Document e79yJex33Q2Zjekj7Dgk6Nqmg
Inspection Entry Date/Time Inspection Exit Date/Time
Regulatory Program Type of Inspection
EPA REGION 6 Enforcement Division
INSPECTION REPORT
06/24/2024 01:00 PM (CT)
Announced: No
06/24/2024 02:30 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
Enterprise Products / Seaway TXR000078402 2327 County Rd 731 Freeport, TX 77541 Brazoria County Non-generator 486110 Enterprise operates as a transfer terminal facility for vessels loading and unloading crude oil at its dock. 28.9417, -95.345546
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 13:20:29 -04'00'
Vince.Damiano@erg.com
Phone (214) 665-8354 (214) 665-3166 (480) 450-6517
(703) 633-1732
Page 1 of 3
Enterprise Products / Seaway
Inspection Date: 06/24/2024
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, and other 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 Enterprise Products / Seaway
Inspection Date
06/24/24
Process Description Enterprise Products/Seaway operates as a transfer facility for vessels unloading crude oil at its dock. The crude oil is not stored at the dock location and is transferred to an offsite location via pipeline. The facility maintains a MARPOL COA for Annex I and V but does not receive waste from vessels.
Area of Concern
No
Page 2 of 3
Enterprise Products / Seaway
Inspection Date: 06/24/2024
SECTION II - OBSERVATIONS
Tenant: Enterprise Products / Seaway
Section: 2.1
Date: 06/24/24, 1:00 PM Contains AOC: No
Lead Inspector: Vince Damiano Attendees: Casey Cowles (EPROD OPS SUP)
Contains CBI: No
Enterprise is a tenant of Port Freeport and operates as a terminal for loading and unloading crude oil via pipeline. Enterprise operates a single dock capable of docking two vessels at once. Crude oil is transferred via pipeline between the terminal and a storage facility at Jones Creek, located seven miles from Enterprise. Crude oil can be stored in one of seven tanks at the Jones Creek facility. Enterprise has a MARPOL Annex I and V COA (see Appendix 1). Mr. Cowles stated they do not accept waste from ships at their docks, and the only material moving across their dock is crude oil, which is hard-piped. They are a non-generator of hazardous waste but have an EPA ID (TXR000078402). The only waste Enterprise generates is general trash and oily trash, both of which are managed as non-hazardous wastes.
Upon finishing the opening conference, the inspection team observed Enterprise's dock areas and where they manage oily trash waste. The inspection team did not observe any apparent AOCs and a closing conference was conducted at approximately 2:30 PM with Enterprise personnel.
SECTION III - RECORDS REVIEW No RCRA-regulated records were reviewed during this focused onsite inspection. SECTION IV - 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. 06/26/24 Enterprise email - Mr. Cowles provided the inspection team with a copy of their MARPOL COA.
SECTION V - LIST OF APPENDICES Appendix 1. Enterprise COA
Page 3 of 3
APPENDIX 1. ENTERPRISE COA