COMPLIANCE INFO_2020 - Laserfiche WebLink

Home Browse Search

ATTACHMENT I Therefore,pursuant to EPA's authority under Section 3007(a) of RCRA,NuStar is requested to submit to EPA the following information: 1. Based on information gathered by EPA during the February 18,2020 CEI,NuStar generates trans mix (may also be written as transmix)which at the time of the inspection is reportedly managed by NuStar as an"excluded recyclable material." a. Provide a written description of how trans mix is managed by NuStar including the following information: i. source(s)of trans mix; ii. types of trans mix generated(e.g.,red-dyed diesel mixture,non-red-dyed diesel mixture)including the average amount of each type of trans mix generated on a monthly or yearly basis, and iii. the method(s)utilized by NuStar to manage each type of trans mix on-site(i.e., in above or below storage tanks and/or containers). 1. provide a written description of the process used to determine when trans mix is accumulated in a tank or container; 2. for trans mix accumulated in a tank,please provide a written description of the tank(e.g., construction, storage capacity, age), and a. please confirm, Tank 1501 is the trans mix tank for non-red-dyed trans mix. 3. please confirm that only red-dyed diesel trans mix is accumulated in containers. 2. How does red-dyed diesel impact the manageability of the trans mix as an excluded recyclable material? 3. How are the different types of trans mix managed off-site by the facilities which receive each type of trans mix generated by NuStar? a. provide the facility name(s)and address(es)where red-dyed diesel trans mix is transferred from the Stockton,California facility to the receiving facility, and how is the red-dyed trans mix managed at the receiving facility, and b. provide the facility name(s)and address(es)where non-red-dyed diesel trans mix is transferred from the Stockton, California facility to the receiving facility, and how is the non-red-dyed trans mix managed at the receiving facility(ies). For example, on April 20,2020,NuStar provided a weighmaster certificate,No. 1180 dated April 4,2018. The destination facility is identified as Shore Terminals,LLC(Shore Terminals), 90 San Pablo Avenue,Crockett, CA 94525. What does Shore Terminals do with the non-red-dyed trans mix. 4. On February 19, 2020, Garrett Backus, San Joaquin County,Environmental Health Department provided NuStar with the requirements for a material such as trans mix to be classified as an excluded recyclable material. One of the requirements is that the generator of the excluded recyclable material must be able to demonstrate that the trans mix is being transferred to a petroleum refinery and made into a product(see California Health and Safety Code 25143.2(d)(2)(D) and 25144(a)(4)). If none of the facilities where NuStar ships its trans mix to are petroleum refineries,how is NuStar able to classify the trans mix as an excluded recyclable material(see Item 3 above)? 5. Provide copies of NuStar Standard Operating Procedures (SOPS)the company had in place at the time of the CEI regarding the management of trans mix at the Stockton,California facility. 6. Referencing NuStar's April 20,2020 and April 24,2020 response to EPA's April 2,2020 NOV,NuStar provided a figure of 10,240 pounds (lbs) of trans mix that was on-site on April 3,2018. Additionally, NuStar provided a figure of 1,470(5 X 294)lbs of trans mix which represented the trans mix containers I-1