Document ZngjKq8ww0bjg05mgRzeoEeyd

Inspection Date(s): Time: Program: Regulatory Program(s): If Access is Denied: REGION 10 Enforcement Division INSPECTION REPORT 06/06/2022 - 06/06/2022 Announced: No Entry: 10:51 AM (AKT) Exit: 12:24 PM (AKT) RCRA Title 40 - ENVIRONMENTAL PROTECTION AGENCY Company Name: Facility or Site Name: Facility/Site Physical Address: (City, state, zip code) Type of Operation: Size of Facility: Length of Facility at Location: Geographic Coordinates: Mailing address: (Secondary Address) Northern Oilfield Solutions, LLC Deadhorse Facility 1001 Airport Way Prudhoe Bay, AK 99734 Fuel distribution and tank farm 257,475 sq. Ft. Since 1984 70.20026, -148.46481 Christina Bentz, REM, C.P.G. Director of Environmental Affairs 450 Alaskan Way South, Suite 707 Seattle, WA 98104 christinab@nsenergy.com Direct: 907-265-3836 (City, state, zip code) Seattle, WA 98104 Facility/Site Identifier: Media Number: NAICS: AKD023254378 N/A 424710 - Petroleum Bulk Stations and Terminals Lead Inspector: Jon Jones Jones, Jon REGION 10 Digitally signed by Jones, Jon Date: 2022.08.05 11:29:46 -08'00' Jones.Jon@epa.gov Additional Persons Participating in Inspection: (907) 271-6329 Supervisor Review: Jen Sullivan Jennifer A Sullivan REGION 10 Digitally signed by Jennifer A Sullivan Date: 2022.08.09 11:39:00 -07'00' Sullivan.Jennifer.A@epa.gov (206) 553-6978 1 of 7 NORTHERN OILFIELD SVCS INC Inspection Date(s): 06/06/2022 - 06/06/2022 SECTION I - INTRODUCTION Purpose of the Inspection/Objective Type of inspection: CEI - Compliance Evaluation Inspection This was a Resource Conservation and Recovery Act (RCRA) inspection. The facility was inspected to ensure compliance with standards for hazardous waste generators and universal waste management (40 C.F.R. Part 262 through 273) and used oil management (40 C.F.R. Part 279). The inspection was conducted as part of a Core Program requirement for FY 2022. Attendees Title Lead Inspector Director of Environmental Affairs Operations Supervisor Name Jon Jones Phone 9072716329 Email Jones.Jon@epa.gov Present in Present in Opening Conf. Closing Conf. Yes Yes Christina Bentz (907) 265-3836 christinab@nsenergy.com Yes No Brian Graves (907) 659-2840 brian.graves@nosi.com Yes Yes Opening Conference EPA Lead Inspector Jon Jones arrived at the Northern Oilfield Solutions, LLC at 10:51 AM (AKT) on 06/06/2022 for an inspection. I presented my credentials to Brian Graves and informed him that this was an EPA RCRA inspection. The table above presents all the inspection opening and closing conference participants. Ms. Bentz joined by telephone and during the opening conference I told her that during my file review for the inspection, I identified that there were two EPA identification numbers for the site. I told Ms. Bentz that I had previously inspected the facility on July 10, 2017 under EPA identification number AKR 00000 4994. I explained that while reviewing the file, the address for EPA identification number AKD 02325 4378 was listed as Pouch 340043 which is a mail stop. I searched E-Manifest, using EPA identification number AKD 02325 4378 and saw that the generators address on the last hazardous waste manifest was listed as 1001 Airport Way, Prudhoe Bay, AK 99734. I told Ms. Bentz that I would have someone from EPA follow-up with her regarding the two EPA identification numbers for the same physical location. I was accompanied by Mr. Graves during the inspection of the facility. During the inspection I looked at the facility's processes, in addition to hazardous waste management practices, generation points, and accumulation areas. I looked for wastes that facility representatives had not yet identified or designated as hazardous. Specifically, I inspected the following areas of the facility listed below. Only those areas in which I observed areas of concern or noted other pertinent issues are discussed in this inspection report. Facility/Site Description Northern Oilfield Solutions, LLC (facility) is a bulk fuel terminal located in an industrial area in Deadhorse, Alaska. 2 of 7 NORTHERN OILFIELD SVCS INC Inspection Date(s): 06/06/2022 - 06/06/2022 Facility Info Number of employees 8 full-time and 4 contractors Weather Conditions Cold and windy Operating Hours 7 days a week, 6:00 a.m. to 4:30 p.m. Safety Training No Provided to Inspector(s)? What type of generator facility notified? Very Small Quantity Generator (VSQG) What type of generator facility verified as? VSQG, verified by Mr. Graves Process Description I asked Mr. Graves about the facility's waste streams and he told me the following: Waste Ni-Cad and Lithium-ion batteries - managed as universal waste. Waste aerosols - Mr. Graves said that they were looking into taking their waste aerosols to the Oxbow landfill. Waste absorbents contaminated with gasoline are managed as hazardous waste (offered for transportation to US Ecology - formerly NRC). Waste absorbents contaminated with Jet A (diesel) are managed as solid waste and disposed of at the Oxbow landfill. The shop was inaccessible at the time if the inspection due to a fire that occurred in 2019. According to Mr. Graves the shop building was deemed unsafe to enter. Building(s) Building/Area/Sub-area Tank farm Tote Barn Across from SAA Process Description Fuel storage Storage and SAA Area of Concern No No No 3 of 7 NORTHERN OILFIELD SVCS INC Inspection Date(s): 06/06/2022 - 06/06/2022 SECTION II - OBSERVATIONS AND RECORDS REVIEW Observations Building: Tote Barn Observation #: JJ1-OB-001 Contains CBI: No Date: 06/06/2022 At the time of the inspection, there was a 55-gallon container that held a mix of snow melt and gasoline from a gas spill incident that occurred 11/13/20. According to Mr. Graves the container was full. Mr. Graves was unsure what they planned to do with it. After talking with Ms. Bentz, Mr. Graves said the waste would be managed as non-regulated waste and go out for fuel blending. Photo(s) 1. IMG-202206061202222221057358.jpg 2. IMG-202206061203383381042275.jpg 3. IMG-20220606120358358659285.jpg 4. IMG-2022060612040646822473.jpg Records Review The facility is a VSQG and no records were reviewed during the inspection. SECTION III - AREAS OF CONCERN The presentation of areas of concern does not constitute a formal compliance determination or violation. I observed no areas of concern at the time of the inspection. SECTION IV - FOLLOW UP N/A 4 of 7 NORTHERN OILFIELD SVCS INC Inspection Date(s): 06/06/2022 - 06/06/2022 Closing Conference At the conclusion of the inspection, I conducted a closing conference that was attended by those listed in the Attendees table, in Section I of this report. I thanked Mr. Graves for his time and cooperation during the inspection. I then explained the follow-up process that would take place once I finished the report. I explained they would receive a copy of the report as would a case officer. I told Mr. Graves that I had not observed any areas of concern during my inspection of the facility; however, areas of concern could still be identified once the inspection report was completed and reviewed. Following the Inspection After the inspection, I sent an email to both Mr. Graves and Ms. Bentz on July 20, 2022. In that email, I stated, "During the inspection, it wasn't completely clear how your facility was managing waste aerosols. Can you follow-up with how your facility is managing this waste and please include a copy of any paperwork from the last time they were managed for disposal." Ms. Bentz responded by email on July 21, 2022. In that email Ms. Bentz stated, "Thank you for including me in your question below. Northern Oilfield Solutions, LLC did not generate a lot of waste aerosols. The ones onsite that you observed were primarily generated in the last 12 months following discontinuing the use of a thirdparty service provider who was the main generator of waste aerosols. As the generator of the waste aerosols, the third-party took them with them and disposed of them as part of their process. Prior to that, the last disposal record we have is from 2016 (attached) when they were shipped offsite." I replied to the email Ms. Bentz sent on July 21, 2022 asking, "How does your facility intend to manage the waste aerosols that were onsite during the inspection?" Ms. Bentz responded with an email on July 22, 2022 stating, "With the respect to the below, the facility was recently purchased by another entity and they have taken possession of the waste aerosols. It is my understanding that they have a puncturing station and have punctured them and will managing the empty containers and any liquid contents in accordance with federal waste regulations." SECTION V - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS - No sampling was conducted. SECTION VI - LIST OF APPENDICES Photo Log 5 of 7 NORTHERN OILFIELD SVCS INC Inspection Date(s): [Title] IMG-202206061202222221057358.jpg 06/06/2022 12:02 PM (AKT) Jon Jones Tote Barn No CBI No PII View of 55-gallon container, marked with a Phillips 66 logo, that held a mix of snow melt and gasoline from a gas spill incident that occurred 11/13/20. [Title] IMG-202206061203383381042275.jpg 06/06/2022 12:03 PM (AKT) Jon Jones Tote Barn No CBI No PII Close-up view of 55-gallon container, marked with a Phillips 66 logo, that held a mix of snow melt and gasoline from a gas spill incident that occurred 11/13/20. [Title] IMG-20220606120358358659285.jpg 06/06/2022 12:03 PM (AKT) Jon Jones Tote Barn No CBI No PII View of the top of the container. 06/06/2022 - 06/06/2022 6 of 7 NORTHERN OILFIELD SVCS INC Inspection Date(s): [Title] IMG-2022060612040646822473.jpg 06/06/2022 12:04 PM (AKT) Jon Jones Tote Barn No CBI No PII View of the labeling on the container. 06/06/2022 - 06/06/2022 Document Log Document Type Facility Map Manifests Manifests Communications Document Name Contains Contains Uploaded By CBI PII NOS Block 301 Site Map.docx No No Jon Jones AKD 02325 4378 Man#008741313FLE.pdf No No Jon Jones 2016_12_SCC - Non Hazardous No No Jon Jones Waste Disposal_Clean Harbors.pdf RE_ RCRA Compliance Evaluation No No Jon Jones Inspection of June 6, 2022.pdf Date Received 08/02/2022 08/02/2022 08/02/2022 08/02/2022 7 of 7