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From: Schofield,John [mailto:Schofield.John(@epa.gov] <br /> Sent:Tuesday, March 17, 2020 2:01 PM <br /> To: Smith, Ray<Ray.Smith(@nustarenerg)1.com> <br /> Subject: [EXTERNAL] Follow-up to earlier call <br /> Ray, <br /> Below is the draft language from the draft inspection report. Note: Until the report is finalized, the <br /> language provided is subject to change. <br /> Inspector Schofield observed in the facility s central accumulation area (CAA) one, closed, <br /> properly labeled 55-gallon metal container of flammable solid waste gloves, rag. etc. Also, <br /> within the CAA were approximately 10 to 15 55-gallon metal containers labeled "Materials <br /> for Recycle, Trimix, Gas, Diesel, Ethanol, 4-3-18, Red" (Attachment 2-Photographs I and 2). <br /> The trimix containers were dated 4-3-18. Finding/Observation 1:NuStar has not recycled or <br /> reused 75% by weight or volume of the material within one calendar year, therefore the <br /> facility is speculatively accumulating RCRA hazardous waste (D001 and/or D018) in <br /> containers (22 CCR§66260.10[40 CFR§261.1(c)(8)J). Therefore, the containers of trimix <br /> observed are subject to applicable hazardous waste management requirements including but <br /> are not limited to waste determination, storage time limits, weekly inspection, and container <br /> management requirements. <br /> If you or other NuStar representatives have questions concerning the above, please do not hesitate <br /> to contact me. <br /> regards, <br /> John <br /> ************************************** <br /> John Schofield <br /> U. S. Environmental Protection Agency <br /> Region 9 <br /> Enforcement and Compliance Assurance Division <br /> Air, Waste and Analysis Branch, ENF-2-2 <br /> 75 Hawthorne Street <br /> San Francisco, CA 94105 <br /> (415) 972-3386 <br /> (415) 947-3530 (fax) <br /> schofield.john(a epa.gov <br /> ************************************* <br /> NOTE: This email, including any attachments, may contain material that is confidential, privileged and/or <br /> attorney work product and is for the sole use of the intended recipient. Any review, reliance or <br /> distribution by others or forwarding without expressed permission is strictly prohibited. If you are not the <br /> intended recipient, please contact the sender and delete all copies. <br />