Document pBgJLn1exKDQeqJ16GeOOR3yd

Inspection Entry Date/Time EPA REGION 6 Enforcement Division INSPECTION REPORT 06/25/2024 01:10 PM (CT) Inspection Exit Date/Time 06/25/2024 03:10 PM (CT) Regulatory Program Type of Inspection RCRA Focused Compliance Inspection (FCI) 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 Vopak Industrial Infrastructure Americas Freeport, LLC TXR000085527 2301 Brazosport Blvd, Building A-2813 Freeport, TX 77541 Brazoria County Large Quantity Generator (LQG) 493190 Vopak operates as a terminal for product transfers between ships, vessels, rails, and barges for chemical products 28.9825, -95.352777 Additional Persons Participating in Inspection: Name Title Organization Email Elizabeth Pham Inspector EPA REGION 6 Pham.Elizabeth@epa.gov Erin Young-Dahl Inspector EPA REGION 6 YoungDahl.Erin@epa.gov Neil Rapp Contractor Eastern Research Neil.Rapp@erg.com Group (ERG) Phone (214) 665-8354 (214) 665-3166 (480) 450-6517 Lead Inspector: Vince Damiano Vincent Damiano ERG Digitally signed by Vincent Damiano Date: 2024.08.27 13:56:28 -04'00' Vince.Damiano@erg.com (703) 633-1732 Page 1 of 3 Vopak Industrial Infrastructure Americas Freeport, LLC Inspection Date: 06/25/2024 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, port related facilities, 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 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 Vopak Industrial Infrastructure Americas Freeport, LLC Inspection Date 06/25/24 Process Description Vopak Industrial Infrastructure Americas Freeport, LLC (Vopak) is a terminal facility loading and unloading specialty chemicals. Dow maintains ownership of the facility's MARPOL COA because they own the facility's dock. Area of Concern No Page 2 of 3 SECTION II - OBSERVATIONS Tenant: Vopak Industrial Infrastructure Americas Freeport, LLC Section: 2.1 Date: 06/25/24, 1:10 PM Contains AOC: No Contains CBI: No Lead Inspector: Vince Damiano Attendees: Clifton Ferrell (SHEQ Director), Sally Perry (Environmental Engineer), Felix Saavedra (Tech Manager), Bas Kleijn (Terminal Manager), Mark Wade (Operations Manager), Joe Garcia (Waste Coordinator) Vopak is located just North of Port Freeport and operates as a terminal for unloading and loading products from vessels, barges, and rail cars. Vopak is not a tenant of Port Freeport. The products being moved consist of hydrocarbons, glycols, caustics, Pygas, naphtha, and other specialty chemicals. Vopak will occasionally receive bulk raw product, containerize it, and ship it off to customers. Vopak is situated next to a DOW plant where products are transferred to Vopak's storage tanks via pipeline. Vopak will store the products in their storage tanks for customers and conduct the loading and unloading operations for transportation. Vopak also has DOW contractors conducting day-to-day operations including waste management. DOW maintains the MARPOL COA for the six dock spaces Vopak operates on. Vopak is registered with EPA as an LQG (TXR000085527). Ms. Perry described that the waste streams generated mainly are from small leaks/spills, line flushings, tank cleanings, off spec product, and used oil. Ms. Perry stated she performs the waste profiling and reprofiling as needed, but most material stored on site does not change. Most of the hazardous waste is co-generated with Vopak's customer but is manifested under Vopak. The hazardous waste is mostly sent to the neighboring DOW plant for disposal, but some will be manifested to other disposal facilities based on the nature of the waste. The inspection team began a visual inspection at Vopak's dock spaces at approximately 2:00 PM. The first dock observed was A-8 Dock. There was a satellite accumulation drum at the dock space, but it was empty. Mr. Garcia, Waste Coordinator, stated he brings the waste from the satellite drums at each dock space to the central accumulation area every morning. Next, the inspection team observed the "1660 Area" which serves as Vopak's 90-day accumulation area. The inspection team observed four containers of hazardous waste with a D008 waste code. All containers were properly labeled. The inspection team also observed the roll-off area where hazardous waste can be stored for up to 90-days in roll-off containers. One roll-off with hazardous waste sludge was found; the container was properly sealed and labeled. No apparent areas of concern were noted from the visual inspection. Following the visual inspection, a closing conference was held with Vopak personnel at 3:10 PM. SECTION III - RECORDS REVIEW No RCRA-regulated records were reviewed during this focused onsite inspection. SECTION IV - AREAS OF CONCERN Not Applicable SECTION V - FOLLOW UP Follow-Up Not Applicable Page 3 of 3