Document jgp02Xx9xZMmdEm8v7LqXpOdO

f t E A ~ United States ..~ . Environmental Protection ~, Agency EPA REGION 6 Enforcement Division INSPECTION REPORT Inspection Entry 4/21/2025 11:54 AM (CT) Date/Time Inspection Exit Date/Time 4/21/2025 01:40 PM (CT) Regulatory Program Type of Inspection RCRA Compliance Evaluation Inspection (CEI) Announced: No (tenants and related facilities) Access: Granted 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 Kinder Morgan Seven Oaks Terminal, LLC LAD084670652 106 Seven Oaks Blvd. Westwego, LA 70094 Jefferson Large Quantity Generator (LQG) 493190 Kinder Morgan Seven Oaks (KMSO) is a bulk liquid storage terminal where barges, vessels, trucks, and railcars transport products in and out of the facility. 29.9299, -90.1632 Additional Persons Participating in Inspection: Name Title Organization Email Sandesh Thapa Inspector EPA REGION 6 Thapa.Sandesh@epa.gov Joseph Watson Contractor Eastern Research Joe.Watson@erg.com Group (ERG) Lead Inspector: Vince Damiano ERG Vincent Damiano Digitally signed by Vincent Damiano Date: 2025.06.06 15:54:30 -04'00' Vince.Damiano@erg.com I Page 1 of 4 Kinder Morgan Seven Oaks Terminal, LLC Inspection Date: 4/21/2025 SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection The Port of New Orleans and surrounding facilities were selected for inspection based on a 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, portrelated facilities, and other records, including photographs taken, verbal or written statements made during or after the on-site inspection, and/or materials shown, demonstrated, or submitted to the Environmental Protection Agency (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 Inspector/Enforcement Officer/EPA Region 6 RCRA Inspector/ Contractor/ERG EHS/KMSO Operations/KMSO EHS/KMSO Name Email Vince Damiano Vince.Damiano@erg.com Sandesh Thapa Thapa.Sandesh@epa.gov Joseph Watson Joe.Watson@erg.com Barry Mader Eddie Cuevas Matthew Santiago Barry_mader@kindermorgan.com Eddie_cuevas@kindermorgan.com Matthew_santiago@kindermorgan.com Opening Closing Conf. Conf. Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Page 2 of 4 Kinder Morgan Seven Oaks Terminal, LLC Inspection Date: 4/21/2025 Facility General Description Tenant/Area Kinder Morgan Seven Oaks Terminal, LLC Inspection Date 4/21/25 Process Description KMSO is a bulk liquid storage terminal where barges, vessels, trucks, and railcars transport products in and out of the facility. The facility maintains a MARPOL Annex I, II, and V COA. Area of Concern Yes SECTION II - OBSERVATIONS Facility: Kinder Morgan Seven Oaks Terminal, LLC Section: 2.1 Date: 4/21/25, 11:54 AM Contains AOC: Yes Contains CBI: No I I Lead Inspector: Vince Damiano Attendees: Barry Mader (EHS), Eddie Cuevas (Operations), and Matthew Santiago (EHS) KMSO, located in Westwego, LA, operates as a bulk liquid storage terminal on the Mississippi River. The facility stores and handles products such as vegetable oils, diesel distillates, and chemicals. KMSO has 17 storage tanks ranging in capacity from 15,00 barrels to 80,000 barrels. KMSO can load and unload products via trucks, railcars, and marine barges at its single dock berth. Tank cleaning and maintenance activities, such as painting and sand blasting, are conducted by third-party contractors who are responsible for managing any waste generated from those operations. KMSO maintains a MARPOL Annex I, II, and V COA. According to Mr. Mader, no waste is allowed to be transferred across the dock space. KMSO has two central accumulation areas (CAAs) and two satellite accumulation areas (SAAs) across the site. KMSO is registered with the EPA as a LQG of hazardous waste under EPA ID LAD084670652. After the opening conference, the inspection team observed KMSO's CAAs, SAAs, universal waste storage area, and dock space. The inspection team first observed the South CAA. The inspection team observed one full 55-gallon drum containing hazardous aniline-contaminated PPE (see Appendix 1 - Photo 1). The drum had the label "haz" instead of "hazardous waste," and did not contain an indication of the hazard of the contents [AOC #1 - KMSO did not label a container with the words "Hazardous Waste" and indication of the hazards of the contents- 40 CFR 262.17(a)(5)(i)]. Upon identification of the AOC, facility representatives immediately relabeled the container to spell the correct phrase (see Appendix 1 - Photo 2). No other waste drums were observed in the south CAA. The inspection team also noted that there was no posted "No Smoking" sign at the South CAA, which may periodically store ignitable or reactive waste [AOC #2 - KMSO did place a "No Smoking" sign where there is a hazard from ignitable or reactive waste - 40 CFR 262.17(a)(1)(vi)(B)]. The inspection team then observed the South SAA, North SAA, North CAA, and universal waste storage area, which were all empty at the time of the inspection. The inspection team then observed the dock space. No areas of concern (AOCs) were noted at the dock. The inspection team did not observe other AOCs at the time of the inspection. However, further EPA review may change or add to their potential AOCs. A closing conference was conducted at approximately 1:40 PM with KMSO personnel. The AOCs were communicated during the closing. Following the inspection on 4/24/2025, Mr. Mader sent a follow-up email in response to the AOCs observed during the inspection, including: Page 3 of 4 Kinder Morgan Seven Oaks Terminal, LLC Inspection Date: 4/21/2025 Photos of No Smoking signs posted at both North and South CAAs (see Appendix 2). 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. Facility: Kinder Morgan Seven Oaks Terminal, LLC AOC #1 - KMSO did not label a container with the words "Hazardous Waste" and an indication of the hazards of the contents Citation: 40 CFR 262.17(a)(5)(i) Section: 2.1 AOC #2 - KMSO did place a "No Smoking" sign where Citation: 40 CFR 262.17(a)(1)(vi)(B) Section: 2.1 there is a hazard from ignitable or reactive waste. 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. 4/24/25 KMSO email - Mr. Mader provided the inspection team with photos of corrections made towards AOCs observed. SECTION VI - LIST OF APPENDICES Appendix 1. Photograph Log Appendix 2. 4/24/25 Response from KMSO Page 4 of 4 APPENDIX 1. PHOTOGRAPH LOG UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Kinder Morgan Seven Oaks Terminal City: Westwego County/Parish: Jefferson State: Louisiana Photo No. 1 Photo File Name: DSCN7958 Date of Photo: 4/21/2025 Time of Photo: 1257 hrs. Photographer: Vince Damiano Description: View of a full 55-gallon drum of storing aniline-contaminated PPE, which was labeled as "Haz" in the South CAA. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Kinder Morgan Seven Oaks Terminal City: Westwego County/Parish: Jefferson State: Louisiana Photo No. 2 Photo File Name: DSCN7959 Date of Photo: 4/21/2025 Time of Photo: 1300 hrs. Photographer: Vince Damiano Description: View of a full 55-gallon drum of storing aniline-contaminated PPE, showing that the facility representatives added the words "Hazardous Waste." APPENDIX 2. 4/24/25 RESPONSE FROM KMSO  Outlook RE: Follow-up from EPA Visit on 4/21/2025 (Seven Oaks) From Mader, Barry <Barry_Mader@kindermorgan.com> Date Thu 4/24/2025 1:36 PM To Vince Damiano <Vince.Damiano@erg.com>; Santiago, Matthew <Matthew_Santiago@kindermorgan.com> Cc Joe Watson <Joe.Watson@erg.com>; Thapa, Sandesh <Thapa.Sandesh@epa.gov> @2 attachments (3 MB) DSCF0444.JPG; DSCF0427.JPG; CAUTION : Don't open links or attachments unless you recognize the sender and know they are safe. Vince, In response to your email below, here's photographs of the posted No Smoking signs at each of the Hazardous Waste Storage Areas (North & South Yards) at the Seven Oaks Terminal. If you need any more information, please advise. Thank you. Barry Mader Specialist-Permitting Compliance Sr I C: 504-239-2882 I 0 : 504-371-7241 KINDER/ MORGAN Harvey & Seven Oaks Terminals 4400 River Road Marrero, LA 70072 Do The Right Thing Every Day CORE PRINCIPLES: 1) Safety Will Not Be Compromised 2) Environmentally Compliant and Responsible Operator 3) Ethics and Integrity 4) Commitment to Employees and Resources 5) Customer Service and Fiscal Responsibility 6) Quality Focus From: Vince Damiano <Vince.Damiano@erg.com> Sent: Tuesday, April 22, 2025 10:16 PM To: Mader, Barry <Barry_Mader@kindermorgan.com>; Santiago, Matthew <Matthew_Santiago@kindermorgan .com> Cc: Joe Watson <Joe.Watson@erg.com>; Thapa, Sandesh <Thapa.Sandesh@epa.gov> Subject: Follow-up from EPA Visit on 4/21/2025 (Seven Oaks) You don't often get email from vince.damiano@ergm. Learn whY. this is im12ortant [This email message was received from the Internet and came from outside of Kinder Morgan.] WARNING: EXTERNAL EMAIL: PROCEED WITH CAUTION. Do not respond, click on links or open attachments unless you recognize the sender or know the content is safe. Hello Barry and Matt, I am following up with a list of items and notes from our inspection yesterday. Below are initial Areas of Concern and items requested; you may follow up with pictures, write-ups, sample results, or however you see fit: No smoking signs were posted in the 90-day storage areas. Hazardous waste drum was improperly labeled (already fixed and documented) Again, thank you for taking the time out of your day to meet with us. Please let us know if you have any questions or concerns. Thanks, Vince ERG Vince Damiano Chemical Engineer, Chantilly Office Cell: (703) 835-6281 Vince.Damiano@m:g.com