Document xjDLB4rVaJzqYVJYGL4nr8pNm

Inspection Date(s): Time: Program: Regulatory Program(s): If Access is Denied: REGION 10 Enforcement Division INSPECTION REPORT 04/26/2021 - 04/26/2021 Announced: No Entry: 08:09 AM (AKT) Exit: 04:10 PM (AKT) RCRA Title 40 - ENVIRONMENTAL PROTECTION AGENCY Company Name: Facility or Site Name: Facility/Site Physical Address: (city, state, zip code) Type of Operation: Size of Facility: Length of Facility at Location: Geographic Coordinates: Mailing address: (Secondary Address) (city, state, zip code) County: Tesoro Alaska Company, LLC TESORO ALASKA COMPANY LLC - KENAI REFINERY 54741 ENERGY WAY KENAI, AK 99611 Petroleum Refinery 135 acres within the fence line area Since 1969 60.683603, -151.367204 Mr. Cameron Hunt, Plant Manager P.O. Box 3369 54741 Energy Way crhunt@marathonpetroleum.com Kenai, AK 99611 Facility/Site Identifier: Media Number: NAICS: AKD048679682 Unpermitted Facility 324110 - Petroleum Refineries Lead Inspector: Jon Jones Jones, Jon REGION 10 Digitally signed by Jones, Jon Date: 2021.07.12 08:40:44 -08'00' Jones.Jon@epa.gov (907) 271-6329 Additional Persons Participating in Inspection: Supervisor Review: Jen Sullivan Jennifer A Sullivan REGION 10 Digitally signed by Jennifer A Sullivan Date: 2021.07.12 11:15:34 -07'00' Sullivan.Jennifer.A@epa.gov SECTION I - INTRODUCTION Purpose of the Inspection/Objective Type of inspection: CEI - Compliance Evaluation Inspection (206) 553-6978 This was a Resource Conservation and Recovery Act (RCRA) inspection. The facility was inspected to ensure 1 of 20 TESORO ALASKA COMPANY LLC KENAI REFINERY Inspection Date(s): 04/26/2021 - 04/26/2021 compliance with standards for hazardous waste generators and universal waste management (40 C.F.R. Part 262 through 273) and used oil management (40 C.F.R. Part 279). The inspection was conducted as part of a Core Program requirement for FY 2021. Attendees Title Name Lead Inspector Jon Jones Contingency Planner Gerald Warrick Environmental Leah Vik Administrator Environmental Amanda Health & Safety Millay Environmental Marcus Health & Safety Garvin Manager Environmental Michael Supervisor Harper Phone 9072716329 (907) 2528946 (907) 7763819 (907) 7764225 (409) 7501179 Email Jones.Jon@epa.gov Present in Opening Conf. Yes gtwarrick@marathonpetroleum.com Yes ltvik@marathonpetroleum.com Yes amillay@marathonpetroleum.com Yes megarvin@marathonpetroleum.com Yes Present in Closing Conf. Yes Yes Yes No Yes (907) 776- mdharper@marthonpetroleum.com Yes Yes 3599 Opening Conference EPA lead Inspector Jon Jones arrived at the Tesoro Alaska Company, LLC - Kenai Refinery at 08:09 AM (AKT) on 04/26/2021 for an inspection. I presented my credentials to Gerald Warrick and informed him that this was an EPA RCRA inspection. The table above presents all the inspection opening and closing conference participants. During the inspection I looked at the facility's processes, in addition to hazardous waste management practices, generation points, and accumulation areas. I looked for wastes that facility representatives had not yet identified or designated as hazardous. I also observed the facility's universal waste and used oil management. Only those areas in which I observed areas of concern or noted other pertinent issues are discussed in this inspection report. Facility/Site Description Tesoro Alaska Company, Kenai Refinery (hereafter referred to as Tesoro, Refinery or facility) is a petroleum refinery located in an industrial area with no nearby residential or other non-commercial properties. Facility Info Operating Hours 24/7, 365 with 12-hour shifts Number of employees Approximately 231 What type of generator facility notified? Large Quantity Generator (LQG) 2 of 20 TESORO ALASKA COMPANY LLC KENAI REFINERY Inspection Date(s): What type of generator facility verified as? LQG verified by Mr. Gerald Warrick, Contingency Planner Weather Conditions Cool and sunny Safety Training No Provided to Inspector(s)? Process Description 04/26/2021 - 04/26/2021 According to Mr. Warrick, the facility is a petroleum refinery that began operating in 1969. Mr. Warrick explained the facility operations to me as follows: Tesoro's Kenai refinery facility receives crude oil from Tesoro's Kenai Pipeline (KPL) Company or from two pipelines from platforms in Cook Inlet. Tank 11 is the refinery's "charge tank" which is the introduction point for all crude oil processed at the facility. From Tank 11, crude oil is heated and flash-evaporated in the Crude Unit. From there, the crude goes to the Crude Tower. According to Plant Operations representatives, the following occurs in the Crude Tower: Bottoms are sent to the vacuum unit for processing, in which the bottoms are heated and fractionated into various products. Atmospheric gas oil is removed and sent to the hydrocracker. #2 diesel is sent to the distillate desulfurization unit (DDU). Jet A and ADF are removed and sent to the DDU. Lighter naphthas, LPG, methane and ethane are taken from the top and sent to the PRIP isomerization plant to convert these straight-chain molecules into higher-octane branched molecules. Heavier naphthas are sent to the catalytic reformer. Catalytic reforming is a chemical process used to convert petroleum refinery naphtha's, typically having low-octane ratings, into high-octane liquid products called reformates which are components of high-octane gasoline. In so doing, the process produces very significant amounts of byproduct hydrogen gas for use in several other processes. Other byproducts are small amounts of methane, ethane, propane, and butanes. The LPG plant uses simple distillation to separate isobutene and lighter components. This is a noncatalytic process, and wastes are generated only during maintenance. The Hydro-cracker takes atmospheric gas oil from the Crude Tower and Vacuum Unit. It uses high pressure and hydrogen to convert larger molecules into various smaller components which are generally used to make jet fuel. Wastes are generated during maintenance turn-around periods and include hydrotreater catalysts (listed wastes). The DOU desulfurizes diesel fuel. This catalytic process converts elemental sulfur to hydrogen sulfide. The hydrogen plant produces hydrogen using a natural gas and steam feed, splitting off hydrogen with a catalyst. The DIB (de-isobutane) plant takes LPG off-gas from the plant and separates out the CS and heavier components for fuel blending. The amine unit absorbs hydrogen sulfide and sends it to the sulfur 3 of 20 TESORO ALASKA COMPANY LLC KENAI REFINERY Inspection Date(s): recovery unit to make elemental sulfur, which is then sold. 04/26/2021 - 04/26/2021 I asked if there had been any changes or modifications to the refinery since the last inspection on July 26, 2018. Messrs. Warrick and Harper told me about the following changes/modifications: The facility was procuring two Rain-for-rent tanks for an upcoming project on the API slab The facility completed a September 2020 turn-around The facility's satellite control room was removed from the process area and a new control center was built outside the process area and finished in March 2021. Building(s) Building/Area API slab Surface Impoundment Building Fabrication Shop Carpenter Shop NE corner by insulator door Instrumentation and Electrical Shop Mechanic Maintenance Shop New Hazardous Waste Pad SE corner of pad Non-hazardous waste storage Refinery Lab Lab storage supply room Acids/Corrosives locker Refinery Process Area Warehouse Process Description Central Accumulation Area (CAA) CAA Satellite Accumulation Area (SAA) CAA Heat exchanger bundle cleaning area Product quality, water quality lab SAA SECTION II - OBSERVATIONS AND RECORDS REVIEW Observations Area of Concern No No Yes Yes Yes No No Yes Yes No Yes Yes Yes No No Building: Fabrication Shop Contains CBI: No Observation #: JJ1-OB-002 Date/Time: 04/26/2021 While inspecting the Fabrication Shop, I saw some work gloves in a trash receptacle. The work gloves looked like they were made with a combination of both man-made materials and leather parts. I explained to Messrs. Warrick and Harper that welding accessories, such as leather chaps and gloves, when tested by other facilities, using the Toxicity Characteristic Leaching Process (TCLP) testing method have been failing for chromium (D007). I asked if they knew how many pairs of leather gloves were provided to Tesoro employees each year and both gentlemen said they would need to check with the issuing department in the Warehouse. I told both gentlemen they may want to make a hazardous waste determination on the leather items issued/provided to Tesoro personnel. At the time this report was written, no information was provided to me by the facility regarding the 4 of 20 TESORO ALASKA COMPANY LLC KENAI REFINERY Inspection Date(s): number of leather gloves that are issued/provided to Tesoro personnel. 04/26/2021 - 04/26/2021 Photo(s) 1. Observation_Image-202104261054505450326188.jpg Building: Fabrication Shop/Carpenter Shop Contains CBI: No Observation #: JJ1-OB-004 Date/Time: 04/26/2021 While inspecting the Carpenter Shop, I saw a one-gallon can of Rust-Oleum, oil-based coating that was on a work bench. I saw about one inch of paint in the bottom of the container that was more solid than liquid, and still exhibited a strong solvent odor. Mr. Warrick said that they just dry out the paint when the paint cans are "RCRA Empty", but he said this paint can didn't look "RCRA Empty." At the time of the inspection, the container was not closed and appeared to me to have been left open to evaporate and dry out. . There was not a hazardous waste, risk, or accumulation state date label on the paint can. I asked for a copy of the Safety Data Sheet (SDS)for the paint and was provided with a copy prior to departing the facility. According to the information contained within the SDS, the paint has a flash point of 40 C (104 F) and is ignitable (D001). Mr. Harper followed up with a response letter that was provided as an attachment in an email dated 05/06/2021. The waste paint identified in the Carpenter Shop was addressed with the following response: "The one-gallon (dry) oil-based paint can was removed and disposed of as a non-hazardous material. Discussions were had with the Fabrication Shop employees that paint cans need to be RCRA empty and dry before disposal." Photo(s) 1. Observation_Image-202104261127402740246218.jpg 2. Observation_Image-202104261127512751282040.jpg 3. Observation_Image-20210426112808288258566.jpg Building: Fabrication Shop/NE corner by insulator door Contains CBI: No Observation #: JJ1-OB-003 Date/Time: 04/26/2021 While in the Fabrication Shop, I saw a 55-gallon container located in the satellite accumulation area (SAA). According to Mr. Warrick, the facility manages the 55-gallon container as a hazardous waste SAA container to accumulate spent sandblast media. He said once full, it gets tested. While still in the Fabrication Shop, Messrs. Warrick and Harper took me over to the sandblast cabinet. There was a sandblast air filter system adjacent to the blast cabinet and beneath the filtering system I saw a 15-gallon container affixed to the sandblast air filter. Mr. Warrick said the 15-gallon container was also a SAA container. Mr. Warrick said that when full, the 15-gallon satellite container is emptied into the 55-gallon SAA container. At the time of the inspection, the 55-gallon container was in an area that was clearly delineated with yellow floor markings and signage indicating that it was a SAA. The hazardous waste marking on the container was also not marked with an accumulation start date which is indicative of being a SAA container. I asked Mr. Warrick when the last time was that the 55-gallon container was moved to the CAA. He told me that he would have to check and get back with me. Mr. Harper followed up with a response letter that was provided as an attachment in an email dated 5 of 20 TESORO ALASKA COMPANY LLC KENAI REFINERY Inspection Date(s): 04/26/2021 - 04/26/2021 05/06/2021. The waste sandblast media identified in the Fabrication Shop was addressed with the following response: 55-gallon drum removed from SAA to hazardous waste accumulation slab on 4/27/2021. Samples from both SAA drums were sent out for RCRA TCLP metals analysis on 4/27/2021 (see photos 2a and 2a-2). Small drum was checked for content volume. Only a small amount of powder was observed (see photo 2b). Total contents of both drums were less than 55 gallons. Mr. Harper followed up with another email dated 05/14/2021. In that email Mr. Harper stated, "We have additional follow up to the Marathon Kenai Refinery April 26, 2021 RCRA Inspection. One of the items identified during the inspection and discussed during the close out meeting was two SAA drums of spent sandblast media in the fabrication shop. During the close out meeting we had decided to analyze the media in both drums to determine if the material was hazardous waste. We have received the results and have determined that none of the material is characteristic for RCRA metals. We have attached the results for your reference." Photo(s) 1. Observation_Image-20210426110820820343944.jpg 2. Observation_Image-20210426110945945306544.jpg 3. Observation_Image-20210426111003103247394.jpg 4. Observation_Image-202104261110201020246290.jpg Building: New Hazardous Waste Pad/SE corner of pad Contains CBI: No Observation #: JJ1-OB-006 Date/Time: 04/26/2021 While inspecting the Pad, I saw two heat exchanger bundles that, according to Messrs. Warrick and Harper, had been pressure washed to remove the solids. The solids removed from heat exchanger bundles are a K-listed (K050) waste. At the time of the inspection, I saw some waste debris and staining on the pad around the bundles which looked like it could have come off the heat exchanger bundles. Upon closer inspection, Mr. Warrick said the heat exchanger bundle on the right (toward center of pad) looked like the interior of the bundle had not been cleaned out. I asked Mr. Warrick about the volume of waste solids inside the heat exchanger bundle and he told me the volume of the material appeared to be about 10 gallons. I asked how long the heat exchanger bundles had been on the pad and Messrs. Warrick and Harper said the bundle cleaning crew cleaned them in September 2020 and that they had been on the pad since then. Mr. Harper followed up with a response letter that was provided as an attachment in an email dated 05/06/2021. The two heat exchanger bundles identified on the New Hazardous Waste Pad were addressed with the following response: The bundles were moved, cleaned, and material on waste slab was removed and containerized on 4/28/2021(see photos 4a, 4a-2, 4a-3). Photo(s) 1. Observation_Image-20210426120720720368320.jpg 2. Observation_Image-202104261207427421111520.jpg 3. Observation_Image-202104261208168161228133.jpg 6 of 20 TESORO ALASKA COMPANY LLC KENAI REFINERY Inspection Date(s): Building: Non-hazardous waste storage Contains CBI: No 04/26/2021 - 04/26/2021 Observation #: JJ1-OB-005 Date/Time: 04/26/2021 While walking around the facility, we passed by an area where non-hazardous waste asphalt was being accumulated. I observed asphalt containers off their containment area and asphalt on ground. Mr. Harper followed up with a response letter that was provided as an attachment in an email dated 05/06/2021. The non-hazardous waste asphalt drums observed off containment and asphalt on ground was addressed with the following response: The non-hazardous waste was cleaned, and dripping asphalt containers were moved onto the waste slab to lined containment on 4/27/2021 (see photo 3a and 3a-2) Photo(s) 1. Observation_Image-20210426114907497413954.jpg 2. Observation_Image-2021042611493749371265659.jpg 3. Observation_Image-2021042611502050201297047.jpg Building: Refinery Lab/Lab storage supply room/Acids/Corrosives locker Contains CBI: No Observation #: JJ1-OB-001 Date/Time: 04/26/2021 While in the Refinery lab, I went to the lab storage supply room. While in the supply room, I opened an acid/corrosives locker to inspect the contents. While inspecting the contents of the locker I saw several containers that were labeled with the words "Used Chromerge" and both Toxic and Oxidizer hazard indicators. There were two, 2.5-liter containers and a smaller 1-liter container. At the time of the inspection, Mr. Phillip Carpenter, Lab Supervisor, said it's used as a cleaning agent. Upon closer inspection, I saw that only two of the three containers were marked as "Used Chromerge." The 1liter container and one of the 2.5-liter containers were marked as "Used." According to one of the Lab Technicians, they mix up a batch of the Chromerge and then they use small amounts of it in certain lab equipment to clean certain internal sections of the equipment. According to the Lab technician I was speaking with, the Chromerge can be used multiple times until it becomes too dirty to use. That being the case, I was concerned about there being two containers of the used Chromerge in the acid/corrosives locker. My thought process being that one container might contain Chromerge that was still in-use and one might contain waste Chromerge. I asked for a copy of the SDS for the Chromerge and Mr. Carpenter provided a copy during the inspection. A cursory review of the SDS indicated that Chromerge contained 25 - 50% chromium (VI) trioxide (D007) with additional hazards including, oxidizer and corrosivity. Following the inspection, I sent an email to Mr. Harper requesting the following information: List of each piece of lab equipment where Chromerge is used. Provide any Chromerge mixing instructions or instructions for use. Provide any lab standard operating procedures (SOP) in place for the use of Chromerge. Provide frequency of use in the lab, how long the used Chromerge has been in the locker and the date it was last generated and shipped out. If you find that it was previously disposed of in a Labpack, please include a copy of the disposal 7 of 20 TESORO ALASKA COMPANY LLC KENAI REFINERY Inspection Date(s): paperwork. 04/26/2021 - 04/26/2021 Mr. Harper followed up with a response letter that was provided as an attachment in an email dated 05/06/2021. The containers of Chromerge observed in the lab storage supply room acid/corrosives locker were addressed with the following response: Chromerge solutions in storage room were relabeled for clarification on 4/29/2021 (see photo 1c). o These solutions are still in use by the lab and are not considered a waste. The solution is used and transferred back into the bottles until such time that a lab technician has determined it is no longer effective. o Chromerge is used in the following lab equipment: densitometers and Zeituchs Cross-Arm size 1-9 viscometer tubes and Ubbelohde size 50 & 100 viscometer tubes o Chromerge mixing instructions are taken from the package labeling (see photo 1d) o The Lab does not have a Standard Operating Procedure (SOP) specifically for Chromerge use. The file `Viscosity, Cleaning and Verification' is the checklist for the yearly viscosity bath cleaning Process (attachment 4). o Frequency of use in viscometers is once per year. Frequency in densitometers is "as-needed". The Lab does not have documentation for when the identified "used" Chromerge was put into use. o We have no records of hazardous waste labpack Chromerge solution being disposed of in the last three years. Photo(s) 1. Observation_Image-20210426100342342276262.jpg 2. Observation_Image-2021042610050757294519.jpg 3. Observation_Image-202104261018101810280188.jpg Records Review Record: Inspections AOC: No Ref #: JJ1-RR-002 Reviewed By: Jon Jones Reviewed Date: 06/29/2021 I reviewed the facility's weekly hazardous waste inspections while at the facility and identified a discrepancy with the date of an inspection. This was addressed by the facility following the inspection. Mr. Harper followed up with a response letter that was provided as an attachment in an email dated 05/06/2021 and included a copy of weekly inspection that contained wrong date and included annotation that it was for a different day (08/24/20) was addressed with the following response: This record request was received via email on April 27, 2021. The August 24, 2020 RCRA weekly inspection form has been included (attachment 1). Also included as attachment 2 is the August 24, 2020 email correspondence from Mr. Benjamin Taylor (contractor with Trihydro). This correspondence includes the original forms from the inspections conducted on the 24th (including the mis-dated weekly inspection form). Further investigation by the facility security officers indicate that Mr. Taylor was not onsite at the refinery on October 24, 2020 (a Saturday). Security officers confirmed there was no record in the electronic security system of Mr. Taylor entering the facility on that day. A copy of this inquiry has been included as attachment 3. I also observed during this document review that following the weekly inspection that occurred on 05/02/2019, the time of the inspection was no longer being documented on the weekly hazardous waste inspection logs. A copy of the 05/02/2019 weekly inspection log was provided, showing that the time of the inspection was documented on the inspection log and a copy of the 05/09/2019 weekly inspection log was provided, showing 8 of 20 TESORO ALASKA COMPANY LLC KENAI REFINERY Inspection Date(s): 04/26/2021 - 04/26/2021 that the time of the inspection was no longer being documented on the inspection log. Document(s) 1. 5.2.19 weekly.pdf 2. 5.9.19 HW weekly.pdf SECTION III - AREAS OF CONCERN The presentation of areas of concern does not constitute a formal compliance determination or violation. Building: Fabrication Shop JJ1-OB-002 While in the Fabrication Shop, I saw some gloves in the trash that may have contained leather parts. Leather gloves and welding accessories, made of leather, such as welding chaps, when tested, using the Toxicity Characteristic Leaching Process (TCLP) testing method have been failing for chromium (D007). At the time of the inspection, the facility had not made a hazardous waste determination. Area: Citation: Sub-area: Section: Building: Fabrication Shop JJ1-OB-004 While in the Carpenter Shop, I saw a one-gallon can of RustOleum, oil-based coating that was on the work bench. At the time of the inspection, the container was not closed and appeared to be left open to evaporate and dry out. I observed the contents of the container and saw that it contained approximately one inch of waste paint in the bottom of the container and was not "RCRA Empty." Mr. Warrick stated , during the inspection, that the container was not "RCRA Empty." Area: Carpenter Shop Citation: Sub-area: Section: 9 of 20 TESORO ALASKA COMPANY LLC KENAI REFINERY Inspection Date(s): Building: Fabrication Shop JJ1-OB-003 Area: NE corner by insulator door Mr. Warrick said that when full, the 15-gallon satellite container of spend sandblast media is emptied into another 55-gallon SAA container of spent sandblast media. Citation: Building: New hazardous waste pad Area: SE corner of pad JJ1-OB-006 While inspecting the New hazardous waste pad, I saw two heat exchanger bundles that had been pressure washed to remove the solids (K050). At the time of the inspection, I saw this K050 waste on the pad around the bundles. Citation: Mr. Warrick said the bundle on the right (toward center of pad) looked like the interior of the bundle had not been cleaned out. He said the bundle cleaning crew cleaned them in September 2020. Building: Refinery Lab JJ1-OB-001 Area: Lab storage supply room There were two, 2.5 liter containers and a smaller 1 liter container. Upon closer inspection, I saw that only two of the three containers were marked as "Used Chromerge." The 1-liter container and one of the 2.5-liter containers were marked as "Used." According to one of the Lab Technicians, they mix up a batch of the Chromerge and then they use small amounts of it in certain lab equipment to clean certain internal sections of the equipment. According to the Citation: 10 of 20 04/26/2021 - 04/26/2021 Sub-area: Section: Sub-area: Section: Sub-area: Acids/Corrosives locker Section: TESORO ALASKA COMPANY LLC KENAI REFINERY Inspection Date(s): Lab technician I was speaking with, the Chromerge can be used multiple times until it becomes too dirty to use. That being the case, I was concerned about there being two containers of the used Chromerge in the acid/corrosives locker. My thought process being that one container might contain Chromerge that was still in-use and one might contain waste Chromerge. SECTION IV - FOLLOW UP I observed no follow up at the time of the inspection. 04/26/2021 - 04/26/2021 Closing Conference I thanked everyone for their time and cooperation during the inspection and began a review of the areas of concern that I observed during my walk-through inspection and paperwork review while at the facility. I also explained the follow-up process that would take place after the inspection. SECTION V - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS No sampling was conducted. 11 of 20 TESORO ALASKA COMPANY LLC KENAI REFINERY Inspection Date(s): SECTION VI - LIST OF APPENDICES Photo Log [Title] Observation_Image202104261054505450326188.jpg 04/26/2021 10:54 AM (AKT) Jon Jones Fabrication Shop No CBI No PII View of waste gloves in the trash. [Title] Observation_Image202104261127402740246218.jpg 04/26/2021 11:27 AM (AKT) Jon Jones Fabrication Shop/Carpenter Shop No CBI No PII View of a gallon can of Rust-Oleum, oil-based paint/coating that was on the work bench. 04/26/2021 - 04/26/2021 12 of 20 TESORO ALASKA COMPANY LLC KENAI REFINERY Inspection Date(s): [Title] Observation_Image202104261127512751282040.jpg 04/26/2021 11:27 AM (AKT) Jon Jones Fabrication Shop/Carpenter Shop No CBI No PII Close-up view of the label on a gallon can of Rust-Oleum, oil-based paint/coating that was on the work bench. [Title] Observation_Image20210426112808288258566.jpg 04/26/2021 11:28 AM (AKT) Jon Jones Fabrication Shop/Carpenter Shop No CBI No PII Close-up view of a gallon can of Rust-Oleum, oil-based paint/coating that was on the work bench 04/26/2021 - 04/26/2021 13 of 20 TESORO ALASKA COMPANY LLC KENAI REFINERY Inspection Date(s): [Title] Observation_Image20210426110820820343944.jpg 04/26/2021 11:08 AM (AKT) Jon Jones Fabrication Shop/NE corner by insulator door No CBI No PII View of a 15-gallon satellite accumulation container that was being used to accumulate waste sandblast media. [Title] Observation_Image20210426110945945306544.jpg 04/26/2021 11:09 AM (AKT) Jon Jones Fabrication Shop/NE corner by insulator door No CBI No PII View of a 55-gallon SAA container, holding waste sandblast media, in the SAA of the Fabrication Shop. 04/26/2021 - 04/26/2021 14 of 20 TESORO ALASKA COMPANY LLC KENAI REFINERY Inspection Date(s): [Title] Observation_Image20210426111003103247394.jpg 04/26/2021 11:10 AM (AKT) Jon Jones Fabrication Shop/NE corner by insulator door No CBI No PII Close-up (Blurry) view of the label on the 55gallon SAA container of waste sandblast media. [Title] Observation_Image202104261110201020246290.jpg 04/26/2021 11:10 AM (AKT) Jon Jones Fabrication Shop/NE corner by insulator door No CBI No PII Another close-up view of the label on the 55gallon SAA container of waste sandblast media. 04/26/2021 - 04/26/2021 15 of 20 TESORO ALASKA COMPANY LLC KENAI REFINERY Inspection Date(s): [Title] Observation_Image20210426100342342276262.jpg 04/26/2021 10:03 AM (AKT) Jon Jones Lab storage supply room/Acids/Corrosives locker No CBI No PII View of the three containers holding Chromerge. Seen in the photo here is a 1-Liter bottle of "Used Chromerge" in the back, a 2.5Liter bottle of Chromerge in the middle, and another 2.5-Liter bottle of "Used Chromerge seen in the front. [Title] Observation_Image2021042610050757294519.jpg 04/26/2021 10:05 AM (AKT) Jon Jones Lab storage supply room/Acids/Corrosives locker No CBI No PII This is another view showing a 1-Liter bottle of "Used Chromerge" in the back, a 2.5-Liter bottle of Chromerge on the right, and another 2.5-Liter bottle of "Used Chromerge seen on the left. 04/26/2021 - 04/26/2021 16 of 20 TESORO ALASKA COMPANY LLC KENAI REFINERY Inspection Date(s): [Title] Observation_Image202104261018101810280188.jpg 04/26/2021 10:18 AM (AKT) Jon Jones Lab storage supply room/Acids/Corrosives locker No CBI No PII This is another view showing the labeling on a 1-Liter bottle of "Used Chromerge" in the back, a 2.5-Liter bottle of Chromerge on the right, and another 2.5-Liter bottle of "Used Chromerge seen on the left. [Title] Observation_Image20210426120720720368320.jpg 04/26/2021 12:07 PM (AKT) Jon Jones New hazardous waste CAA pad/SE corner of pad No CBI No PII View of two heat exchanger bundles as well as debris and staining on the pad around the bundles. 04/26/2021 - 04/26/2021 17 of 20 TESORO ALASKA COMPANY LLC KENAI REFINERY Inspection Date(s): [Title] Observation_Image202104261207427421111520.jpg 04/26/2021 12:07 PM (AKT) Jon Jones New hazardous waste CAA pad/SE corner of pad No CBI No PII Close-up view of the debris on the pad around the heat exchanger bundles. [Title] Observation_Image202104261208168161228133.jpg 04/26/2021 12:08 PM (AKT) Jon Jones New hazardous waste CAA pad/SE corner of pad No CBI No PII Another view of two heat exchanger bundles. 04/26/2021 - 04/26/2021 18 of 20 TESORO ALASKA COMPANY LLC KENAI REFINERY Inspection Date(s): [Title] Observation_Image20210426114907497413954.jpg 04/26/2021 11:49 AM (AKT) Jon Jones Non-hazardous waste storage No CBI No PII Non-hazardous waste asphalt seen here on the left in the photo. [Title] Observation_Image2021042611493749371265659.jpg 04/26/2021 11:49 AM (AKT) Jon Jones Non-hazardous waste storage No CBI No PII Close-up view of the Non-hazardous waste asphalt. 04/26/2021 - 04/26/2021 19 of 20 TESORO ALASKA COMPANY LLC KENAI REFINERY Inspection Date(s): [Title] Observation_Image2021042611502050201297047.jpg 04/26/2021 11:50 AM (AKT) Jon Jones Non-hazardous waste storage No CBI No PII Another view of the Non-hazardous waste asphalt. 04/26/2021 - 04/26/2021 Document Log Document Type Document Name Contains Contains Uploaded By CBI PII Inspection Reports Field_Notes_AKD048679682v1.0.pdf No No Jon Jones Other - Safety Data Pro QT 2PK Safety Yellow SDS.pdf No No Jon Jones Sheet Other - Safety Data Sheet Chromerge SDS.pdf No No Jon Jones Records Review ERP and quick reference guide.pdf No No Jon Jones Records Review 5.2.19 weekly.pdf No No Jon Jones Records Review 5.9.19 HW weekly.pdf No No Jon Jones Records Review Marathon Kenai Refinery Waste No No Jon Jones Mgmt Plan.pdf Communications Att 1 8-24-20 Weekly RCRA Form.pdf No No Jon Jones Communications Att 3 - Security.pdf No No Jon Jones Communications Att 4 - Viscosity Cleaning and Verification.xlsx No No Jon Jones Communications Response to EPA Inspection 4-26- No No Jon Jones 2021.pdf Communications Email from Mike.pdf No No Jon Jones Communications Fab Shop Sandbast Sand Waste No No Jon Jones Determination.pdf Date Received 06/29/2021 06/29/2021 06/29/2021 06/29/2021 06/29/2021 06/29/2021 06/29/2021 06/29/2021 06/29/2021 06/29/2021 06/29/2021 06/29/2021 06/29/2021 20 of 20