Document ZQjYG5xa47wa0oDGL1qOMp17

Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 6 Enforcement Division INSPECTION REPORT 06/26/2024 12:55 PM (CT) Announced: No 06/26/2024 01:40 PM (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 Tenaris N/A 1107 Navigation Blvd Freeport, TX 77541 Brazoria County Non-generator 331210 Tenaris Freeport facility receives steel bars from ships, which are offloaded by Gulf Stream Marine and stored in two yards at the port before being shipped to another Tenaris facility for processing. 28.9392, -95.34806 Additional Persons Participating in Inspection: Name Title Organization Elizabeth Pham Inspector EPA REGION 6 Erin Young-Dahl Inspector EPA REGION 6 Neil Rapp Contractor Eastern Research Group (ERG) Email Pham.Elizabeth@epa.gov YoungDahl.Erin@epa.gov Neil.Rapp@erg.com Lead Inspector: Vince Damiano Vincent Damiano ERG Digitally signed by Vincent Damiano Date: 2024.08.27 13:54:29 -04'00' Vince.Damiano@erg.com Phone (214) 665-8354 (214) 665-3166 (480) 450-6517 (703) 633-1732 Page 1 of 3 Tenaris Inspection Date: 06/26/2024 SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection The Port Freeport 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 Neil Rapp (480) 450-6517 Neil.Rapp@erg.com Yes Yes Elizabeth Pham (214) 665-8354 Pham.Elizabeth@epa.gov Yes Yes Erin Young-Dahl (214) 665-3166 YoungDahl.Erin@epa.gov Yes Yes Facility General Description Tenant/Area Tenaris Inspection Date 06/26/2024 Process Description Tenaris's Freeport facility receives steel bars from ships, which are offloaded by Gulf Stream Marine and stored in two yards at the port. The steel bars are then shipped to Tenaris facility in Bay City. The facility does not maintain a MARPOL COA. Area of Concern No Page 2 of 3 Tenaris Inspection Date: 06/26/2024 SECTION II - OBSERVATIONS Tenant: Tenaris Section: 2.1 Date: 06/26/24, 12:55 PM Contains AOC: No Contains CBI: No Lead Inspector: Vince Damiano Attendees: Carl Thigpan (Logistics Operator), Dan Daughrity (Logistics Operator), Yazmin Sanchez (Logistics Sr Manager), Sorin Moga (Port Operations Manager), Nancy Hernandez (Logistics Operator, Foreign Trade Manager) Tenaris is located within Port Freeport and operates as a shipping station for Tenaris' operations. Tenaris receives steel bars from ships which are offloaded by Gulf Stream Marine and stored in two yards at the port. The steel bars are then delivered by Jetco to Tenaris in Bay City, TX. Tenaris representatives explained that all operations conducted in their storage yards are managed by Gulf Stream Marine. Tenaris does not generate any RCRA-regulated waste and does not have an EPA ID. Tenaris does not maintain a MARPOL COA as all dock operations are conducted by Gulf Stream Marine. Following an opening conference, the inspection team conducted a visual inspection of the storage yards. The inspection team observed one 55-gallon drum of used oil, properly labeled, from Gulf Stream Marine equipment maintenance. No apparent areas of concern were noted during the inspection. A closing conference was conducted at approximately 1:30 PM with Tenaris personnel. SECTION III - RECORDS REVIEW No RCRA-regulated records were reviewed during this focused onsite inspection. SECTION IV - AREAS OF CONCERN Not Applicable SECTION V - FOLLOW UP Not Applicable Page 3 of 3