Document XZE06k6ZaE2zj2eamEqoN4qK

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY, REGION 2 CARIBBEAN ENVIRONMENTAL PROTECTION DIVISION MULTIMEDIA PERMITS AND COMPLIANCE BRANCH Industrial Facility NPDES Compliance Evaluation Inspection Commonwealth Oil Refining Company Firm Delivery, 600 Road 127, Peuelas Puerto Rico 00624-7501 State Road No. 127, Km. 17.3, Tallaboa Poniente Ward Peuelas, Puerto Rico 00624 Coordinates:18 00' 23.05" N; - 66 44' 21.82" W Telephone Number: (787) 836-1350 Sections 301(a), 308(a) and 402 of the Clean Water Act NPDES Regulations: 40 C.F.R. 122 NPDES Permit Number PR0000345 Inspection Date: June 7, 2023 Participating Personnel: U.S. EPA: Yolianne Maclay, P.E. Senior Environmental Engineer Clean Water Act Team Commonwealth Oil Refining Company: Mr. Rodolfo Seda, E, H & S Manager rodolfo.seda@corcopr.com Inspection Report Prepared by: Inspection Report Approving Officer: Ms. Cynthia Martnez, E, H & S Coordinator Cynthia.martinez@corcpr.com YOLIANNE Digitally signed by YOLIANNE MACLAY MACLAY Date: 2023.07.03 13:57:03 ____________________-_04_'00'______________ Yolianne Maclay, P.E. Date Senior Environmental Engineer Clean Water Act Team Email: maclay.yolianne@epa.gov Tel.: 787.977.5849 Digitally signed by NANCY NANCY RODRIGUEZ _______________________ ____R_O_D__R_IG_U_E_Z__ Jos A. Rivera, BSCE DatDe:a2te023.07.06 06:50:07 -04'00' Lead Environmental Engineer Clean Water Act Team Tel. (787) 977-5842; Email: rivera.jose@epa.gov NPDES Compliance Evaluation Inspection 1. INTRODUCTION On June 7, 2023, Yolianne Maclay, Senior Environmental Engineer (the "EPA Inspector"), of the United States Environmental Protection Agency ("EPA"), Region 2, Caribbean Environmental Protection Division ("CEPD"), conducted a National Pollutant Discharge Elimination System ("NPDES") Compliance Evaluation Inspection (the "Inspection") at the Commonwealth Oil Refining Company ("CORCO" or the "Permittee") located at State Road No. 127, Km. 17.3, Tallaboa Poniente Ward, Peuelas, Puerto Rico (the "Facility"). This Inspection Report includes findings and observations concerning the Inspection. The purpose of the Inspection was to evaluate CORCO's compliance with its NPDES Permit Number PR0000345 (the "Permit"). Upon showing of credentials to Mr. Rodolfo Seda, E, H & S Manager, and Ms. Cynthia Martnez, E, H, & S Coordinator, the EPA Inspector obtained access to the Facility, and performed the Inspection under the authority in Section 308(a) of the Federal Water Pollution Control Act ("CWA" or the "Act"). The Inspection consisted of an entry meeting to discuss the purpose of the Inspection and to request information regarding the Facility, a walkthrough of the Facility to evaluate operational and maintenance conditions, a records review, and a closing meeting to discuss areas of concern. 2. GENERAL INFORMATION a. Date and Time of the Inspection - The Inspection was conducted on Wednesday, June 7, 2023. The Inspection began approximately at 9:00 a.m. and ended approximately at 1:00 p.m. b. Weather - Dry weather and sunny skies prevailed during the Inspection. c. Facility's Representative: Mr. Rodolfo Seda, E, H & S Manager, Tel: (787) 836-1350, email: rodolfo.seda@corcopr.com Ms. Cynthia Martnez, E, H & S Coordinator, Tel: (787) 836-1350 ext..243, email: cynthia.martinez@corcpr.com 3. INFORMATION CONCERNING THE FACILITY AND ITS NPDES PERMIT Description of the Facility CORCO was a refinery that has been inactive since 1982, and now functions as a terminal for the marine transportation and land-based storage of crude oil and petroleum products. Currently, CORCO owns and/or operates a petroleum bulk leasing facility located in Peuelas, Puerto Rico. Petroleum commodities are brought into the Facility by pipelines from marine vessels through its marine terminal. These commodities are subsequently shipped out by marine vessels through the marine terminal, by tank trucks through a truck loading rack, and by pipelines into nearby client facilities. The Facility estimated area of industrial activity exposed to stormwater is 338-acres and consists of numerous storage tanks and oil water separator units typical of petroleum refineries. Commonwealth Oil Refining Company Inspection Report Page 2 of 10 NPDES Compliance Evaluation Inspection The operations at the Facility are best described by the Standard Industrial Classification ("SIC") code 4226. The SIC code 5171 identifies entities engaged in Petroleum Bulk Storage Terminal and Warehousing. CORCO has identify SIC 2911 as their co-located industrial activity related to Former Refinery. Image 1 below depicts an aerial photograph of the Facility and its surroundings. Tallaboa Bay Source: Google Earth ProTM, March 2023 Storm Water Collection and Discharge System The Facility storm water collection and discharge system consist of concrete line pipes, channels, and culverts that convey storm water run-off from the tank farms secondary containments and other industrial areas of the Facility through four (4) Oil Trap Boxes. Stormwater is discharge through Outfall 003, which in turn conveys the runoff into the Tallaboa Bay, a water of the United States. Former Outfall 002 was diverted into Outfall 003 and now conveys stormwater runoff into Commonwealth Oil Refining Company Inspection Report Page 3 of 10 NPDES Compliance Evaluation Inspection the effluent channel of Outfall 003. Outfall 001 will be discharging treated wastewaters from the Wastewater Treatment Plant ("WWTP"), that is currently under construction. Image 2 below depicts the NPDES Discharge Points 001, 002, and 003. Source: CORCO's Storm Water Pollution Prevention Plan, dated December 21, 2020 NPDES Permit The Permit was issued to CORCO on July 2, 2019, the effective date of the Permit is August 1, 2019 and expires on July 31, 2024. The Permit authorizes the discharge of treated wastewater coming from its operations and Kuwait waters1 through Outfall 001 and discharges composed entirely of storm water through Outfalls 002 and 003 into Tallaboa Bay. Part II.A of the Permit includes effluent limitations and monitoring requirements for discharges coming from Outfall 001 and Part II.B of the Permit includes effluent limitations and monitoring requirements for discharges coming from Outfalls 002 and 003. The Permit refers to Outfall 002 and 003, but the entire stormwater runoff eventually flows through Outfall 003, which is the outfall been monitored. 1 Refer to Part II.A of the Permit for a description of the operations that generate wastewater and the definition of Kuwait water. Commonwealth Oil Refining Company Inspection Report Page 4 of 10 NPDES Compliance Evaluation Inspection Part III.A.2 of the Permit establishes the monitoring data submission requirements (i.e., hard copy form and NetDMR) and the timing of submission of monitoring data. Part IV.B.2 of the Permit establishes the requirements for implementation and revisions concerning the Storm Water Pollution Prevention Plan (SWPP Plan) and Best Management Practices and Pollution Prevention (BMP Plan). 4. ENTRY MEETING Upon entry to the Facility, the EPA Inspector met with Mr. Rodolfo Seda and Ms. Cynthia Martnez and held the entry meeting from 9:15 am to 9:35 am. The EPA Inspector stated that the purpose of the Inspection was to determine CORCO's compliance with the Permit. During the meeting, Mr. Seda indicated that the WWTP was under construction and up to the date of the Inspection it has not discharged. The EPA Inspector requested the following documents for review: the Permit, SWPP Plan, Calibration Records, Storm Water Pollution Prevention Plan ("SWPP Plan") Site Map, Facility Routine Inspections, and the Discharge Monitoring Reports (DMRs) from February 2020 to present, which were provided. The EPA Inspector reviewed NPDES Permit and the Site Map. The purpose of the review was for the EPA Inspector to further prepare for the performance of the Inspection walkthrough. 5. FACILITY WALKTHROUGH Upon completion of the entry meeting, the EPA Inspector and Mr. Seda conducted a walkthrough of the Facility from 9:45 am to 12:15 pm. The EPA Inspector observed the following: a. The WWTP was not in operation during the Inspection. The expected date for completion of the WWTP start-up process is June 15, 2023. b. Fuel stains were observed at the floor around the diesel pump station and absorbing material was place over the pipe connected to the pump. Mr. Seda explained that the pipe was leaking, and it was referred for maintenance and repair. Refer to Pictures 2 and 3. c. A water discharge was observed at the north side of the Facility from a PVC Pipe into a concrete stormwater channel. Mr. Seda explained that geological studies were conducted to identify the origin of this discharge and concluded that it was ground water from underneath Tank 1021. The groundwater discharge into the concrete stormwater channel has not been sampled. The color of the water was clear, and no odors were perceived. Refer to Picture 5. d. A second discharge was observed flowing over the concrete channel. This second discharge was coming from the secondary containment of Tank 1014 that was been discharged into the channel. Sediments were observed in the water accumulated at the secondary containment of tank 1014. Refer to Pictures 5 to 8. Commonwealth Oil Refining Company Inspection Report Page 5 of 10 NPDES Compliance Evaluation Inspection e. Oil Trap Boxes - Sediment, oil sheens and waste were observed at the oil traps boxes. a. Oil Trap Box #1 located in between tanks 903 and 950. Sediment was observed accumulated at the bottom of the tank and waste was observed floating at the water surface including plastic bottles, foam cups, and leaves. Refer to Picture #14. b. Oil Trap Box #2 - Fuel residues, oil sheens and waste (like foam cups and water bottles) were observed floating at the water surface. Sediment was observed accumulated at the bottom of the tank reaching above the water surface. Fuel odors were perceived. Refer to Pictures 15 and 16. c. Oil Trap Box #3. - Oil sheens and waste (like water bottles, foam cups and plates) were observed floating over the water surface. The water had a dark green color. Refer to Pictures 17 and 18. d. Oil Trap Box #4, - Sediments were observed, the water was turbid, and had a dark green color. Refer to Pictures 29 and 30. f. Outfall 003 flow meter reading showed a value of -2353.49 gpm. Mr. Seda explained that the negative reading is because the direction of flow in the effluent channel is towards the Facility, rather than into the water body. Refer to Picture 23. The water samples for monitoring are taken with an automatic sampler from the center of the effluent channel when the water level reaches the sampler inlet tube. According to Mr. Seda, no discharge was occurring, the water in the effluent channel was apparently coming from the receiving water body. Which may suggest that the samples taken are not representative if the monitored activity2. Refer to Picture 24. g. The sampling point at the WWTP is located before the flow meter. Part II.E of the Permit states for Outfall 001 that "the sampling point for discharge 001 shall be located immediately after the primary flow-measuring device of the effluent at the treatment system". Refer to Pictures 20 and 21. The WWTP is not in operation and therefore is not discharging. The start-up process of the new WWTP is scheduled to be completed by June 15, 2023. h. Abandoned, deteriorated, and corroded structures were observed throughout the Facility. Refer to Pictures 4, 8, 9, and 10. i. Motors and mechanical equipment placed over concrete floor located at the north side of the Facility were exposed to stormwater. Equipment was corroded and deteriorated. Mr. Seda explained that all liquids in the equipment were drained. Refer to Picture 10. j. Sections of the concrete stormwater channel were observed deteriorated, broken, and with sediments at the bottom. 2 Attachment B.10.a of the Permit and 40 CFR 122.41(j) states that "Samples and measurements taken for the purpose of monitoring shall be representative of the monitored activity." Commonwealth Oil Refining Company Inspection Report Page 6 of 10 NPDES Compliance Evaluation Inspection a. Sediments were observed at the stormwater concrete channel that conveys stormwater from the north side of the Facility to Outfall 003 commonly known as "Tren Urbano". Refer to Pictures 11 and 12. b. The stormwater concrete channel that conveys the effluent of the Oil Trap Box #1 was filled with sediments, the concrete walls were deteriorated, the water in the channel was green, an oil sheen was observed, and fuel odors were perceived. Refer to Pictures 31 and 32. Pictures were taken using a privately-owned phone camera. All pictures taken were unaltered transferred to an EPA-owned laptop (C:\Users\YMaclay\OneDrive - Environmental Protection Agency (EPA)\Pictures\FY 2023\2023-06-07 CORCO). Refer to Attachment 2 for the photo documentation and additional observations. Dry weather prevailed during the Inspection. After the completion of the walkthrough, the EPA Inspector proceeded to perform an Exit Meeting. 6. EXIT MEETING Upon completion of the Site Walkthrough and the document review, the EPA Inspector had an exit meeting with Mr. Seda and Mrs. Martnez. The EPA Inspector provided a summary of her observations during the walkthrough of the Facility including: the leaking at the diesel pump station, corroded equipment around the Facility, sediments at the concrete stormwater channel, sediment and waste at the Oil Trap Boxes. EPA Inspector also requested the following records for offsite review: flow meter calibration records, Facility inspections from August 2021 to present, and the training attendance list. After the conclusion of the Exit Meeting, the EPA Inspector departed the Facility at about 1:00 p.m. 7. OFF-SITE DOCUMENT REVIEW The EPA Inspector performed a review of the following: a. Discharge Monitoring Reports The EPA Inspector requested the Discharge Monitoring Reports (DMRs) from July 2021 up to the most recent submittal. During the Inspection, Mr. Seda provided the DMRs for the following monitoring periods: September 2019, October 2019, November 2019, November 2020, July 2022, August 2022, October 2022, and November 2022. The EPA Inspector performed an off-site search and review of the effluent data submitted by the Permittee for Outfall 003 in EPA's database known as the Integrated Compliance Information System from July 2021 to May 2023 period. Part II.B of the Permit set forth discharge limitations and monitoring requirements which are to be met by CORCO, including the measurement frequency and sample type. The review of the effluent data revealed that effluent limitations were exceeded during mentioned time period for pH, Commonwealth Oil Refining Company Inspection Report Page 7 of 10 NPDES Compliance Evaluation Inspection temperature, and turbidity. Refer to Attachment I of this Inspection Report for a complete list of the DMRs effluent limitations exceedances. b. SWPP Plan The EPA Inspector requested the SWPP Plan and CORCO provided a paper copy, dated December 21, 2020. The EPA Inspector performed an off-site preliminary review of the SWPP Plan and found that CORCO's SWPPP was prepared using the SWPPP template develop by EPA consistent with the requirements of the 2015 NPDES Multi-Sector General Permit for Stormwater Discharges from Industrial Activity ("2015 MSGP"). The SWPP Plan provided to the EPA Inspector does not include a copy of the Environmental Quality Board ("EQB") approval3. Also, the review of the SWPP Plan revealed that it included statements and conditions that are not applicable to the Facility because were based on the 2015 MSGP rather than the Permit. Examples of conditions and statements that are not applicable to the Facility are: Quarterly Visual Assessment of Stormwater Discharges (Section 4.6.2), and Monitoring (Section 4.7). c. Flow Meter Calibration Records The EPA has not received the flow meter calibration records. A label in the flow meter showed that calibration is due in July 2023. d. Facility Routine Inspections The EPA has not received the Facility Routine Inspections; therefore, they were not evaluated. e. Training Attendance List The EPA has not received the training attendance list. End of Report Attachments 3 Part IV.B.15 of the Permit states "The permittee shall comply at all times with the provisions, measures or practices included in the most recent version of the Storm Water Pollution Prevention Plan (Part IV.B.2) approved by EQB." Commonwealth Oil Refining Company Inspection Report Page 8 of 10 NPDES Compliance Evaluation Inspection ATTACHMENT I Discharge Monitoring Reports (DMRs) Review Commonwealth Oil Refining Company Inspection Report Page 9 of 10 DMRs with Effluent Violations Monitoring Period End Date 07/31/2021 10/31/2021 DMR Value Unit Desc Nephelometric Turbidity Units Degrees Fahrenheit Parameter Desc Turbidity Temperature, water deg. fahrenheit 10/31/2021 07/31/2022 07/31/2022 Standard Units Degrees Fahrenheit Nephelometric Turbidity Units pH Temperature, water deg. fahrenheit Turbidity 07/31/2022 Standard Units pH 08/31/2022 Standard Units pH 10/31/2022 Standard Units pH 11/30/2022 Standard Units pH Limit Value 10. 90. 8.5 90. 10. 8.5 8.5 8.5 8.5 DMR Value 15. 90.6 8.52 91.7 38. 8.6 8.62 8.9 9.55 Percent Exceedance 1 2 Violation Code E90 E90 E90 E90 E90 E90 E90 E90 E90 Violation Desc DMR, Limited - Numeric Violation DMR, Limited - Numeric Violation DMR, Limited - Numeric Violation DMR, Limited - Numeric Violation DMR, Limited - Numeric Violation DMR, Limited - Numeric Violation DMR, Limited - Numeric Violation DMR, Limited - Numeric Violation DMR, Limited - Numeric Violation Picture taken on June 7, 2023 CORCO - Peuelas, PR Photo Documentation Picture 1 View of a gasoline pump station located under a roof. Picture 2 View of the diesel pump station located under a roof. Fuel stains were observed at the floor. Picture 3 View of the back side of the diesel pump station. Fuel was observed over the floor and absorbing material was placed at the pipe that feeds the pump. Page 1 of 11 Picture taken on June 7, 2023 CORCO - Peuelas, PR Photo Documentation Picture 4 View of the abandoned plant besides the fuel pump stations in Pictures 1 and 2. The structures were corroded and deteriorated. Picture 5 The red arrow depicts the water coming from the secondary containment of Tank 1014. The yellow arrow shows a groundwater discharge coming from underneath Tank 1021. A stain was observed in the concrete wall where the discharge occurs, and the ground was green like slime. Both discharges reach the stormwater concrete channel at the north side of the Facility and eventually discharge through Outfall 003. Picture 6 View of tank 1014. The secondary containment had standing water and it was being discharged into the stormwater concrete channel at the north side of the Facility during the Inspection. Page 2 of 11 Picture taken on June 7, 2023 CORCO - Peuelas, PR Photo Documentation Picture 7 View of the water accumulated at the secondary containment of tank 1014. Brown sediments were observed at the bottom of the secondary containment, the water was clear, and no oil sheen was observed. Picture 8 View of the Facility from the north side. Corroded tanks were observed. The arrow depicts the discharge coming from the secondary containment of tank 1014. Picture 9 View of the abandoned plant at the north side of the Facility. The structures were corroded and deteriorated. Page 3 of 11 Picture taken on June 7, 2023 CORCO - Peuelas, PR Photo Documentation Picture 10 View of motors and mechanical equipment placed over the concrete floor exposed to stormwater. Equipment was corroded and deteriorated. Picture 11 View of a concrete stormwater channel that conveys stormwater from the north side of the Facility into Outfall 003. This concrete stormwater channel is commonly referred to as "Tren Urbano". The water was turbid, had sediment and a brown/green color. Picture 12 Another view of a stormwater conveyance concrete channel shown in the previous picture. Sediments were observed at the bottom of the channel and the water had a brown/green color. Page 4 of 11 Picture taken on June 7, 2023 CORCO - Peuelas, PR Photo Documentation Picture 13 View of the mechanical shop. Operation is performed under the roof and not exposed to rain. Picture 14 View of Oil Trap Box #1 located between tanks 903 and 950. Sediment was observed accumulated at the bottom of the tank and waste was observed floating at the water surface including plastic bottles, foam cups, and leaves. Picture 15 View of Oil Trap Box #2 near tank 902. Fuel residues, oil sheens and waste (like foam cups and water bottles) were observed floating at the water surface. Fuel odors were perceived. Page 5 of 11 Picture taken on June 7, 2023 CORCO - Peuelas, PR Photo Documentation Picture 16 View of Oil Trap Box #2. Sediment was observed accumulated at the bottom of the tank reaching above the water surface. Picture 17 View of the Oil Trap Box #3 located besides the WWTP. Picture 18 View of Oil Trap Box #3. Oil sheens and waste (like water bottles, foam cups and plates) were observed floating at the water surface. The water had a dark green color. Page 6 of 11 Picture taken on June 7, 2023 CORCO - Peuelas, PR Photo Documentation Picture 19 View of the WWTP. Picture 20 The yellow arrow depicts the location where samples will be taken. The flow meter is located after the red box. Picture 21 The yellow arrow depicts the location where the flow meter is located, which is after the sampling point. Page 7 of 11 Picture taken on June 7, 2023 CORCO - Peuelas, PR Photo Documentation Picture 22 Depicts a view of the shed where the automatic sampler and the flowmeter for Outfall 003 are located. Also, a sign was place in front of the shed that reads "Punto de Muestreo Descarga 003". Picture 23 View of the flowmeter located in the shed. The reading shows a value of 2353.49 gpm. Mr. Seda explained that the negative reading is because the direction of flow in the channel is towards the Facility, rather than into the water body. It shows a sticker with the calibration and the next schedule calibration is in July 2023. Picture 24 View of the sampling location for Outfall 003 at the Effluent Channel. The red arrow indicates the direction of the flow in the Effluent Channel. The yellow arrow depicts the location of the automatic sampler inlet tube and where the water sample for monitoring is taken. Outfall 003 was accessible and free of vegetation, debris, and trash. Page 8 of 11 Picture taken on June 7, 2023 CORCO - Peuelas, PR Photo Documentation Picture 25 View of the Effluent Channel that receive the discharges from Outfall 001 and 003. Absorbent booms were installed. Picture 26 View of Outfall 001 located after Outfall 003 at the Effluent Channel. A label was observed and reads "Punto de Muestreo Descarga 001". Outfall 001 is accessible and free of vegetation, debris, and trash. Picture 27 View of the guillotine valves prior discharge into the effluent channel. During the Inspection, storm water was not being discharged through the guillotine valves. Page 9 of 11 Picture taken on June 7, 2023 CORCO - Peuelas, PR Photo Documentation Picture 28 View of the stormwater concrete channel that flows to Outfall 003, before the guillotine valves. Sediments were observed, and the concrete walls were deteriorated. Picture 29 View of Oil Trap Box #4 located in the North Side of the Facility. Picture 30 View of the water in the Oil Trap Box #4, the water was turbid and had a dark green color and sediments were observed. Page 10 of 11 Picture taken on June 7, 2023 CORCO - Peuelas, PR Photo Documentation Picture 31 View of the channel that conveys stormwater from the Oil Trap Box #1 into the concrete stormwater channel at the north side of the Facility. The channel was filled with sediments, the concrete walls were deteriorated, the water in the channel was green, an oil sheen was observed, and fuel odors were perceived. Picture 32 View of the same channel shown in the previous picture. The concrete headwall structure was broken and deteriorated, the channel was filled with sediments, and oil booms were installed at the entrance of each pipe. Page 11 of 11