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Region 6 Compliance Assurance and Enforcement Division
INSPECTION REPORT
Inspection Date(s): Media: Regulatory Program(s)
June 12- 15, 2017 Waste RCRA
Company Name: Facility Name: Facility Physical location:
(city, state, zip code) Mailing address:
(city, state, zip code) County/Parish: Facility Contact:
Chemical Process and Production Chemical Process and Production (CPP) 15133 Linda lane Santa Fe, Texas 77020
P. 0. Box 1515
Santa Fe, Texas 77510
Greg Ploss GPlOSS@AOl.COM
I President/Environmental Manager
FRS Number: Identification/Permit Number: Media Number: NAICS: SIC:
TXD095185807
32411 (Petroleum Refineries) 2911 (Petroleum Refineries}
Personnel participat ing in inspection:
EPA RCRA Enforcement
Adolphus Talton
Branch (6EN-H1)
EPA RCRA Enforcement
David Robertson
Branch (6EN-H1)
EPA RCRA Enforcement
Angela Hays
Branch (6EN-H1)
Gregg Ploss
CPP
Eddie lewis
Norton Rose Fulbright
Mike landers
CPP
Walt lnkofer, P.E.
CPP
Stephanie Porter
CPP
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EPA Enforcement Officer Signature/Date
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{tn"forcement officer}
Enforcement Officer
lead Inspector
Inspection Team member President/Environ Mgr Attorney for CPP lab Supervisor/Chemist Chemical Engineer Secretary
(214} 665-6651
(214) 665-7363
(214) 665-2285 (409) 925-1676 (713) 651-3760 (409) 925-1676 (409} 925-1676 (409} 925-1676
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Date
Supervisor Signature/Date
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Date
6ENFORM-019-R7 (2/15/2017)
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Section 1- INTRODUCTION
Chemical Process and Production 06/12-16/2017
On June 12,2017, a Compliance Evaluation Inspection covering Resource Conservation and Recovery Act (RCRA) regulations was initiated at Chemical Process and Production (CPP) located at 15133 Linda Lane, Santa Fe, Texas. The inspection was conducted under the authority of RCRA Section 3007(a), as amended.
The inspection team was led by Mr. David Robertson, accompanied by Mr. Adolphus Talton, Enforcement Officer, and Ms. Angela Hays, Inspection team member. The team arrived at the facility on the morning of June 12, 2017. The EPA Representatives presented their credentials and explained the purpose of the visit to Ms. Stephanie Porter, Secretary, Mr. Walt lnkofer, P.E., Chemical Engineer; Mr. Mike landers, Lab Supervisor & Chemist; Mr. Greg Ploss, President/Environmental Manager; and Mr. Eddie Lewis, Attorney for Norton Rose Fulbright US LLP via conference call. CPP provided an overview of the facility's processes and EPA Representatives were informed that normal operations were currently shutdown. Mr. Ploss is responsible for all waste management activities at the CPP facility.
PURPOSE OF THE INSPECTION
The main focus of the inspection was to determine complia nee with applicable hazardous waste regulations. The facility notified as a Small Quantity Generator (SQG) of Hazardous Waste, generating greater than 100 kg (220 lbs) but less than 1,000 kg (2,204 lbs) of hazardous waste per calendar month.
FACILITY DESCRIPTION
CPP was founded in 1972. In the beginning, the facility operated as a petroleum refinery that sat on approximately 15-acres. CPP started as a hydrocarbon tolling facility recovering dichlorbutenes and diisobutylene. CPP currently is a manufacturing plant which processes specialty hydrocarbon feed stock. They have approximately 20 employees and operate 24 hours a day, seven days a week.
CPP has two primary processes (Unit Nos. 2, and 3} that separate various products from feedstock
materials. The feedstock is received from multiple companies (See Appendix 23- Bills of lading). Some
of the feedstocks processed are iso-octane, mineral oil, hexane/toluene mixtures, and hexane/lube oil mixtures. Each process operates in a similar manner, in that the feedstock stream is pre-heated with heat exchangers before it enters distillation tower(s) operating with steam-heated reboiler(s), which separates the higher boiling point component stream (termed "bottom product") from the lower boiling point component stream (termed "overhead product"}. Each process can operate in vacuum mode. The 10.0425 MMBTU/hr boiler combusts primarily natural gas but can combust fuel oil for up to 48 hr/yr to produce stream which is used in the process reboilers and heaters. The products manufactured via distillation include hexane, octane, diisobutylene, cyclohexanol, C6-C12 hydrocarbons, and lube oil. All materials are trucked in and out of the plant.
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