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; [The source of the trans mix is primarily from truck retains— drivers remove retain prior to loading. A secondary source is from truck rack maintenance activities.] 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[The types of trans mix is indistinguishable, in that no segregation is made, it is dependent on prior cargo and intermingled, both red dye and non-red dye. Current practice is to segregate transmix generated from maintenance activities from transmix generated by driver retains (a mix of red-dye and non red-dye).]; [Current generation rate is –2 bbls/month.] 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; [Please see attached copy of procedure NOP-STL-13 BP Pre-Load Draining.] 2. for trans mix accumulated in a tank,please provide a written description of the tank(e.g.,construction,storage capacity, age),and[Trans mix is stored only in drums at the Stockton Terminal.] a. please confirm,Tank 1501 is the trans mix tank for non-red-dyed trans mix. [Tk 1501 is a premium gasoline storage tank at the Stockton Terminal; the gauging sheet provided for Tk 1501 (dated 03/12/2019) is that for the Shore/NuStar Terminals Crockett facility which received 36.36 bbls(10,704 pounds). This material was managed as a product,not trans mix.]; 3. please confirm that only red-dyed diesel trans mix is accumulated in containers. [Could also be non-red dye, and/or a mixture as indicated above.] 2. How does red-dyed diesel impact the manageability of the trans mix as an excluded recyclable material? [The presence of red-dye diesel did not affect the manageability of the trans mix as an ERM; it went to Golden Gate Petroleum for re-refining.] 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[Golden Gate Petroleum received both red-dyed and non-red-dyed at their facility located at 8285 Brentwood Blvd in Brentwood,California, III-1