Document QgJBMX9XGGjz8VERpN7Bo5B5v

March 21, 2025 SENT BY ELECTRONIC MAIL Austin.Taylor@enbridge.com Austin Taylor Environmental Manager Enbridge Ingleside Oil Terminal 1450 Lexington Blvd. Bldg 300 Ingleside, TX 78362 Re: Notice Letter Resource Conservation and Recovery Act Enbridge Ingleside Oil Terminal; EPA ID: TX170099915 Dear Mr. Taylor, Hazardous waste that is improperly managed poses a serious threat to human health and the environment. Through implementation of the authorities in the Resource Conservation and Recovery Act (RCRA), 42 U.S.C. 6901 - 6992k, the United States Environmental Protection Agency (EPA) regulates hazardous waste activities from the "cradle-to-grave." This includes the generation, transportation, treatment, storage and disposal of hazardous waste. On March 13, 2024, EPA, Region 6 conducted an inspection of Enbridge Ingleside Oil Terminal ("Enbridge") facility located in Ingleside, TX. The purpose of the inspection was to determine Enbridge's compliance with the requirements of RCRA, and the implementing regulations. The information currently available to EPA, collected as a result of the inspection, suggests that Enbridge may be in violation of RCRA. RCRA Violations By this letter, EPA is extending Enbridge the opportunity to advise EPA, in person, via a conference call, or in writing, of any further information EPA should consider with respect to the following potential violations of RCRA and the implementing regulations:1 Violations: 1. Used Oil Storage - Failure to clearly label containers used to store used oil with the words "Used Oil," pursuant to 30 Tex. Admin. Code 324.1, adopting by reference 40 C.F.R. 279.22(c)(1) (Lab Storage Area). 2. Waste Management - Failure to store universal waste lamps in a container or package that was structurally sound and able to prevent breakage, pursuant to 30 Tex. Admin. Code 335.261, adopting by reference 40 C.F.R. 273.13(d)(1) (Waste Building). 3. Labeling/Marking - Failure to label boxes of stored universal waste lamps with the words "Universal Waste - Lamp(s)," or "Waste Lamp(s)," or "Used Lamp(s)," pursuant to 30 Tex. Admin. Code 335.261, adopting by reference 40 C.F.R. 273.14(e) (Waste Building) 4. Accumulation Time Limits - Failure to label boxes of universal waste with accumulation date, pursuant to 30 Tex. Admin. Code 335.261, adopting by reference 40 C.F.R. 273.15(c). (Waste Building) 5. Used Oil Storage - Failure to clearly label containers used to store used oil with the words "Used Oil," pursuant to 30 Tex. Admin. Code 324.1 referencing 40 C.F.R. 279.22(c)(1). (Waste Building) 6. Used Oil Storage - Failure to properly manage and cleanup used oil released, pursuant to 30 Tex. Admin. Code 324.1, adopting by reference 40 C.F.R. 279.22(d)(3). (Waste Building) 7. Hazardous Waste Determination - Failure to make a hazardous waste determination on solid wastes material, pursuant to 30 Tex. Admin. Code 335.62, [40 C.F.R. 262.11]. (Waste Building). 8. Containment Systems and Secondary Containment - Failure to comply with secondary containment requirements, pursuant to 30 Tex. Admin. Code 335.12(a)(7), adopting by reference 40 C.F.R. 264.175. (Waste Building). 1 On December 26, 1984, the State of Texas received final authorization for its base Hazardous Waste Management Program (49 Fed. Reg. 48300). Subsequent revisions have been made to the Texas Hazardous Waste Program and authorized by EPA. Except as otherwise provided, all citations found within this Notice Letter are to the "EPAApproved Texas Statutory and Regulatory Requirements Applicable to the Hazardous Waste Management Program" dated March 2021, incorporated by reference under 40 C.F.R. 272.2201(c)(1)(i) (86 Fed. Reg. 12834: Texas StateAdministered Program: Final Authorization). References and citations to the "EPA-Approved Texas Statutory and Regulatory Requirements Applicable to the Hazardous Waste Management Program" may vary slightly from the State of Texas's published version. For ease of reference, the corresponding C.F.R. citations will follow in brackets. Please review the additional information we have provided in the Enclosure. Opportunity to Confer This Notice provides you with the opportunity to confer with EPA within 10 business days of receipt of this Notice, with respect to the above listed alleged violations.We request Enbridge contact Ravi Sharma, Assistant Regional Counsel, at sharma.ravi@epa.gov or (214) 665-6719. Sincerely, JEFFREY YURK Digitally signed by JEFFREY YURK Date: 2025.03.21 09:25:49 -05'00' Jeff Yurk, Manager Waste and Chemical Enforcement Branch Enclosure: Additional Sources of Information ADDITIONAL SOURCES OF INFORMATION 1. Information on RCRA and hazardous waste regulations https://www.epa.gov/rcra/resource-conservation-and-recovery-act-rcra-regulations 2. RCRA Civil Penalty Policy https://www.epa.gov/enforcement/resource-conservation-and-recovery-act-rcra-civilpenalty-policy 3. Consolidated Rules of Practice Governing the Administrative Assessment of Civil Penalties, 40 C.F.R. Part 22 https://www.epa.gov/sites/production/files/2013-10/documents/final-crop-fr_1.pdf 4. Small Business Fact Sheet www.epa.gov/compliance/small-business-resources-information-sheet