Document VGB9R1ypvYXXVKKBXgZBgopQ8
f t E A ~ United States
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Environmental Protection
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Agency
EPA REGION 6 Enforcement Division INSPECTION REPORT
Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection
06/17/2025 09:15 AM (CT)
Announced: Yes
06/17/2025 10:32 AM (CT)
Access: Granted
RCRA
Compliance Evaluation Inspection (CEI)
Facility or Site Name Facility/Site Identifier Facility/Site Physical Address City, State, Zip Code County/Borough
Shamrock Products Victoria Terminal TXR000087028 1894 FM 1432 Victoria, TX 77905 Victoria
Generator Status Very Small Quantity Generator (VSQG)
NAICS
424720
Type of Operation Geographic Coordinates
Shamrock Products Victoria Terminal (Shamrock) is a bulk liquid storage terminal where trucks, and railcars transport petroleum products in and out of the facility. 2841'28.42"N, 9658'1.58"W
Additional Persons Participating in Inspection:
Name
Title
Organization
Andrew Swingler Contractor Eastern Research Group (ERG)
Email Andrew.Swingler@erg.com
Lead Inspector: Janosh Wolters
Janosh Wolters Digitally signed by Janosh Wolters Date: 2025.07.23 20:16:14-04'00'
Contractor Eastern Research Group Janosh.Wolters@erg.com (ERG)
Page 1 of 4
Shamrock Products
Inspection Date: 06/17/2025
SECTION I - INTRODUCTION
Site Entry and Purpose of the Inspection
The Port of Victoria and surrounding facilities were selected for inspection based on a 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, portrelated facilities, and other records, including photographs taken, verbal or written statements made during or after the on-site inspection, and/or materials shown, demonstrated, or submitted to the Environmental Protection Agency (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 CEO/Shamrock Products Vice President/Shamrock Products
Name Janosh Wolters Andrew Swingler Shane Steagall Steve Hernandez
Opening Conf. Closing Conf.
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Page 2 of 4
Shamrock Products
Inspection Date: 06/17/2025
Facility General Description
Tenant/Area Shamrock Products
Inspection Date
6/17/25
Process Description Shamrock is a bulk liquid storage terminal where trucks and railcars transport petroleum products in and out of the facility. The facility maintains a MARPOL Annex I and V COA.
Area of Concern
No
SECTION II - OBSERVATIONS
Facility: Shamrock Products
Section: 2.1
Date: 06/17/25, 09:15 AM Contains AOC: No Contains CBI: No
I
I
Lead Inspector: Janosh Wolters Attendees: Shane Steagall and Steve Hernandez
Shamrock, located in Victoria, TX, operates as a bulk liquid storage terminal where trucks and railcars transport petroleum products in and out of the facility.
The facility receives petroleum products via truck and railcar. Petroleum products are stored onsite in tanks prior to distribution to clients by rail. Shamrock pumps petroleum products from tanks into outgoing railcars and places secondary containment around the hoses during all transfers. Shamrock leases the property from the Port of Victoria. The Union Pacific Railroad operates the railcars and tracks onsite. Shamrock only generates hazardous waste when it cleans its storage tanks. Shamrock has not needed to clean out any tanks since beginning their operations in May 2023. Shamrock is registered with the EPA as a non-generator of hazardous waste under EPA ID TXR000087028, however, Mr. Steagall stated the facility updated Shamrock's generator status in March 2025 because Shamrock anticipates needing to clean their storage tanks soon. (see Appendix 2). Shamrock is still exploring what types of chemicals, if any, will be required for tank cleaning. (see Appendix 2).
After the opening conference, the inspection team observed Shamrock's tank storage areas. Shamrock has 16 tanks; 15 tanks have a 1,000-barrel storage capacity, and one decommissioned tank has a 400-barrel storage capacity. The inspection team observed one 55-gallon container of hazardous waste inside the tank farm. The container was closed, in good condition, and labeled. Mr. Steagall explained the waste was from a cleanup effort after an onsite slop oil spill in January 2024. The spill occurred when a transport truck struck a valve on one of the tanks, resulting in a spill of about 500 barrels of slop oil. The investigation is closed and no readings above background were observed. The inspection team did not observe other wastes being accumulated on site.
The inspection team did not observe any areas of concern (AOCs) at the time of the inspection. However, further EPA review may change or add to their potential AOCs. A closing conference was conducted at approximately 10:25 AM with Legacy personnel. Following the inspection on 6/17/2025, Mr. Steagall sent a follow-up email providing Shamrock's Texas Commission on Environmental Equality Notice of Registration (see Appendix 2).
Page 3 of 4
Shamrock Products
Inspection Date: 06/17/2025
SECTION III - RECORDS REVIEW No RCRA-regulated records were reviewed during this focused on-site inspection.
SECTION IV - AREAS OF CONCERN No AOCs were identified at the time of the inspection.
SECTION V - 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 the provision of documents requested. Communication Log
24 hours prior to the on-site inspection, Erin Young-Dahl (EPA Region 6) notified the facility that ERG would be performing a CEI at Shamrock.
During the inspection, Mr. Wolters requested the following documents:
1. EPA ID notification (if previously obtained)
2. Texas ID notification
Shamrock responded to the request and provided the Texas Commission on Environmental Equality Notice of Registration. VSQGs of hazardous waste do not need to obtain EPA ID numbers because they are exempt from the notification requirements in the Resource Conservation and Recovery Act (RCRA) section 3010 (40 CFR section 262.14).
SECTION VI - LIST OF APPENDICES Appendix 1. Photograph Log Appendix 2. 6/18/2025 Response from Shamrock Products
Page 4 of 4
APPENDIX 1. PHOTOGRAPH LOG
I
Location: Shamrock Products Victoria Terminal
City: Victoria
County/Parish: Victoria
I
State: Texas
,-
Photo No. 1
Photo File Name: DSCN8764 Date of Photo: 6 /17/2025 Time of Photo: 1012 hrs. Photographer: Janosh Wolters Description: Petroleum products storage tanks.
Location: Shamrock Products Victoria Terminal
City: Victoria
County/Parish: Victoria
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State: Texas
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Photo No. 2
Photo File Name: DSCN8765 Date of Photo: 6/17/2025 Time of Photo: 1013 hrs. Photographer: Janosh Wolters Description: View of the fence line and how railcars enter the facility.
APPENDIX 2. 06/17/2025 RESPONSE FROM SHAMROCK PRODUCTS
Outlook
RE: Follow-up from EPA Inspection on 6/17/2025
From Shane Steagall <shane@shamrockproductsusa.com> Date Tue 6/17/2025 10:27 PM To Janosh Wolters <janosh.wolters@erg.com>; Steve Hernandez <steve@shamrockproductsusa.com> Cc Andrew Swingler <Andrew.Swingler@erg.com>
@1 attachment (24 KB)
IHW_NOR_FACREG99113.PDF;
CAUTION : Don't open links or attachments unless you recognize the sender and know they are safe.
Janosh - it was our pleasure, and thanks for the communication on coordinating the meeting. I hope your travels were better today than yesterday!
I've attached the information that I have. I will ask our consultant to see where our EPA ID document came from. I'll be in touch in the coming days.
Feel free to reach out anytime if you need anything further.
Best regards,
Shane
Shane Steagall
Shamrock Products, LLC, President (832) 427-9251 1110 NASA Parkway, Suite 460 Houston, Tx 77058 http://www.Shamrockproductsusa.com
<3shc!mt,PT~
From: Janosh Wolters <janosh.wolters@erg.com> Sent: Tuesday, June 17, 2025 6:37 PM To: Shane Steagall <shane@shamrockproductsusa.com>; Steve Hernandez <steve@shamrockproductsusa.com> Cc: Andrew Swingler <Andrew.Swingler@erg.com> Subject: Follow-up from EPA Inspection on 6/17/2025
Hi Shane,
I am following up with a list of items and notes from our inspection today. Below is my document request: EPA ID notification listing Shamrock as a VSQG Texas ID notification
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.
Thanks, Janosh
Janosh Wolters I ERG
484-678-8675 (cell) WWW.ERG .com Please send any CUI or sensitive information to my ERG email account at janosh.wolters@~_rgvault.com.
99113
*** TEXAS COMMISSION ON ENVIRONMENTAL QUALITY***
Notice of Registration Industrial and Hazardous Waste
SHAMROCK PRODUCTS VICTORIA TERMINAL
Page: 1 Date: 04/04/2025
Solid Waste Registration Number: 99113
EPA Id: TXR000087028
Company Name: Site Name:
Site Location: Primary Contact:
Mailing Address:
Shamrock Products, LLC SHAMROCK PRODUCTS VICTORIA TERMINAL
STEAGALL, DAVID 1110 NASA PKWY STE 460
HOUSTON, TX 77058-3346
Registration Status: Registration Type: Generator Type: Receiver Type: Transporter Type:
Transport Wst Class:
Active Generator Industrial
Universal Waste Activity: Large Quantity Handler of Universal Waste (you accumulate 5,000 kg or more): Type(s) Managed: Destination Facility for Universal Waste:
NAICS Code: Tax Identification #:
Handler Status:
424710 Petroleum Bulk Stations and Terminals 32064547865
Region: 14 County: 235 VICTORIA Land Type: Private
Title: PRESIDENT
Site Street Address: 1894 FM 1432
Initial Registration Date: Last Amendment Date:
Last Date NOR Computer update: Phone:
03/21/2025 03/21/2025 04/03/2025 281-984-7016
VICTORIA, TX 77905
Reporting Method: PAPER
Hazardous Waste Generation Status: Conditionally Exempt Small Quantity Generator
Operator Information
Name: Phone: Address:
Shamrock Products, LLC 281-984-7016 1110 NASA PKWY STE 460 HOUSTON, TX 77058-3346
Owner Information:
Name: Phone: Address:
Shamrock Products, LLC 281-984-7016 1110 NASA PKWY STE 460 HOUSTON, TX 77058-3346
Other Contact: Manager, Environmental Mailing Address: 1110 NASA PKWY STE 460
HOUSTON, TX 77058-3346
As of 03/21/2025 -
The next unassigned sequence number for WASTES is 0002 and The next unassigned sequence number for UNITS is 002
Role: IHW: Owner Contact
Phone:
281-984-7016
99113
*** TEXAS COMMISSION ON ENVIRONMENTAL QUALITY***
Notice of Registration Industrial and Hazardous Waste
SHAMROCK PRODUCTS VICTORIA TERMINAL
Page: 2 Date: 04/04/2025
**** WASTE INFORMATION ****
Texas Waste Code
Waste Class
Status
Date of Status
Managed Onsite/ Offsite
Radioactive
TCEQ Audit Complete
****** Active Wastes ******
00012191
1
Active 03/21/2025 Off-site
No
No
Description from Generator:
Texas Form Code: Origin Code:
Current Management Units:
OILY WATER, SEDIMENTS AND SLUDGE CONTAINING HYDROCARBONS CAN BE GENERATED FROM FILLING AND EMPTYING THE TANKS, ROUTINE MAINTENANCES, AND/OR TANK CLEANING PROCESS. SPENT FILTERS AND OILY RAGS CAN ALSO BE GENERATED FROM MAINTENANCES, INSPECTIONS, AND CLEANING PROCESS. 219 Other organic liquids 1 Generated on-site from a product process or service activity
None
As of 03/21/2025, The next unassigned sequence number for WASTES is 0002
**** UNITS AT THIS SITE MANAGING WASTE ****
Unit Number
Unit Type
Unit Status
Date of Status
Classes of Waste Managed in Unit Onsite / Offsite
Unit Permit Number
Unit # on
Permit
Regulatory Status
Deed Recording Needed/Date
001
Container storage area
ACTIVE
03/21/2025
NA / NA
NA
Description from Company: System Types:
CENTRAL WASTE MANAGEMENT AREA 141 Storage, bulking, and/or transfer off site -no treatment/recovery, fuel blending or disposal at this site.
As of 03/21/2025, The next unassigned sequence number for UNITS is 002
NA 13 RCRA Pmt Exempt Accumulation Time
YES /