained from Alyeska personnel during the inspection. The facility is a crude oil pipeline pumping station. Alyeska TAPS Pump Station 4 is one of twelve pumping stations along the TAPS. There are currently only four pump stations (1, 3, 4, and 9) that pump crude oil from Prudhoe Bay down to Valdez. Work performed at the facility includes: Pipeline maintenance Pig launching/receiving Pump station maintenance Facility Info Safety Training No Provided to Inspector(s)? Operating Hours 24/7, 365 with 12-hour shifts Weather Conditions Cool and windy Number of employees 45 What type of LQG generator facility notified? What type of LQG generator facility verified as? Process Description A description of the facility's wastes and the amounts that were in accumulation at the facility during the inspection are contained within the attached weekly container inspection logs that are listed in the Section VI - Document Log. Building(s) Building/Area/Sub-area Equipment shop Hazardous Waste Storage Conex Helicopter building Manifold building CAA Oil Spill Contingency Plan (OSCP) building Shop/Warehouse building Tank farm CAA Warm Storage Tent Process Description CAA CAA Helicopter hangar and SAA Pigs are received and relaunched further down the TAPS. Pig wax is generated as a waste and accumulated in the Manifold building CAA. Accumulation area for the waste pig wax. SAA Area of Concern No No No No No No CAA No Hazardous waste storage area for waste pig wax. No Used as an overflow CAA No 3 of 6 ALYESKA TAPS PUMP STATION 4 Inspection Date(s): 06/08/2022 - 06/08/2022 SECTION II - OBSERVATIONS AND RECORDS REVIEW Observations Building: Manifold building/CAA Observation #: JJ1-OB-001 Contains CBI: No Date: 06/08/2022 At the time of the inspection, there was one 55-gallon container of waste pig wax in the CAA. According to Alyeska personnel a pig was being received at PS04 every two weeks and they typically generate four 55-gallon containers of waste pig wax each time the pig is received. Building: Tank farm CAA Observation #: JJ1-OB-002 Contains CBI: No Date: 06/08/2022 At the time of the inspection, there were seven 55-gallon containers of waste pig wax in accumulation. Photo(s) 1. IMG-202206081125482548973520.jpg 2. IMG-20220608112605265840089.jpg Building: Warm Storage Tent Observation #: JJ1-OB-003 Contains CBI: No Date: 06/08/2022 At the time of the inspection, there was no waste in accumulation at the Warm Storage Tent. According to Alyeska personnel, the CAA is used for projects that may generate a large amount of waste. Records Review Record: Manifests Ref #: JJ1-RR-001 Reviewed By: Jon Jones AOC: No Reviewed Date: 07/20/2022 While reviewing hazardous waste manifests, sent to me following the inspection, I saw that manifest #012646462 FLE, for a shipment that left PS4 on 9/9/21, was not dated by the generator. I followed up by searching E-Manifest and after finding the manifest, I saw a note of the discrepancy on the manifest and saw that the designated facility had added the 9/9/21 date for the generator. Document(s) 1. PS04 Waste Run Paperwork 090921.pdf 2. Manifest_012646462FLE.pdf Record: Manifests Ref #: JJ1-RR-002 Reviewed By: Jon Jones AOC: No Reviewed Date: 07/21/2022 During my review of the manifests, I saw that there was an internal memo regarding delayed waste shipments during the onset of COVID. One of those delayed shipments was a shipment from PS04. A copy of the memo and manifest for that delayed shipment is included as an attachment to this report and included in the Section VI - Document Log. 4 of 6 ALYESKA TAPS PUMP STATION 4 Inspection Date(s): 06/08/2022 - 06/08/2022 Document(s) 1. COVID waste pickup delay.pdf 2. 012645914 TSD.pdf SECTION III - AREAS OF CONCERN The presentation of areas of concern does not constitute a formal compliance determination or violation. I observed no areas of concern at the time of the inspection. SECTION IV - FOLLOW UP N/A Closing Conference At the conclusion of the inspection, I conducted a closing conference that was attended by those listed in the Attendees table, in Section I of this report. I thanked everyone for their time and cooperation during the inspection. I then explained the follow-up process that would take place once I finished the report. I explained they would receive a copy of the report as would a case officer. I told those present at the closing conference that I had not observed any areas of concern during my inspection of the facility; however, areas of concern could still be identified once the inspection report was completed and reviewed. SECTION V - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS - No sampling was conducted. SECTION VI - LIST OF APPENDICES Photo Log [Title] IMG-202206081125482548973520.jpg 06/08/2022 11:25 AM (AKT) Jon Jones Tank farm CAA No CBI No PII View of the CAA. 5 of 6 ALYESKA TAPS PUMP STATION 4 Inspection Date(s): [Title] IMG-20220608112605265840089.jpg 06/08/2022 11:26 AM (AKT) Jon Jones Tank farm CAA No CBI No PII Another view of the CAA. 06/08/2022 - 06/08/2022 Document Log Document Type Document Name Contains Contains Uploaded By CBI PII Facility Map Facility map.pdf No No Jon Jones Other - PS4 monthly PS1 and PS4 monthly waste waste generation generation.pdf rates No No Jon Jones Other - Weekly Weekly container inspection log.pdf No No Jon Jones container log Contingency Plan PS04 RCRA C-Plan Appendix C wcover.pdf No No Jon Jones Records Review PS04 Waste Run Paperwork 090921.pdf No No Jon Jones Records Review Manifest_012646462FLE.pdf No No Jon Jones Records Review COVID waste pickup delay.pdf No No Jon Jones Records Review 012645914 TSD.pdf No No Jon Jones Date Received 07/19/2022 07/19/2022 07/19/2022 07/19/2022 07/20/2022 07/20/2022 07/21/2022 07/21/2022 6 of 6