Document gDkn2KMGq70ka53ZXK5EZgag3
Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection
EPA REGION 6 Enforcement Division
INSPECTION REPORT
05/20/2024 09:45 (CT)
Announced: No
05/20/2024 12:45 (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
Gibson Energy Infrastructure, LLC None 248 FM 1069 South Ingleside, TX 78362 San Patricio County N/A None Gibson Energy is a crude oil storage and export terminal. 27.827082, -97.192750
Additional Persons Participating in Inspection:
Name
Title
Organization
Cameron Tanaka Erin Young-Dahl
Contractor Inspector
Eastern Research Group (ERG) EPA REGION 6
John Penland
Inspector
EPA REGION 6
Email Cameron.Tanaka@erg.com
YoungDahl.Erin@epa.gov Penland.John@epa.gov
Phone (508) 314-6432
(214) 665-3166 (214) 665-9717
Lead Inspector: Brook McKeown
ERG
Brook.McKeown@erg.com
09/03/2024 (410) 459-5811
Page 1 of 6
Gibson Energy Infrastructure, LLC
Inspection Date: 05/20/2024
SECTION I - INTRODUCTION
Site Entry and Purpose of the Inspection
The Port of Corpus Christi 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 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
Phone
Email
Opening Closing Conf. Conf.
Brook McKeown (410) 459-5811 Brook.McKeown@erg.com Yes
No
Cameron Tanaka (508) 314-6432 Cameron.Tanaka@erg.com Yes
No
Erin Young-Dahl (214) 665-3166 YoungDahl.Erin@epa.gov Yes
Yes
John Penland (214) 665-9717 Penland.John@epa.gov Yes
Yes
Page 2 of 6
Gibson Energy Infrastructure, LLC
Inspection Date: 05/20/2024
Facility General Description
Tenant/Area Gibson Energy Infrastructure, LLC
Inspection Date
05/20/24
Process Description Gibson Energy Infrastructure, LLC (Gibson) is a crude oil storage and export terminal. The company brings crude oil in through pipelines exclusively then loads vessels with crude oil through its pipelines. Gibson generates various waste streams including oily condensate water from its vapor pipelines, oil contaminated seals that it has replaced, and oily rags, pads, and filters. The company sends its condensate waste to Western Gulf Recycling, which uses vacuum trucks to remove the waste from drums onsite. The company has not shipped off any seals or other oil contaminated material yet because it only began operations in January 2024. Gibson is still working on its disposal contract with US Ecology. The facility maintains a MARPOL COA for Annexes I and V.
Area of Concern
No
Page 3 of 6
Gibson Energy Infrastructure, LLC
Inspection Date: 05/20/2024
SECTION II - OBSERVATIONS
Tenant: Gibson Energy Infrastructure, LLC
Section: 2.1
Date: 05/20/24, 09:45 AM
Contains AOC: No Contains CBI: No
Lead Inspector: Cameron Tanaka
Attendees: Casey Krause (EHS Specialist), Jay Storms (Maintenance Supervisor), Barney Duge (HSE Advisor)
Gibson owns and operates the South Texas Gateway Terminal which is a crude oil storage and export terminal. Gibson's main activity at the terminal is tank storage of crude oil. The company brings crude oil in through pipelines exclusively then loads vessels with crude oil through its pipelines. Gibson rents out its tank space to the owners of the crude oil and its pipelines extend to two docks where it loads vessels with crude. The company does not handle any refined material and its product is sampled once a month by its customers through a third party to verify the material. Gibson only accepts vessels on its docks and not barges. Most of Gibson's crude oil is West Texas Intermediate.
The facility maintains a MARPOL COA for Annexes I and V, which Mr. Krause included in a follow-up email on 05/21/2024 (see Appendix 2 and Appendix 3). Gibson does not have an EPA ID, though they do have a solid waste registration number under the Texas Commission on Environmental Quality (TCEQ). The company generates various waste streams including oily condensate water from its vapor pipelines, oil contaminated seals that it has replaced, and oily rags, pads, and filters. Gibson has two pipelines for vapor which are combusted in four vapor combustors, and they generate oily condensate waste from these vapor pipelines. Gibson's maintenance team purges the vapor condensate water into drums. The company sends its condensate waste to Western Gulf Recycling, which uses vacuum trucks to remove the waste from the drums. Gibson has sent oily condensate waste offsite three times since January 2024. Gibson has not shipped off any seals or other oil contaminated material yet because it only began operations in January 2024. The company is still working on its disposal contract with US Ecology. Before January 2024, the terminal was operated by Buckeye. Nothing besides oily condensate waste and general trash have been disposed of since Gibson started operating the terminal. Any oily debris, such as filters, rags, and pads, is collected in a roll-off container that also has the potential to hold spill material and sludge. Gibson personnel indicated that they were recently approved to use US Ecology to dispose of filters and other oil contaminated materials. Gibson personnel indicated that they could potentially have more waste streams in the future such as sandblast media, paint waste, universal waste, and wastes associated with tank cleaning. However, the company does not generate any of these wastes yet. The inspection team observed several Bills of Lading (BOLs) for disposal of hydrocarbon contaminated condensate wastes and found no issues with these BOLs.
During the inspection, the inspection team visually inspected Gibson's dock area, skid area, and nonhazardous waste accumulation area, also known as the Northside area of the facility.
Dock Area:
At the dock area, the inspection team observed a non-hazardous condensate drum that was empty and an oily debris drum that was mostly empty. Gibson personnel indicated that they plan to sample the oily debris drums on a case-by-case basis once they are filled. The inspection team observed four roll-off containers that reportedly held hydrocarbon contaminated debris, which were not labeled as to their contents (see Appendix 1 - Photos 1 through 6). One of these roll-offs was dated as 10/17/23, one had a smudged date, and two were labelled as "trash." The inspection team also viewed the vapor condensate area in the dock area and the drum used to collect condensate water.
Page 4 of 6
Gibson Energy Infrastructure, LLC
Inspection Date: 05/20/2024
Skid Area:
The inspection team observed one 55-gallon drum in the skid area that was labeled as used oil but contained an unknown waste. The drum had reportedly been onsite since at least the end of 2023 (see Appendix 1 - Photo 7). A hazardous waste determination was not performed for this waste, and it was not labeled "hazardous waste, pending analysis" until a determination was made [AOC #1 - Gibson did not make an accurate determination as to whether its waste is a hazardous waste in order to ensure wastes are properly managed according to applicable RCRA regulations. - 40 CFR 262.11].
Northside Area:
In the Northside area, the inspection team observed two unlabeled roll-offs that supposedly contained hydrocarbon contaminated used seals (see Appendix 1 - Photo 8). The inspection team also observed five roll-offs that contained hydrocarbon contaminated debris, which were not labeled as to their contents (see Appendix 1 - Photo 9). The inspection team observed Gibson's non-hazardous accumulation area in the Northside area and found no issues (see Appendix 1 - Photo 10).
The AOC was communicated to Gibson during the closing conference; however, further EPA review may change or add to their potential AOCs. A closing conference was conducted at approximately 12:20 PM with Gibson personnel. Mr. Krause responded via email on 05/23/2024 (see Appendix 2) with images of the twelve roll-offs being labelled as non-hazardous waste (see Appendix 4 - Photos 1 through 13). In his email, Mr. Krause also explained that the contents of the 55-gallon drum in the skid area were transferred to a new drum (see Appendix 2). He explained that the new drum was labeled "Hazardous Waste, pending analysis" and was moved to the waste management area (see Appendix 4 - Photo 15). He indicated that the previous drum is now empty and has been labeled as such (see Appendix 4 - Photo 14). He explained that Gibson personnel determined that the contents of the original drum were crude oil from a previous drain-up with debris mixed in. According to Mr. Krause's follow-up email, Gibson personnel plan to sample this drum in the near future and dispose of it as hazardous waste (see Appendix 2).
Page 5 of 6
Gibson Energy Infrastructure, LLC
Inspection Date: 05/20/2024
SECTION III - RECORDS REVIEW No RCRA-regulated records were reviewed during this focused onsite inspection.
SECTION IV - AREAS OF CONCERN
The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation. Tenant: Gibson Energy Infrastructure, LLC
AOC #1 - Gibson did not make an accurate
Citation: 40 CFR 262.11
determination as to whether its waste is a hazardous
waste in order to ensure wastes are properly managed
according to applicable RCRA regulations.
Section: 2.1
SECTION V - 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. 05/21/24 Gibson email - Casey Krause provided Gibson's MARPOL COA. 2. 05/23/24 Gibson email - Casey Krause provided follow-up photos and an explanation of how the drum in the skid area was handled.
SECTION VI - LIST OF APPENDICES Appendix 1. Photograph Log Appendix 2. Follow-Up Email from Gibson Appendix 3. Gibson MARPOL COA Appendix 4. Follow-Up Photographs from Gibson
Page 6 of 6
APPENDIX 1. PHOTOGRAPH LOG
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 1
Location: Gibson Energy Infrastructure, LLC
City: Ingleside
County/Parish: San Patricio
State: Texas
Photo File Name: DSCN1055 Date of Photo: 05/20/2024 Time of Photo: 11:05 hrs. Photographer: Cameron Tanaka Description: A roll-off container with hydrocarbon contaminated debris in Gibson's dock area dated 10/17/23.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 2
Location: Gibson Energy Infrastructure, LLC
City: Ingleside
County/Parish: San Patricio
State: Texas
Photo File Name: DSCN1056 Date of Photo: 05/20/2024 Time of Photo: 11:05 hrs. Photographer: Cameron Tanaka Description: Close-up of the label on the roll-off container in Photo No. 1 in Gibson's dock area.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 3
Location: Gibson Energy Infrastructure, LLC
City: Ingleside
County/Parish: San Patricio
State: Texas
Photo File Name: DSCN1057 Date of Photo: 05/20/2024 Time of Photo: 11:06 hrs. Photographer: Cameron Tanaka Description: Roll-off container with hydrocarbon contaminated debris that did not have a label and had a smudged date in Gibson's dock area.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 4
Location: Gibson Energy Infrastructure, LLC
City: Ingleside
County/Parish: San Patricio
State: Texas
Photo File Name: DSCN1058 Date of Photo: 05/20/2024 Time of Photo: 11:07 hrs. Photographer: Cameron Tanaka Description: Close-up of the label on the roll-off container in Photo No. 3 in Gibson's dock area.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 5
Location: Gibson Energy Infrastructure, LLC
City: Ingleside
County/Parish: San Patricio
State: Texas
Photo File Name: DSCN1059 Date of Photo: 05/20/2024 Time of Photo: 11:08 hrs. Photographer: Cameron Tanaka Description: Two roll-off containers with hydrocarbon contaminated debris in Gibson's dock area.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 6
Location: Gibson Energy Infrastructure, LLC
City: Ingleside
County/Parish: San Patricio
State: Texas
Photo File Name: DSCN1060 Date of Photo: 05/20/2024 Time of Photo: 11:08 hrs. Photographer: Cameron Tanaka Description: Close-up of the label on one of the roll-off containers in Photo No. 5 in Gibson's dock area.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 7
Location: Gibson Energy Infrastructure, LLC
City: Ingleside
County/Parish: San Patricio
State: Texas
Photo File Name: DSCN1061 Date of Photo: 05/20/2024 Time of Photo: 11:20 hrs. Photographer: Cameron Tanaka Description: 55-gallon drum in Gibson's skid area that was labeled as used oil but contained an unknown waste. The drum had been onsite since at least the end of 2023.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 8
Location: Gibson Energy Infrastructure, LLC
City: Ingleside
County/Parish: San Patricio
State: Texas
Photo File Name: DSCN1062 Date of Photo: 05/20/2024 Time of Photo: 11:31 hrs. Photographer: Cameron Tanaka Description: Two unlabeled roll-off containers that supposedly contained hydrocarbon contaminated used seals in Gibson's Northside area.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 9
Location: Gibson Energy Infrastructure, LLC
City: Ingleside
County/Parish: San Patricio
State: Texas
Photo File Name: DSCN1063 Date of Photo: 05/20/2024 Time of Photo: 11:36 hrs. Photographer: Cameron Tanaka Description: Five roll-off containers that supposedly contained hydrocarbon contaminated debris in Gibson's Northside area.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 10
Location: Gibson Energy Infrastructure, LLC
City: Ingleside
County/Parish: San Patricio
State: Texas
Photo File Name: DSCN1064 Date of Photo: 05/20/2024 Time of Photo: 11:39 hrs. Photographer: Cameron Tanaka Description: Gibson's non-hazardous waste accumulation area in Gibson's Northside area (observed).
APPENDIX 2. FOLLOW-UP EMAIL FROM GIBSON
Appendix 2 Page 1 of 3
Appendix 2 Page 2 of 3
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APPENDIX 3. GIBSON MARPOL COA
United States Coast Guard
Certificate Of Adequacy
for
Reception Facility
This certifies that:
Gibson Energy Aransas Pass Texas UNITED STATES
has facilities adequate to receive
MARPOL I
MARPOL V
From oceangoing ships, as required by the International Convention for the Prevention of Pollution from Ships, 1973. As modified by the protocol of 1978 (MARPOL 73/78), The Act to Prevent Pollution from Ships, 33 USC 1901-1912 and associated U.S. Regulations in 33 CFR 158.
This certificate is issued pursuant to an application dated 14DEC2023 and an inspection dated 20DEC2023, copies of which are attached, and part of this certificate. Each terminal listed in the application shall maintain a copy of this certificate available for inspection by Coast Guard personnel and the master, operator, agent, or owner of any ship using or intending to use this terminal.
Terminals and ports required to have an operations manual for oil transfer described in 33 CFR 154.300 shall attach a copy of this certificate thereto.
The terminal/port person in charge identified in the attached application shall notify the U.S. Coast Guard Captain of the Port (COTP) in writing after any of the reception facility information or terminal/port information identified in 33 CFR 158.165 changes.
The terminal/port owner, operator, or person in charge is liable for violations of the provisions of 33 CFR 158 and may be subject to the maximum penalty under 33 USC 1908, as adjusted for inflation and found at 33 CFR 27.3.
The terminal/port owner, operator, or person in charge shall ensure that the reception facility holds each state, local, and federal permit and license required by environmental laws and regulations concerning garbage, residues and mixtures containing oil or noxious liquid substances. This certificate certifies compliance with applicable sections of 33 CFR 158, but does not certify compliance with any other law or regulation.
This certificate is valid for a period of 5 years from the date issuance; or until suspended or revoked; or until 30 days after the operator cited on the certificate changes; at which time it shall be promptly returned to the U.S. Coast Guard COTP.
This Certificate Expires:
12JAN2029
5 years from date of issuance
Signature of COTP M. W. METZ, CDR, USCG, By direction Typed Name of COTP Sector Corpus Christi COTP Zone
Date 12JAN2024 Date
Phone
The following waivers to this certificate are granted. The waivers shall be attached to and are part of this certificate. Waiver Description (brief description)
Expire Date (if applicable)
Dept. of Homeland Sec., USCG, CG-5401 (Rev 01-2019)(v3), OMB No. 1625-0045, Previous Editions are Obsolete Appendix 3 Page 1 of 2
Page 1 of 2
Date
Certificate of Adequacy Inspection Endorsement
(to be endorsed after each reception facility inspection)
Inspector's Name (typed or printed)
Inspector's Signature
Dept. of Homeland Sec., USCG, CG-5401 (Rev 01-2019)(v3), OMB No. 1625-0045, Previous Editions are Obsolete Appendix 3 Page 2 of 2
Page 2 of 2
APPENDIX 4. FOLLOW-UP PHOTOGRAPHS FROM GIBSON
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