Document Qg7oZmeDJm38m58o9dKqkGObo

Inspection Date(s): Time: Program: Regulatory Program(s): If Access is Denied: REGION 10 Enforcement Division INSPECTION REPORT 04/28/2021 - 04/28/2021 Announced: No Entry: 02:55 PM (AKT) Exit: 03:49 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: Harvest Alaska, LLC HARVEST ALASKA - MIDSTREAM PIPELINE DIVISION - EAST FORELANDS 53550 RODNEY & SHELLEY'S AVE NIKISKI, AK 99611 Natural gas pipeline junction facility 10 acres Since 1969 60.736485, -151.33638 Mr. Kijun Hong, Environmental Specialist khong@harvestmidstream.com 3800 Centerpoint Drive, Suite 1400 Anchorage, AK 99503 Facility/Site Identifier: Media Number: NAICS: AKR000204230 Unpermitted Facility 486210 - Pipeline Transportation of Natural Gas Lead Inspector: Jon Jones Jones, Jon REGION 10 Digitally signed by Jones, Jon Date: 2021.07.07 13:51:58 -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: 2021.07.12 15:21:56 -07'00' Sullivan.Jennifer.A@epa.gov (206) 553-6978 1 of 6 HARVEST ALASKA - MIDSTREAM PIPELINE DIVISION - EAST FORELANDS Inspection Date(s): 04/28/2021 - 04/28/2021 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 2021. Attendees Title Name Phone Email Lead Inspector Jon Jones 9072716329 Jones.Jon@epa.gov Present in Opening Conf. Yes Environmental Kijun Hong Specialist Safety Specialist Eric Wilcox II (505) 436-8457 khong@harveststream.com Yes (907) 283-1375 ewilcox@harvestmidstream.com Yes Lead Operator Elijah Gerow (907) 398-9976 egerow@harvestmidstream.com Yes Present in Closing Conf. Yes Yes Yes Yes Opening Conference EPA Lead Inspector Jon Jones arrived at the HARVEST ALASKA - MIDSTREAM PIPELINE DIVISION - EAST FORELANDS at 02:55 PM (AKT) on 04/28/2021 for an inspection. I presented my credentials to Eric Wilcox 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 Harvest Alaska - Midstream Pipeline Division - East Forelands facility is a natural gas pipeline junction located along the shores of Nikiski Bay, on Cook Inlet in Nikiski, Alaska. Facility Info Number of employees Unmanned facility What type of generator facility notified? Not a generator 2 of 6 HARVEST ALASKA - MIDSTREAM PIPELINE DIVISION - EAST FORELANDS Inspection Date(s): 04/28/2021 - 04/28/2021 Process Description The facility is a flow through facility with a 10 inch gas line and a 10 inch crude oil line that comes into the facility from Cook Inlet production platforms and exits the facility, going to a Kenai Pipeline (KPL) junction where it enters the Kenai/Nikiski pipeline and gets sent to processing facilities. Building(s) Building/Area Filter room Process Description Used to have filters or what was referred to as separators that pulled liquid out of the gas. The separators were removed in 2015 and the building is now used for storage. Area of Concern No Office No Storage building No SECTION II - OBSERVATIONS AND RECORDS REVIEW Observations Building: Filter room Contains CBI: No Observation #: JJ1-OB-002 Date/Time: 04/28/2021 While I was inspecting the Filter room, I saw a smart ash burner. I also saw three 55-gallon containers that held ash from the burner as well as additional debris. According to Mr. Wilcox oil filters, rags, absorbent pads , and pig parts (Brushes) were burned using the smart ash burner. I asked about the burning of the pig brushes and Mr. Wilcox said the brushes were put in the smart ash burner to burn off the paraffin (Pig wax) from the pig brushes. Photo(s) 1. Observation_Image-20210428152608268716803.jpg 2. Observation_Image-202104281526192619386138.jpg 3. Observation_Image-202104281526362636582430.jpg Records Review There were no records at the facility to be reviewed. SECTION III - AREAS OF CONCERN The presentation of areas of concern does not constitute a formal compliance determination or violation. 3 of 6 HARVEST ALASKA - MIDSTREAM PIPELINE DIVISION - EAST FORELANDS Inspection Date(s): I observed no areas of concern at the time of the inspection. 04/28/2021 - 04/28/2021 SECTION IV - FOLLOW UP Building: Filter room JJ1-OB-002 Area: Sub-area: Following the inspection, I sent an email, dated 5/6/2021, to Mr. Hong. In that email I asked, "While at the facility, there were three smart ash burn barrels located in the storage building. All of the barrels held ash and solids. One barrel contained brushes from a pig and the contents of the barrel had a very strong odor, similar to a solvent or maybe petroleum based. Can you tell me when the last time pig wax was generated at the facility and how that waste was managed? Please provide any applicable disposal paperwork you have too. There were remnants of filters in the other barrels too. Can you tell me what the filters would have been contaminated with? I am including the photos taken so you can see what I'm referring to. Let me know if you have any questions." Mr. Hong responded in an email, dated 5/7/2021 with the following information: "OK, here is what I've found: Can you tell me when the last time pig wax was generated at the facility and how that waste was managed? o We have not received wax at this location for a long time (last 10 years). Can you tell me what the filters would have been contaminated with? o Motor Oil o Natural Gas Condensate Let me know if there is anything else we can provide! Kijun" 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. 4 of 6 HARVEST ALASKA - MIDSTREAM PIPELINE DIVISION - EAST FORELANDS Inspection Date(s): SECTION V - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS No sampling was conducted. SECTION VI - LIST OF APPENDICES Photo Log [Title] Observation_Image20210428152608268716803.jpg 04/28/2021 03:26 PM (AKT) Jon Jones Filter room No CBI No PII View inside of a 55-gallon drum that contains ash residue from burning oil filters, rags, absorbent pads , and pig parts in a smart ash burner. [Title] Observation_Image202104281526192619386138.jpg 04/28/2021 03:26 PM (AKT) Jon Jones Filter room No CBI No PII View inside of a second 55-gallon drum that contains ash residue from burning oil filters, rags, absorbent pads , and pig parts in a smart ash burner. 04/28/2021 - 04/28/2021 5 of 6 HARVEST ALASKA - MIDSTREAM PIPELINE DIVISION - EAST FORELANDS Inspection Date(s): [Title] Observation_Image202104281526362636582430.jpg 04/28/2021 03:26 PM (AKT) Jon Jones Filter room No CBI No PII View inside of a third 55-gallon drum that contains ash residue from burning oil filters, rags, absorbent pads , and pig parts in a smart ash burner. Brushes from a pig can be seen here on top of the ash pile. 04/28/2021 - 04/28/2021 Document Log Document Type Inspection Reports Communications Communications Document Name Contains Contains Uploaded By CBI PII Field_Notes_AKR000204230v1.0.pdf No No Jon Jones FW_ [EXTERNAL] April 28, 2021 No No Jon Jones RCRA inspection at the East Forelands facility.pdf RE_ [EXTERNAL] April 28, 2021 RCRA No No Jon Jones inspection at the East Forelands facilit.pdf Date Received 07/07/2021 07/07/2021 07/07/2021 6 of 6