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Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 6 Enforcement Division INSPECTION REPORT 11/05/2024 8:40 (CT) 11/05/2024 11:25 (CT) Announced: No (tenants and related facilities) 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 Jefferson Railport Terminal TXR000081730 94 Old Highway 90 E Vidor, TX 77662 Orange County N/A 424710 Jefferson Railport Terminal is a loading and unloading facility for crude oil and oil products such as yellow wax, WTI, Arab light, diesel, gasoline, and naphtha. 30.0827, -94.0807 Additional Persons Participating in Inspection: Name Title Organization Angela Hays Inspector EPA REGION 6 Sandesh Thapa Inspector EPA REGION 6 Jon Herbay Contractor Eastern Research Group (ERG) Email Hays.Angela@epa.gov Thapa.Sandesh@epa.gov Jon.Herbay@erg.com Lead Inspector: Vince Damiano Chemical Engineer ERG Vincent Damiano Digitally signed by Vincent Damiano Date: 2025.02.06 11:09:24 -05'00' Vince.Damiano@erg.com Phone (214) 665-2285 (214) 665-2265 (412) 780-9931 02/06/2025 (703) 633-1732 Page 1 of 5 Jefferson Railport Terminal Inspection Date: 11/05/2024 SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection The Port of Beaumont 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, portrelated 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 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 Inspector/Enforcement Officer/EPA Region 6 RCRA Inspector/ Contractor/ERG Jefferson Railport Terminal Jefferson Railport Terminal Name Phone Email Vince Damiano (703) 633-1732 Vince.Damiano@erg.com Opening Closing Conf. Conf. Yes Yes Angela Hays (214) 665-2285 Hays.Angela@epa.gov Yes Yes Sandesh Thapa (214) 665-2265 Thapa.Sandesh@epa.gov Yes Yes Jon Herbay (412) 780-9931 Jon.Herbay@erg.com Yes Yes John Istre (405) 880-5891 jistre@jeffersonenergyco.com Yes Yes Chris Jeanes (409) 554-1650 cjeanes@jeffersonenergyco.com Yes Yes Page 2 of 5 Jefferson Railport Terminal Inspection Date: 11/05/2024 Facility General Description Tenant/Area Jefferson Railport Terminal Inspection Date 11/05/24 Process Description Jefferson Railport Terminal (JRT) is a storage terminal for crude oil and oil-based products such as yellow wax, West Texas Intermediate (WTI) crude, Arab Light crude, diesel, gasoline, and naphtha. Their facility is covered under Port Beaumont's MARPOL COA for Annexes I and V. Area of Concern Yes SECTION II - OBSERVATIONS Tenant: Jefferson Railport Terminal Section: 2.1 Date: 11/05/24, 08:40 AM Contains AOC: Yes Contains CBI: No Lead Inspector: Vince Damiano Attendees: John Istre (EHS Specialist), Chris Jeanes (Terminal Manager) JRT is located in the Port of Beaumont and operates as a midstream terminal for crude oil and refined oil products. The products RST handles consist of crude oil and oil-based products such as yellow wax, WTI crude, Arab Light crude, diesel, gasoline, and naphtha. JRT moves products via barges, ships, railcars, and pipelines. Once products are received, they are stored in one of 30 storage tanks ranging in size from 31,000 to 423,000 barrels. When products are being delivered to a ship or barge, they are moved through a designated pipe given the product and loaded through a loading arm at one of three docks. JRT is covered under Port of Beaumont's MARPOL COA, but Mr. Jeanes stated they do not remove trash or waste from vessels. JRT is registered with the EPA (TXR000081730) but does not generate hazardous waste. JRT generates used oil, universal waste, and non-hazardous waste from tank cleanouts. Used oil is picked up by E3 OMI, LLC (TXD981055163) for recycling. Following the opening conference, the inspection team conducted a visual inspection of JRT's dock spaces and waste storage areas. The team observed dock spaces OC1 and OC2. Each dock has a rainwater collection sump that is pumped back to its ditch system unless an incident such as a spill or a visible sheen is observed. No areas of concern (AOCs) were observed at JRT's dock spaces. Next, the inspection team observed JRT's drum storage area located in their operating area. The inspection team first observed two parts washers, one 55-gal and one 100-gal, that were not currently in use but left open (see Appendix 1 - Photos 1 and 2). The cleaning solvent used in the parts washers is recycled and serviced by Safety Kleen. The inspection team informed JRT that it is considered a best management practice to keep the parts washers closed when not in use, given the volatile nature of such solvents. The inspection team then observed several different-sized drums to the left of the parts washers that appeared to contain waste given their state including: Six 55-gallon drums ranging from half-full to full of material, Three 5-gallon containers that were half-full of material, Three 35-gallon drums that were half-full of material; and One drip pad that appeared to have oily liquid collected in it (see Appendix 1 - Photos 3 to 6). The drums did not contain any labels or markings. JRT representatives were not able to verify the contents of 3 of 5 Jefferson Railport Terminal Inspection Date: 11/05/2024 the drums or if the drums were storing waste materials at the time of the inspection [AOC #1 - JRT did not make a hazardous waste determination - 40 CFR 262.11]. In front of the shed housing the parts washers, the inspection team observed one half-full 300-gallon tote storing HOH oil, a high-performance industrial lubricant, which is a usable product. The inspection team also found nineteen 55-gallon drums which were also not labeled and all contained material ranging from one-quarter full to full (see Appendix 1 - Photos 7 to 11). One of the 55-gallon drums was crushed (see Photo 10) and all the drums were stored on broken wooden pallets. JRT representatives were unsure what was being stored in the drums at the time of the inspection (see AOC#1). The inspection team also observed a 55-gallon drum accumulating unpunctured aerosol cans. JST stated they are managing the waste as universal waste and the hazardous waste label on the drum was not updated. The drum was closed but had a hole cut into the lid (see Appendix 1 - Photo 12). The inspection team noticed that the facility manages and maintains the railroad tracks within the operating area of JST. The inspection team inquired about any waste generated from railroad maintenance. JST representatives said the largest waste stream is treated wood from the railroad tracks. Following the inspection, JST provided a non-hazardous waste manifest for the treated wood from track maintenance (see Appendix 2). 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 11:30 AM with JST personnel. The AOCs were communicated during the closing. Following the inspection, Mr. Istre sent two emails to the inspection team responding to the AOCs found during the inspection and providing any documents the inspection requested. On 11/6/2024, Mr. Istre sent a profile and manifest for treated wood from the railroad tracks (Appendix 2), an example waste profile and Bill of Lading (BOL) for oily waste (see Appendix 3), and an update on progress in email form (see Appendix 4). On 11/11/2024, Mr. Istre provided a picture of the aerosol drum found during the inspection with a new lid (Appendix 5). On 11/21/2024, Mr. Istre sent an email stating all of the drums found during the inspection were determined to contain usable product and provided several pictures including the lids of the parts washers closed and the drum storage area better organized (see Appendix 6). SECTION III - RECORDS REVIEW No RCRA regulated records were reviewed during this focused onsite inspection besides those mentioned in Section II. SECTION IV - AREA OF CONCERN The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation. Tenant: Jefferson Railport Terminal AOC #1 - JRT did not make a hazardous waste determination. Citation: 40 CFR 262.11 Section: 2.1 SECTION V - FOLLOW UP 4 of 5 Jefferson Railport Terminal Inspection Date: 11/05/2024 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 After the inspection, additional information was emailed to EPA including: 1. 11/05/24 JRT email - Mr. Jeanes provided the pictures taken from the inspection to the inspection team. 2. 11/06/24 JRT email - Mr. Istre sent a profile and manifest for treated wood from the railroad tracks, an example waste profile and BOL for oily waste, and an update on progress. 3. 11/11/24 JRT email - Mr. Istre provided a picture of the aerosol drum found during the inspection with a new lid. 4. 11/21/24 JRT email - Mr. Istre sent an email stating all of the drums found during the inspection were determined to contain usable product and provided several pictures including the lids of the parts washers closed and the drum storage area. SECTION VI - LIST OF APPENDICES Appendix 1. Photograph Log Appendix 2. Treated Wood Profile and Manifest Appendix 3. Oily Waste Profile and BOL Appendix 4. JRT 11/6 Email Response Appendix 5. Aerosol Drum Photo with New Lid Appendix 6. JRT 11/21/24 Response 5 of 5 APPENDIX 1. PHOTOGRAPH LOG UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Jefferson Railport Terminal City: Vidor County/Parish: Orange State: Texas Photo No. 1 Photo File Name: IMG2458 Date of Photo: 11/05/2024 Time of Photo: Between 10:00 and 11:30 hrs. Photographer: Chris Jeanes, JRT Terminal Manager Description: View of a 100-gallon parts washer found in the drum storage area that had its lid left open at the time of the inspection. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Jefferson Railport Terminal City: Vidor County/Parish: Orange State: Texas Photo No. 2 Photo File Name: IMG2459 Date of Photo: 11/05/2024 Time of Photo: Between 10:00 and 11:30 hrs. Photographer: Chris Jeanes, JRT Terminal Manager Description: View of a 55-gallon parts washer found in the drum storage area that had its lid left open at the time of the inspection. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Jefferson Railport Terminal City: Vidor County/Parish: Orange State: Texas Photo No. 3 Photo File Name: IMG2460 Date of Photo: 11/05/2024 Time of Photo: Between 10:00 and 11:30 hrs. Photographer: Chris Jeanes, JRT Terminal Manager Description: View from left to right: two 55-gallon drums, three 35-gallon drums, and two 5-gallon containers found inside the drum storage area next to the parts washers. The containers were storing unknown materials at the time of the inspection. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Jefferson Railport Terminal City: Vidor County/Parish: Orange State: Texas Photo No. 4 Photo File Name: IMG2461 Date of Photo: 11/05/2024 Time of Photo: Between 1000 and 1130 hrs. Photographer: Chris Jeanes, JRT Terminal Manager Description: View from left to right: one 5-gallon container, six 55-gallon drums, and two 35-gallon drums found inside the drum storage area next to the parts washer. The containers were storing unknown materials at the time of the inspection. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Jefferson Railport Terminal City: Vidor County/Parish: Orange State: Texas Photo No. 5 Photo File Name: IMG2462 Date of Photo: 11/05/2024 Time of Photo: Between 10:00 and 11:30 hrs. Photographer: Chris Jeanes, JRT Terminal Manager Description: Another view of the containers seen above in Photo 5. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Jefferson Railport Terminal City: Vidor County/Parish: Orange State: Texas Photo No. 6 Photo File Name: IMG2463 Date of Photo: 11/05/2024 Time of Photo: Between 10:00 and 11:30 hrs. Photographer: Chris Jeanes, JRT Terminal Manager Description: View of drip pad that appeared to be storing oily rags and liquid inside the drum storage area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Jefferson Railport Terminal City: Vidor County/Parish: Orange State: Texas Photo No. 7 Photo File Name: IMG2467 Date of Photo: 11/05/2024 Time of Photo: Between 10:00 and 11:30 hrs. Photographer: Chris Jeanes, JRT Terminal Manager Description: View of a half-full tote containing HOH oil and seven 55-gallon drums containing unknown materials at the time of the inspection. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Jefferson Railport Terminal City: Vidor County/Parish: Orange State: Texas Photo No. 8 Photo File Name: IMG2468 Date of Photo: 11/05/2024 Time of Photo: Between 10:00 and 11:30 hrs. Photographer: Chris Jeanes, JRT Terminal Manager Description: Another view of nineteen 55-gallon drums containing unknown materials at the time of the inspection in the drum storage area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Jefferson Railport Terminal City: Vidor County/Parish: Orange State: Texas Photo No. 9 Photo File Name: IMG2469 Date of Photo: 11/05/2024 Time of Photo: Between 10:00 and 11:30 hrs. Photographer: Chris Jeanes, JRT Terminal Manager Description: Another view of nineteen 55-gallon drums containing unknown materials at the time of the inspection in the drum storage area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Jefferson Railport Terminal City: Vidor County/Parish: Orange State: Texas Photo No. 10 Photo File Name: IMG2470 Date of Photo: 11/05/2024 Time of Photo: Between 10:00 and 11:30 hrs. Photographer: Chris Jeanes, JRT Terminal Manager Description: View of one of the unidentified 55-gallon drums shown to be crushed. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Jefferson Railport Terminal City: Vidor County/Parish: Orange State: Texas Photo No. 11 Photo File Name: IMG2471 Date of Photo: 11/05/2024 Time of Photo: Between 10:00 and 11:30 hrs. Photographer: Chris Jeanes, JRT Terminal Manager Description: Close-up view of the drums containing unknown materials shown to be stored on broken wooden pallets inside the drum storage area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Jefferson Railport Terminal City: Vidor County/Parish: Orange State: Texas Photo No. 12 Photo File Name: IMG3752 Date of Photo: 11/05/2024 Time of Photo: Between 10:00 and 11:30 hrs. Photographer: Chris Jeanes, JRT Terminal Manager Description: View of a 55-gallon drum storing unpunctured aerosol cans, approximately half-full, that had a hole cut into the lid of the container found inside the drum storage area. APPENDIX 2. TREATED WOOD PROFILE AND MANIFEST APPENDIX 3. OILY WASTE PROFILE AND BOL APPENDIX 4. JRT 11/6 EMAIL RESPONSE APPENDIX 5. AEROSOL DRUM PHOTO WITH NEW LID Image of aerosol can drum with new lid sent on 11/11/2024 by JRT. APPENDIX 6. JRT 11/21/24 RESPONSE