Document XOR9jjmjE8g8xpoGr10qMp5m4
Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection
EPA REGION 6 Enforcement Division
INSPECTION REPORT
03/14/2024 08:30 (CT)
Announced: No
03/14/2024 11:40 (CT)
Access: Granted
RCRA
Focused Compliance Inspection (FCI)
Facility or Site Name Facility/Site Identifier Facility/Site Physical Address City, State, Zip Code County/Borough Generator Status NAICS Type of Operation
Geographic Coordinates
Valero Bill Greehey Refineries East TXD008132268 1147 Cantwell Ln Corpus Christi, TX 78407 Nueces County Large Quantity Generator (LQG) 32411 Valero Bill Greehey Refineries operates as a refinery producing several products including gasoline, jet fuel, diesel, asphalt, and other petrochemicals. 27.820277, -97.435
Additional Persons Participating in Inspection:
Name
Title
Organization
Joyce Johnson
Inspector
EPA REGION 6
Erin Young-Dahl
Inspector
EPA REGION 6
Andrew Gates
Contractor
Eastern Research Group (ERG)
Email Johnson.Joyce@epa.gov YoungDahl.Erin@epa.gov Andrew.Gates@erg.com
Lead Inspector: Vince Damiano
ERG
Vincent Damiano
Digitally signed by Vincent Damiano Date: 2024.07.11 18:53:46 -04'00'
Vince.Damiano@erg.com
Phone (214) 665-8548 (214) 665-3166 (657) 206-7829
07/11/2024 (703) 633-1732
Page 1 of 6
Valero Bill Greehey Refineries East
Inspection Date: 03/14/2024
SECTION I - INTRODUCTION
Site Entry and Purpose of the Inspection
The Port of Corpus Christi and surrounding facilities were selected for inspection based on an Environmental Justice and 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, port related facilities, and records including photographs taken (see Appendix 1), verbal or written statements made during or after the on-site inspection, and/or materials shown, demonstrated, or submitted to the 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 Inspector/Enforcement Officer/EPA Region 6 Inspector/Enforcement Officer/EPA Region 6
Name Vince Damiano
Phone
Email
(703) 633-1732 Vince.Damiano@erg.com
Opening Conf.
Yes
Closing Conf.
Yes
Andrew Gates (657) 206-7829 Andrew.Gates@erg.com Yes
Yes
Joyce Johnson (214) 665-8548 Johnson.Joyce@epa.gov Yes
Yes
Erin Young-Dahl (214) 665-3166 YoungDahl.Erin@epa.gov Yes
Yes
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Valero Bill Greehey Refineries East
Inspection Date: 03/14/2024
Facility General Description
Tenant/Area Valero Bill Greehey Refineries East
Inspection Date
03/14/24
Process Description Valero Bill Greehey Refineries (Valero) operates as a refinery producing several products including gasoline, jet fuel, diesel, asphalt, and other petrochemicals. Valero receives raw material primarily via ship, but also by pipeline. Refined products go out via ship, barge, truck, and pipeline.
Area of Concern
Yes
The facility maintains a MARPOL COA for Annex I, II, and V but does not receive waste from vessels.
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Valero Bill Greehey Refineries East SECTION II - OBSERVATIONS
Inspection Date: 03/14/2024
Tenant: Valero Bill Greehey Refineries (East)
Section: 2.1
Date: 03/14/24, 8:30 AM Contains AOC: Yes Contains CBI: No
Lead Inspector: Vince Damiano Attendees: Joe Almaraz (HSE Director), Meagan Marguard (PSM Manager), Marin Maldonado (Environmental Engineer), Faren VonDuben (Environmental Engineer), Kelli Coates (Complex Manager), Marco Rocha (Environmental Tech)
Valero is located along the Port of Corpus Christi shipping channel and operates as a refinery for fuel oils and petrochemicals. Materials are moved via pipeline, barges, ships, and sometimes trucks. Valero operates on five public docks owned by the Port of Corpus Christi. Valero maintains a MARPOL COA for Annex I, II, and V from the USCG and operates as a LQG of hazardous waste (EPA ID TXD00813268). Valero personnel stated they do not accept waste from ships across their docks and are unaware of any ship-to-ship transfers of waste occurring at their dock spaces.
During the inspection, the inspection team observed Valero's dock spaces. At each dock, there is a rainwater collection sump that collects rainwater and any other liquid material that may end up in the sump. The material is pumped back to Valero's wastewater treatment plant where it is treated. The inspection team arrived at Oil Dock #6 where a yellow trashcan was found storing a mix of aerosol cans and hydrocarbon contaminated waste debris (see Appendix 1 - Photos 1 through 3). The facility stated that that drum is designated for hydrocarbon waste debris only. The drum was found to be unlabeled and storing unpunctured aerosol cans. [AOC #1 - Valero did not clearly label its containers as "Hazardous Waste" and indicate the hazardous contents - 40 CFR 262.15 (a)(5)]
The inspection team did not observe other apparent AOCs at the time of the inspection. A closing conference was conducted at approximately 11:30 PM with Valero personnel. The AOC was communicated during the closing. On 03/15/2024, Valero personnel followed up with an email stating the aerosol cans have been removed from the oily trash and transported to the puncture station. A new SAA was set up at Oil Dock #6 for aerosol can management with proper labeling (see Appendix 2).
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Valero Bill Greehey Refineries East SECTION III - RECORDS REVIEW
Inspection Date: 03/14/2024
No RCRA-regulated records were reviewed during this focused onsite inspection.
SECTION IV - AREAS OF CONCERN
The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation. Tenant: Valero Bill Greehey Refineries (East)
AOC #1 - Valero did not clearly label its containers as "Hazardous Waste" or indicate the hazardous contents.
Citation: 40 CFR 262.15 (a)(5)
Section: 2.1
SECTION V - FOLLOW UP
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 provision of documents requested.
Communication Log
During and after the inspection, additional information was emailed to EPA including: 1. 03/15/24 Valero email - Faren Von Duben sent an email with their response and corrections made to the AOC noted during the inspection.
Page 5 of 6
Valero Bill Greehey Refineries East
SECTION VI - LIST OF APPENDICES Appendix 1. Photograph Log Appendix 2. Valero Response 03/15/24
Inspection Date: 03/14/2024
Page 6 of 6
APPENDIX 1. PHOTOGRAPH LOG
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 1
Location: Valero Bill Greehey Refineries East
City: Corpus Christi
County/Parish: Nueces
State: Texas
Photo File Name: DSCN7157 Date of Photo: 03/14/2024 Time of Photo: 09:29 hrs. Photographer: Vince Damiano Description: View of unlabeled drum designated for oil rags containing an unpunctured aerosol can at Oil Dock 6.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 2
Location: Valero Bill Greehey Refineries East
City: Corpus Christi
County/Parish: Nueces
State: Texas
Photo File Name: DSCN7158 Date of Photo: 03/14/2024 Time of Photo: 09:29 hrs. Photographer: Vince Damiano Description: View of an unlabeled drum designated for oil rags containing an unpunctured aerosol can at Oil Dock 6.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 3
Location: Valero Bill Greehey Refineries East
City: Corpus Christi
County/Parish: Nueces
State: Texas
Photo File Name: DSCN7159 Date of Photo: 03/14/2024 Time of Photo: 09:29 hrs. Photographer: Vince Damiano Description: View of an unlabeled drum designated for oil rags containing an unpunctured aerosol can at Oil Dock 6.
APPENDIX 2. VALERO RESPONSE 03/15/24
RE: Follow-up from EPA Visit 3/14/2024
Von Duben, Faren <Faren.VonDuben@valero.com>
Fri 3/15/2024 2:32 PM To:Vince Damiano <Vince.Damiano@erg.com>;Almaraz, Joe <Joe.Almaraz@valero.com>;Marquard, Meagan <Meagan.Marquard@valero.com>;Maldonado, Marin <Marin.Maldonado@valero.com>;Coates, Kelli <Kelli.Coates@valero.com>;Almaraz, Aimee <Aimee.Almaraz@valero.com> Cc:Andrew Gates <andrew.gates@erg.com>;Johnson, Joyce-R6 <johnson.joyce-r6@epa.gov>;Young-Dahl, Erin <YoungDahl.Erin@epa.gov>
1 attachments (253 KB) Valero CC Follow-up EPA Inspection on 3-14-24.pdf;
CAUTION: Don't open links or attachments unless you recognize the sender and know they are safe.
Hello Vince,
Attached is the follow up from the RCRA inspection on 3/14/2024 at Valero Corpus Christi East Plant Docks as referenced in the email below.
Please let us know if you have any questions, comments, or concerns.
Thank you,
Faren Von Duben
Sr Environmental Engineer Valero - Bill Greehey Refineries Office: 361-887-4169 Mobile: 956-454-2517
From: Vince Damiano <Vince.Damiano@erg.com> Sent: Thursday, March 14, 2024 5:19 PM To: Almaraz, Joe <Joe.Almaraz@valero.com>; Meagan.marguard@valero.com; Marin.maldonado@valeo.com; Von Duben, Faren <Faren.VonDuben@valero.com>; Coates, Kelli <Kelli.Coates@valero.com> Cc: Andrew Gates <andrew.gates@erg.com>; Johnson, Joyce-R6 <johnson.joyce-r6@epa.gov>; Young-Dahl, Erin <YoungDahl.Erin@epa.gov> Subject: Follow-up from EPA Visit 3/14/2024
Hello Joe,
I am following up with a list of items and notes from our inspection today. Below are initial Areas of Concern and items requested:
Follow-up drum found in Oil Dock 6 designated for oily rags but had aerosol cans in it.
Again, 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. Any follow-up can be sent to myself and the persons attached.
Thanks, Vince
Appendix 2 Page 1 of 3
Vince Damiano
Chemical Engineer, Chantilly Office Cell: (570) 956-1468 Vince.Damiano@erg.com
Appendix 2 Page 2 of 3
Valero Corpus Christi Refinery - East Plant EPA RCRA Inspection on March 14, 2024
Areas of Concern Response Area of Concern and Items Requested: Follow-up drum found in Oil Dock 6 designated for oily rags but had aerosol cans in it. Valero's Follow-Up (3/15/2024): On 3/14/2024, aerosol cans that were found in the yellow oily trash bin were separated from the oily trash and transported to the puncture station to safely puncture, drain, and recycle the puncture aerosol cans. A new satellite accumulation area (SAA) was set up at Oil Dock 6 for aerosol can management. A 55-gallon drum with a latching lid was placed in the SAA, with a yellow hazardous waste label, to store the emptied aerosol cans. The photo below shows the completed follow up.
Appendix 2 Page 3 of 3