Document dQ1Mv5VqnjDr6wmVZGEKYqy9R

Inspection Date(s): Time: Program: Regulatory Program(s): If Access is Denied: REGION 10 Enforcement Division INSPECTION REPORT 02/24/2022 - 02/24/2022 Announced: No Entry: 01:14 PM (AKT) Exit: 02:09 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) (City, state, zip code) County: Petro 49, Inc. Petro Marine Services Ketchikan 1100 Stedman St. Ketchikan, AK 99901 Fuel Distribution Facility 110,000 square feet, 220,000 with tank farm. Approximately 100 years 55.33454, -131.62678 Mr. Kris Hall, Plant Manager 1100 Stedman St. Ketchikan, AK 99901 krish@petro49.com Ketchikan, AK 99901 Facility/Site Identifier: Media Number: NAICS: AKD000834846 N/A 424710 - PETROLEUM BULK STATIONS AND TERMINALS Lead Inspector: Jon Jones Jones, Jon REGION 10 Digitally signed by Jones, Jon Date: 2022.03.17 12:45:08 -08'00' Jones.Jon@epa.gov (907) 271-6329 Supervisor Review: Jen Sullivan Jennifer A Sullivan REGION 10 Digitally signed by Jennifer A Sullivan Date: 2022.03.21 11:12:35 -07'00' Sullivan.Jennifer.A@epa.gov (206) 553-6978 1 of 9 PETRO MARINE SERVICES KETCHIKAN Inspection Date(s): 02/24/2022 - 02/24/2022 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 Name Lead Inspector Jon Jones Cordova Terminal Manager Mark Frohnapfel Plant Manager Kris Hall Operations Manager Wendell Pahang Phone Email 9072716329 Jones.Jon@epa.gov Present in Opening Conf. Yes (907) 424-4050 markf@shoresidepetroleum.com Yes (907) 225-2106 krish@petro49.com Yes (907) 225-2106 wendellp@petro49.com No Present in Closing Conf. Yes Yes Yes Yes Opening Conference EPA Lead Inspector Jon Jones arrived at the Petro Marine Services Ketchikan at 01:14 PM (AKT) on 02/24/2022 for an inspection. I presented my credentials to Mr. Kris Hall, Plant Manager and informed him that this was an EPA RCRA inspection. The table above presents all the inspection participants. When I arrived at the facility, I met with the receptionist at the front desk and announced my intention to conduct a RCRA compliance inspection at the facility. The receptionist asked me who I needed to see, and I told her that the point-of-contact (POC) I had for the facility was Randi Pickrell, Plant Manager. I told the receptionist that Randi Pickrell was the POC in 2014 and may or may not be the current POC. The receptionist had me sign the visitor log. The receptionist told me that she would let the Plant Manager, Kris Hall know I was on-site. Mr. Hall arrived shortly after my arrival and led me upstairs to a conference room where I held the opening conference. Facility/Site Description Fuel Distribution Facility and Tank Farm located in Ketchikan, AK. Additional information about the company can be found at: www.petromarineservices.com 2 of 9 PETRO MARINE SERVICES KETCHIKAN Inspection Date(s): 02/24/2022 - 02/24/2022 Facility Info Number of employees 30 Weather Conditions Sunny and cool Operating Hours Monday through Saturday from 8:00 a.m. to 5:00 p.m. , dock is open Sunday from 8:00 a.m. to 5:00 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? Mr. Hall verified that his facility was a VSQG. Process Description According to Mr. Hall, the following wastes are generated at the facility: Used oil - Burned in an onsite used oil burning space heater. If it can't be burned, due to being contaminated, it is managed through Full Cycle, LLC for recycling. Used antifreeze - Managed through Full Cycle for recycling. Oily absorbents - Burned in smart ash burner. Aerosols, batteries, and lamps are managed through the Household Hazardous Waste (HHW) facility at the local landfill. Automotive and Marine lead-acid batteries are sent to a recycler. During the inspection of the facility on February 24, 2022, I was accompanied by Mr. Hall. 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. I also observed the facility's used oil management. Building(s) Building/Area/Sub-area Warehouse Processing Room Process Description Management and accumulation of used oil which is burned on-site in a used oil burning space heater. Area of Concern Yes Yes 3 of 9 PETRO MARINE SERVICES KETCHIKAN Inspection Date(s): 02/24/2022 - 02/24/2022 SECTION II - OBSERVATIONS AND RECORDS REVIEW Observations Building: Warehouse/Processing Room Observation #: JJ1-OB-001 Contains CBI: No Date: 02/24/2022 Mr. Hall took me to an area in the facility warehouse that he referred to as the Processing room. The processing room is where the facility accumulates used oil in a variety of storage units. During the inspection, I saw a large tank that was located beneath the facility's used oil burning space heater. According to Mr. Hall the tank had a capacity of 300 gallons and was full. At the time of the inspection the tank was not labeled with the words "Used Oil." At the opposite end of the processing room, next to the entrance, I saw a large, black plastic spill catchment container, covered with a wire mesh that was also being used to accumulate used oil. According to Mr. Hall, it had a capacity of approximately 75 gallons. At the time of the inspection, the container held several gallons of used oil and was not labeled with the words 'Used Oil." I told Mr. Hall that federal regulations required all used oil storage units to be labeled with the words "Used Oil" Mr. Hall had warehouse personnel label both the tank beneath the space heater and the spill catchment container with the words "Used Oil" during the inspection. Photo(s) 1. IMG-202202241349104910185730.jpg 2. IMG-202202241349184918132275.jpg 3. IMG-202202241349264926172253.jpg 4. IMG-202202241351295129186966.jpg 5. IMG-202202241351365136175949.jpg 6. IMG-202202241355375537187674.jpg 7. IMG-202202241355435543105755.jpg 8. IMG-202202241355555555203563.jpg 9. IMG-20220224135602562145143.jpg Records Review Facility was verified as being a VSQG and no records were reviewed. SECTION III - AREAS OF CONCERN The presentation of areas of concern does not constitute a formal compliance determination or violation. Building: Warehouse JJ1-OB-001 Area: Processing Room Sub-area: 300-gallon used oil storage tank, beneath the used oil burning space heater, was not labeled with the words "Used Oil." Regulation: 279.22(c)(1) Sections: 4 of 9 PETRO MARINE SERVICES KETCHIKAN Inspection Date(s): Mr. Hall had facility personnel label the tank with the words "Used Oil" during the inspection. 75-gallon used oil tote was not labeled with the words "Used Regulation: Oil." 279.22(c)(1) Mr. Hall had facility personnel label the tote with the words "Used Oil" during the inspection. SECTION IV - FOLLOW UP N/A 02/24/2022 - 02/24/2022 Sections: 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 everyone for their time and cooperation during the inspection and began a review of the areas of concern (listed in Section III - Areas of Concern) that I observed during my inspection of the facility. I then explained the follow-up process that would take place once I finished the report. I explained to Mr. Hall that he would receive a copy of the report, as would a case officer. I told him the case officer would review the report to determine if any of the areas of concern identified in the report documented violations. Following the Inspection After leaving the facility, I received documentation from USDHS CG Base Ketchikan, a facility I had previously inspected in Ketchikan, AK on February 23-24, 2022, just prior to my inspection of Petro Marine Services. The documentation I received was a shipping paper related to the management of universal waste batteries. According to the documentation, USDHS CG Base Ketchikan had shipped universal waste batteries to Petro Marine Services on February 25, 2022. I followed up with Mr. Hall to inquire as to why his facility was taking universal waste batteries from the Coast Guard Base next door. I sent an email to Mr. Hall in which I asked several questions about his facility managing universal waste batteries. Mr. Hall immediately responded by saying that was never an agreement they had and telling me that he had contacted the Coast Guard to have them come back and pick up the batteries. A copy of the email chain between me and Mr. Hall is an attachment to this report. SECTION V - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS - No sampling was conducted. 5 of 9 PETRO MARINE SERVICES KETCHIKAN Inspection Date(s): SECTION VI - LIST OF APPENDICES Photo Log [Title] IMG-202202241349104910185730.jpg 02/24/2022 01:49 PM (AKT) Jon Jones Warehouse/Processing Room No CBI No PII View of 300-gallon used oil storage tank, beneath the used oil burning space heater, that was not labeled with the words "Used Oil." [Title] IMG-202202241349184918132275.jpg 02/24/2022 01:49 PM (AKT) Jon Jones Warehouse/Processing Room No CBI No PII View of 300-gallon used oil storage tank, beneath the used oil burning space heater, that was not labeled with the words "Used Oil." [Title] IMG-202202241349264926172253.jpg 02/24/2022 01:49 PM (AKT) Jon Jones Warehouse/Processing Room No CBI No PII View of 300-gallon used oil storage tank, beneath the used oil burning space heater, that was not labeled with the words "Used Oil." 6 of 9 02/24/2022 - 02/24/2022 PETRO MARINE SERVICES KETCHIKAN Inspection Date(s): [Title] IMG-202202241351295129186966.jpg 02/24/2022 01:51 PM (AKT) Jon Jones Warehouse/Processing Room No CBI No PII View of 75-gallon used oil tote that was not labeled with the words "Used Oil." [Title] IMG-202202241351365136175949.jpg 02/24/2022 01:51 PM (AKT) Jon Jones Warehouse/Processing Room No CBI No PII View of 75-gallon used oil tote that was not labeled with the words "Used Oil." [Title] IMG-202202241355375537187674.jpg 02/24/2022 01:55 PM (AKT) Jon Jones Warehouse/Processing Room No CBI No PII View of 300-gallon used oil storage tank, after being labeled with the words "Used Oil" during the inspection. 7 of 9 02/24/2022 - 02/24/2022 PETRO MARINE SERVICES KETCHIKAN Inspection Date(s): [Title] IMG-202202241355435543105755.jpg 02/24/2022 01:55 PM (AKT) Jon Jones Warehouse/Processing Room No CBI No PII Close-up view of the label on the 300-gallon used oil storage tank. [Title] IMG-202202241355555555203563.jpg 02/24/2022 01:55 PM (AKT) Jon Jones Warehouse/Processing Room No CBI No PII View of 75-gallon used oil tote, after being labeled with the words "Used Oil" during the inspection. [Title] IMG-20220224135602562145143.jpg 02/24/2022 01:56 PM (AKT) Jon Jones Warehouse/Processing Room No CBI No PII Close-up view of the label on the 75-gallon used oil tote. 02/24/2022 - 02/24/2022 8 of 9 PETRO MARINE SERVICES KETCHIKAN Inspection Date(s): 02/24/2022 - 02/24/2022 Document Log Document Type Facility Map Communications Document Name Contains Contains Uploaded By CBI PII Site Map.pdf No No Jon Jones RE_ Universal Waste Batteries.pdf No No Jon Jones Date Received 03/16/2022 03/16/2022 9 of 9