Document 0JjkZgM81zJg7M0B0Knv8zQXd
Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection
EPA REGION 6 Enforcement Division INSPECTION REPORT 04/16/2024 08:35 (CT) 04/16/2024 12:19 (CT) RCRA Focused Compliance Inspection (FCI)
Announced: No Access: Granted
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
Environmental Response Services, Inc. (ERS)
LAR000026534
8583 Joe Ledoux Rd
Lake Charles, LA 70605
Calcasieu Parish
Very Small Quantity Generator (VSQG)
None
ERS is a VSQG and transporter of hazardous waste and a generator, transfer facility, and transporter of used oil. The facility has an on-site oil-water separator and sells most of their used oil for a profit. They also receive nonhazardous waste, universal waste, medical waste, and APHIS regulated garbage. 30.09548, -93.27908
Additional Persons Participating in Inspection:
Name
Title
Organization
Elizabeth Pham
Inspector
EPA REGION 6
Sandesh Thapa
Inspector
EPA REGION 6
Anshul Paripati
Contractor
Eastern Research Group (ERG)
Email Pham.elizabeth@epa.gov Thapa.sandesh@epa.gov Anshul.Paripati@erg.com
Phone (214) 665-8354 (214) 665-2265 (571) 535-1503
Lead Inspector: Cameron Tanaka
Cameron Tanaka Date: 2024.07.25 16:07:30 -04'00' Digitally signed by Cameron Tanaka 07/25/2024
ERG
Cameron.Tanaka@erg.com
(703) 633-1632
ext. 11632
Page 1 of 10
Environmental Response Services, Inc.
Inspection Date(s): 04/16/2024
SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection Type of inspection: Focused Compliance Inspection (FCI)
The Port of Lake Charles 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, port related 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 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 RCRA Inspector/ Contractor/ERG Inspector/Enforcement Officer/EPA Region 6 Inspector/Enforcement Officer/EPA Region 6
Name
Phone
Email
Opening Closing Conf. Conf.
Cameron Tanaka (703) 633-1632 Cameron.Tanaka@erg.com Yes
No
ext. 11632
Anshul Paripati (571) 535-1503 Anshul.Paripati@erg.com Yes
Yes
Elizabeth Pham (214) 665-8354 Pham.elizabeth@epa.gov Yes
Yes
Sandesh Thapa (214) 665-2265 Thapa.sandesh@epa.gov Yes
Yes
Page 2 of 10
Environmental Response Services, Inc.
Inspection Date(s): 04/16/2024
Facility General Description
Tenant/Area Environmental Response Services, Inc. (ERS)
Inspection Date
04/16/24
Process Description Environmental Response Services, Inc. (ERS) is a VSQG and transporter of hazardous waste. ERS is a generator, transfer facility, and transporter of used/waste oil. The facility has an on-site oil-water separator and sells most of their used oil for a profit. They also receive non-hazardous waste and universal waste, such as batteries, e-waste, oily sludge, fluorescent lamps, and printer cartridges. They receive APHIS regulated garbage, including incinerator ash, that is sterilized at another unrelated facility. They also accept medical waste. They generate hazardous waste on site in the form of residual liquids from punctured aerosol can. They do not have a MARPOL COA.
Area of Concern
Yes
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Environmental Response Services, Inc.
Inspection Date(s): 04/16/2024
SECTION II - OBSERVATIONS
Tenant: Environmental Response Services, Inc. (ERS)
Section: 2.1
Date: 04/16/24, 8:35 AM Contains AOC: Yes Contains CBI: No
Lead Inspector: Cameron Tanaka
Attendees: Neil Clark (President) and Forress Clark (Secretary/Treasurer)
ERS is a VSQG and transporter of hazardous waste. ERS is also a generator, transfer facility, and transporter of used oil. They have two vacuum trucks that are used for transportation of liquid wastes. ERS only services facilities, vessels, or docks by road. They are registered under the EPA ID LAR000026534 as a VSQG. They are currently undergoing LDEQ enforcement for leaking drums and tanks and other issues (see Appendix 2).
They receive waste and used oil from land and marine facilities. Besides used oil, they also transfer and transport sump clean out materials, oil water filters, maintenance sludge, and oily waste filters and tank bottoms. The facility has an on-site oil-water separator process and sells most of the used oil they receive or generate on site for a profit. This process separates their oily slop into oil, water, and sludge. The slops are held in a 20,000-gallon slop tank before going into the separator process. ERS typically sells their used oil to H&H Chemical Company in Lake Charles. Every 1-2 years they remove the sludge from the separator process and transport it off site as non-hazardous waste to Republic in Winnie, Texas for deep well injection. They occasionally run TCLP tests for these sludges. Partial loads of sludge and oily water are also sent to US Ecology where US Ecology will perform testing. They have never seen this sludge or separator process waste come back as hazardous. Generally, they subcontract trucking companies for disposal of these wastes.
They also receive non-hazardous waste, such as APHIS regulated incinerator ash and garbage, e-waste, oily sludge, and printer cartridges. ERS receives universal waste including used batteries and fluorescent lamps. Universal wastes are generally sent to LEI or Veolia. Mr. Clark indicated that they send off universal wastes approximately every 6 months. Mr. Clark explained that incinerator ash is held in chemical waste roll-off boxes that also include RCRA-empty containers, containers of paint chips, and rust scale. He indicated that these wastes are sent to a chemical waste management landfill. The incinerator ash, paint chips, and rust scale material are sampled about once a year. Their APHIS regulated garbage is sterilized at an unrelated facility. ERS also accepts medical waste. They generally try to reject any waste that they are not equipped to handle, such as hazardous waste. For APHIS regulated garbage, which are received on site in supersacks, their employees have a general understanding of materials that should not be included in the supersacks, such as cans or other potentially hazardous wastes. When ERS employees can feel these materials in the supersacks they will reject the waste, though sometimes 5-gallon buckets or other small items are found in the supersacks. For these incidents, they manage the wastes on a case-by-case basis. ERS also scraps old empty metal drums and sends empty plastic drums to landfills.
They generate hazardous waste on site in the form of residual material from aerosol cans and waste paint. They keep drums on site for accumulating hazardous waste paint waste and residual materials from aerosol cans. These drums have been sent to Chemical Waste Management or Circon as they are filled in the past. When they receive waste paint, they review the SDS of the waste paint to determine if they can accept the waste. They do not perform any further analysis on waste paint received at the time of reception. They comingle all waste paints in their hazardous paint waste drum. They do not perform transfers of hazardous waste as these wastes are generated on-site by being comingled in the drum. Mr. Clark indicated that they ship off their hazardous waste approximately every 4 months, soon after it is filled up, via vacuum trucks or trucks. ERS does not maintain a MARPOL COA.
The inspection team viewed a hazardous waste manifest for non-hazardous oily water sludge and used oil
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Environmental Response Services, Inc.
Inspection Date(s): 04/16/2024
forms for reception and sale. ERS did not hold the used oil on-site for more than 35 days according to the reviewed forms. The inspection team requested copies of their most recent universal waste manifest and hazardous waste paint and residual material from aerosol cans manifest in a follow-up email from April 18 (see Appendix 3). The universal waste and hazardous waste paint and residual material from aerosol cans manifests are included as Appendix 4 and Appendix 5, respectively. There were no issues noted for these manifests. Mr. Clark also included a waste profile from Tradebe Environmental Services, LLC for their paint and aerosol liquid waste in the follow-up email (see Appendix 6). There were no issues noted for this profile. Mr. Clark also included two manifests showing collection of used oil from a land-based facility and one manifest of used oil from a vessel (see Appendix 7 and Appendix 8, respectively). There were no issues noted for these manifests. Mr. Clark indicated that they have a Spill Response Plan and that drills for spills are performed every quarter. Documentation of their most recent spill response, which was requested in the follow-up email, is included as Appendix 9.
After the opening meeting, the inspection team performed a walk through around ERS' yard. They only operate on one acre of space with waste material scattered throughout the plot. Throughout the yard, the inspection team noted over 15 containers with used oil that did not have secondary containment (see Appendix 1 - Photo 1 and 2). [AOC #1 - ERS held containers used to store used oil at their transfer facility that were not equipped with a secondary containment system - 40 CFR 279.45(d)] Mr. Clark indicated that the containers from Photo 1 were full and waiting to be sold.
Hazardous Waste Pad
In the ERS Hazardous Waste Pad area, the inspection team noted that the hazardous waste paint accumulation drum was labeled "paint" and not closed or dated (see Appendix 1 - Photo 3 and 4). In a follow up email from April 25 (see Appendix 10), Mr. Clark explained that this drum, "when inspected, did not have the lid securely closed or label on it. This drum contains paint and paint related waste from non-aerosol can generation. This is paint and thinner from emptying paint cans and jugs of paint thinner." Mr. Clark responded to this observation in his follow-up email on April 18 indicating that the drums had been closed, labeled, and dated by the end of the day on April 16 (see Appendix 3). Mr. Clark included a photograph of this waste paint drum in the follow-up email from April 25 (see Appendix 11). ERS also had waste aerosol cans that were not RCRA-empty that were not being treated as hazardous waste and they were not secured, labeled, or dated (see Appendix 1 - Photo 5). Mr. Clark responded to this observation in his follow-up email on April 18 indicating that these cans were put into a drum which was labeled and dated by the end of the day on April 16 (see Appendix 3). Similarly, a black 55-gallon drum containing unemptied aerosol cans was not treated as hazardous waste and it was not secured, labeled, or dated (see Appendix 1 - Photo 6). A red 55gallon drum containing accumulated liquids from aerosol cans was not labeled (see Appendix 1 - Photo 6). Mr. Clark responded to this observation in his follow-up email on April 18 indicating that the drums had been labeled and dated by the end of the day on April 16 (see Appendix 3). Mr. Clark included a photograph of the aerosol waste management drums with a third drum for emptied aerosol cans in his follow-up email from April 25 (see Appendix 12). He explained in the email that these drums "are related to aerosol can management. From left to right, the left drum is where we put the unpunctured cans until we get a chance to puncture them. The center drum is a closed top drum with the aerosol can puncturing device and vapor filter installed. This center drum is where we puncture our aerosol cans and retain the liquids until ready for disposal. The third drum labeled non-regulated are the aerosol cans which have been punctured, drained, and empty" (see Appendix 10).
General Yard Area
The inspection team also viewed a tote labeled "operational wastes" containing used oil that did not have secondary containment (see Appendix 1 - Photo 7 and 8). [see AOC #1; AOC #2 - ERS did not clearly label
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Environmental Response Services, Inc.
Inspection Date(s): 04/16/2024
containers used to store used oil with the words "Used Oil" - 40 CFR 279.22(c)(1)] A spill was observed to be coming from a drum that Mr. Clark indicated contained grease. [AOC #3 - Upon detection of a release of used oil to the environment that is not subject the requirements of part 280, subpart F of this chapter and which has occurred after the effective date of the recycled used oil management program in effect in the State in which the release is located, ERS did not perform the following cleanup steps: Clean up and manage properly the released used oil and other materials. - 40 CFR 279.22(d)(3)] The drum was picked up during the inspection (see Appendix 1 - Photo 25). Mr. Clark explained in his email from April 25 that the "Contaminated soil was removed and placed in the roll off box with the rest of the oily solids for later disposal at Chemical Waste Management this was completed before end of day 4-16" (see Appendix 10).
Oil-Water Separator Process Area
The inspection team observed a spill from ERS' used oil tank (see Appendix 1 - Photo 9 and 10). Mr. Clark explained that they have an impermeable liner buried under 2 feet of soil under this tank. The inspection team viewed used oil totes that did not have secondary containment directly outside of this lined area (see Appendix 1 - Photo 11). [see AOC #1] The facility's washout pad also had visible soil contamination surrounding it (see Appendix 1 - Photo 12). [see AOC #3]
General Waste Storage Area
The inspection team observed 40 5-gallon buckets and 14 55-gallon drums of potentially hazardous waste that had been on site for over a year according to Mr. Clark (see Appendix 1 - Photo 13). Waste determinations were not conducted on the contents of these containers. [AOC# 4 - ERS did not make an accurate determination as to whether their waste is a hazardous waste in order to ensure wastes are properly managed according to applicable RCRA regulations. - 40 CFR 262.11]. Similarly, three white drums containing "soaps" according to Mr. Clark, which had been on site for about six years, and three blue drums of unknown material without waste determinations were observed (see Appendix 1 - Photo 14). [see AOC #4]
Universal Waste Storage Area (see Appendix 1 - Photo 15)
The inspection team observed many containers of e-waste in the universal waste storage area (see Appendix 1 - Photo 16). The team also observed a bucket and a drum of used batteries in this area with universal waste labels that were not dated (see Appendix 1 - Photo 17 and 18). [AOC #5 - ERS did not provide a demonstration of the length of time that the universal waste has been accumulated from the date it becomes a waste or is received - 40 CFR 273.15(c)]. ERS also had a box of expired flares that were handled as universal waste (see Appendix 1 - Photo 19 and 20). At the time of the inspection, ERS had not made a hazardous waste determination on these flares. [AOC #6 - ERS must make an accurate determination as to whether the expired flares are a hazardous waste in order to ensure wastes are properly managed according to applicable RCRA regulations. - 40 CFR 262.11] This area contained two pallets of used batteries that had not been labelled or dated (see Appendix 1 - Photo 21). [AOC #7 - ERS did not label or mark clearly their used batteries with any one of the following phrases: "Universal Waste-Battery(ies)," or "Waste Battery(ies)," or "Used Battery(ies)." - 40 CFR 273.14(a); see AOC #5] In his follow-up email from April 18, Mr. Clark indicated that "Two pallets of Lead Acid batteries were labeled shortly after inspection and by end of day (April 16) shipped off for scrap" (see Appendix 3). The team also observed two piles of expired fluorescent lamps that were not labeled (see Appendix 1 - Photo 22). [AOC #8 - ERS did not label or mark clearly each lamp or a container or package in which such lamps are contained with one of the following phrases: "Universal Waste- Lamp(s)," or "Waste Lamp(s)," or "Used Lamp(s)." - 40 CFR 273.14(e)]. Several of the lamps were not secured in closed boxes or in structurally sound boxes [AOC #9 - ERS did not store some of the universal waste lamps in containers or packages that are structurally sound and able to prevent breakage - 40 CFR 273.13(d)(1)]. In his follow-up email from April 18, Mr. Clark indicated that these "Expired Lamps were labeled and dated 4-17"
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Environmental Response Services, Inc.
Inspection Date(s): 04/16/2024
(see Appendix 3). This area also contained 8 used oil drums without secondary containment or labels (see Appendix 1 - Photo 23 and 24). [see AOC #1 and AOC #2]
The inspection team did not observe any other areas of concern at the time of the inspection. A closing conference was conducted at approximately 12:05 PM with ERS personnel. The initial AOCs were communicated during the closing.
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Environmental Response Services, Inc.
Inspection Date(s): 04/16/2024
SECTION III - RECORDS REVIEW
No RCRA regulated records reviewed during this focused onsite inspection.
SECTION IV - APPARENT AREAS OF CONCERN
The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation. Tenant: Environmental Response Services
AOC #1 - ERS held containers used to store used oil at Citation: 40 CFR 279.45(d) their transfer facility that were not equipped with a secondary containment system.
Section: 2.1
AOC #2 - ERS did not clearly label containers used to Citation: 40 CFR 279.22(c)(1) store used oil with the words "Used Oil."
Section: 2.1
AOC #3 - Upon detection of a release of used oil to the environment that is not subject the requirements of part 280, subpart F of this chapter and which has occurred after the effective date of the recycled used oil management program in effect in the State in which the release is located, ERS did not perform the following cleanup steps: Clean up and manage properly the released used oil and other materials.
Citation: 40 CFR 279.22(d)(3)
Section: 2.1
AOC #4 - ERS did not make an accurate determination Citation: 40 CFR 262.11 as to whether their waste is a hazardous waste in order to ensure wastes are properly managed according to applicable RCRA regulations.
Section: 2.1
AOC #5 - ERS did not provide a demonstration of the length of time that the universal waste has been accumulated from the date it becomes a waste or is received.
Citation: 40 CFR 273.15(c)
Section: 2.1
AOC #6 - ERS must make an accurate determination Citation: 40 CFR 262.11 as to whether the expired flares are a hazardous waste in order to ensure wastes are properly managed according to applicable RCRA regulations.
Section: 2.1
AOC #7 - ERS did not label or mark clearly their used batteries with any one of the following phrases: "Universal Waste-Battery(ies)," or "Waste Battery(ies)," or "Used Battery(ies)."
Citation: 40 CFR 273.14(a)
Section: 2.1
AOC #8 - ERS did not label or mark clearly each lamp or a container or package in which such lamps are contained with one of the following phrases: "Universal Waste- Lamp(s)," or "Waste Lamp(s)," or "Used Lamp(s)."
Citation: 40 CFR 273.14(e)
Section: 2.1
AOC #9 - ERS did not store some of the universal
Citation: 40 CFR 273.13(d)(1)
Section: 2.1
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Environmental Response Services, Inc.
waste lamps in containers or packages that are structurally sound and able to prevent breakage.
Inspection Date(s): 04/16/2024
SECTION V - FOLLOW UP
Follow-Up Any facility follow-up items are as discussed in each facility's observations in Section II. Documents or files provided by the facilities were transmitted via email and included responses to areas of concern or provision of documents requested.
Communication Log
During and after the inspection, additional information was emailed to EPA including: 1. 04/18/24 ERS email - Neil Clark sent many descriptions of corrective actions implemented at the site and many documents requested during the inspection. 2. 04/25/24 ERS email - Neil Clark sent several photographs and descriptions of corrective actions implemented at the site.
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Environmental Response Services, Inc.
Inspection Date(s): 04/16/2024
SECTION VI - LIST OF APPENDICES Appendix 1. Photograph Log Appendix 2. LDEQ Inspection Report for ERS Appendix 3. Follow-Up Email from ERS April 18 Appendix 4. ERS Universal Waste Manifest Appendix 5. ERS Hazardous Waste Manifest Paint and Aerosol Liquid Appendix 6. ERS Profile for Paint and Aerosol Liquid Appendix 7. ERS Receipt of Used Oil from Land-based Facility Appendix 8. ERS Most Recent Spill Response Report Appendix 9. ERS Receipt of Used Oil from Vessel Appendix 10. Follow-Up Email from ERS April 25 Appendix 11. Photo of Waste Paint Drum in Follow-Up Email from ERS April 25 Appendix 12. Photo of Aerosol Can Management Drums in Follow-Up Email from ERS April 25
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APPENDIX 1. PHOTOGRAPH LOG
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 1
Location: Environmental Response Services
City: Lake Charles
County/Parish: Calcasieu
State: Louisiana
Photo File Name: DSCN7176 Date of Photo: 04/16/2024 Time of Photo: 09:28 hrs. Photographer: Anshul Paripati Description: View of two containers of used oil and one container of oily rags and filters in the ERS yard without secondary containment.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 2
Location: Environmental Response Services
City: Lake Charles
County/Parish: Calcasieu
State: Louisiana
Photo File Name: DSCN7177 Date of Photo: 04/16/2024 Time of Photo: 09:30 hrs. Photographer: Anshul Paripati Description: View of four containers labelled used oil in the ERS yard without secondary containment.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 3
Location: Environmental Response Services
City: Lake Charles
County/Parish: Calcasieu
State: Louisiana
Photo File Name: DSCN7178 Date of Photo: 04/16/2024 Time of Photo: 09:39 hrs. Photographer: Anshul Paripati Description: View of 55-gallon waste paint drum in the ERS Hazardous Waste Pad area, which was unsecured, labeled "paint," and not dated.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 4
Location: Environmental Response Services
City: Lake Charles
County/Parish: Calcasieu
State: Louisiana
Photo File Name: DSCN70179 Date of Photo: 04/16/2024 Time of Photo: 09:42 hrs. Photographer: Anshul Paripati Description: View of label on 55-gallon waste paint drum in the ERS hazardous waste pad area, which was unsecured, labeled "paint," and not dated.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 5
Location: Environmental Response Services
City: Lake Charles
County/Parish: Calcasieu
State: Louisiana
Photo File Name: DSCN7181 Date of Photo: 04/16/2024 Time of Photo: 09:45 hrs. Photographer: Anshul Paripati Description: Waste aerosol cans that were not RCRA-empty and not secured, labeled, or dated in the ERS Hazardous Waste Pad area.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 6
Location: Environmental Response Services
City: Lake Charles
County/Parish: Calcasieu
State: Louisiana
Photo File Name: DSCN7182 Date of Photo: 04/16/2024 Time of Photo: 09:47 hrs. Photographer: Anshul Paripati Description: View of two unlabeled 55-gallon containers for aerosol waste management. The red drum on the left is for puncturing aerosol cans and accumulating their liquids. The black drum on the right is for storing unemptied aerosol cans before they are punctured.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 7
Location: Environmental Response Services
City: Lake Charles
County/Parish: Calcasieu
State: Louisiana
Photo File Name: IMG_7689 Date of Photo: 04/16/2024 Time of Photo: 11:43 hrs. Photographer: Anshul Paripati Description: Overview of used oil tote labeled "operational wastes" without secondary containment in ERS' general yard area.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 8
Location: Environmental Response Services
City: Lake Charles
County/Parish: Calcasieu
State: Louisiana
Photo File Name: IMG_7690 Date of Photo: 04/16/2024 Time of Photo: 11:43 hrs. Photographer: Anshul Paripati Description: View of used oil tote labeled "operational wastes" without secondary containment in ERS' general yard area.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 9
Location: Environmental Response Services
City: Lake Charles
County/Parish: Calcasieu
State: Louisiana
Photo File Name: IMG_7692 Date of Photo: 04/16/2024 Time of Photo: 11:48 hrs. Photographer: Anshul Paripati Description: View of a spill onto the soil on top of the liner, directly in front of the wooden plank in front of the black bucket, coming from a used oil tank in ERS' oil-water separator process area.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 10
Location: Environmental Response Services
City: Lake Charles
County/Parish: Calcasieu
State: Louisiana
Photo File Name: IMG_7693 Date of Photo: 04/16/2024 Time of Photo: 11:49 hrs. Photographer: Anshul Paripati Description: Close-up of contaminated soil due to a spill coming from a used oil tank in ERS' oil-water separator process area.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 11
Location: Environmental Response Services
City: Lake Charles
County/Parish: Calcasieu
State: Louisiana
Photo File Name: IMG_7694 Date of Photo: 04/16/2024 Time of Photo: 11:50 hrs. Photographer: Anshul Paripati Description: View of three used oil totes that did not have secondary containment directly outside of the lined area of the oil-water separator process area.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 12
Location: Environmental Response Services
City: Lake Charles
County/Parish: Calcasieu
State: Louisiana
Photo File Name: IMG_7695 Date of Photo: 04/16/2024 Time of Photo: 11:52 hrs. Photographer: Anshul Paripati Description: View of soil contamination surrounding ERS' washout pad in the oil-water separator process area.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 13
Location: Environmental Response Services
City: Lake Charles
County/Parish: Calcasieu
State: Louisiana
Photo File Name: IMG_7696 Date of Photo: 04/16/2024 Time of Photo: 11:53 hrs. Photographer: Anshul Paripati Description: View of 40 buckets and 14 drums of potentially hazardous waste that had been on site for over a year according to Mr. Clark in ERS' general waste storage area.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 14
Location: Environmental Response Services
City: Lake Charles
County/Parish: Calcasieu
State: Louisiana
Photo File Name: IMG_7697 Date of Photo: 04/16/2024 Time of Photo: 11:55 hrs. Photographer: Anshul Paripati Description: View of three white drums containing "soaps" according to Mr. Clark, which had been on site for about six years, and three blue drums of unknown material without waste determinations in ERS's general waste storage area.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 15
Location: Environmental Response Services
City: Lake Charles
County/Parish: Calcasieu
State: Louisiana
Photo File Name: IMG_7698 Date of Photo: 04/16/2024 Time of Photo: 11:57 hrs. Photographer: Anshul Paripati Description: Overview of ERS' universal waste storage area
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 16
Location: Environmental Response Services
City: Lake Charles
County/Parish: Calcasieu
State: Louisiana
Photo File Name: IMG_7699 Date of Photo: 04/16/2024 Time of Photo: 11:57 hrs. Photographer: Anshul Paripati Description: View of a container of e-waste in the universal waste storage area, observed.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 17
Location: Environmental Response Services
City: Lake Charles
County/Parish: Calcasieu
State: Louisiana
Photo File Name: IMG_7700 Date of Photo: 04/16/2024 Time of Photo: 12:00 hrs. Photographer: Anshul Paripati Description: Close-up view of used battery containers in the universal waste storage area with universal waste labels, observed.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 18
Location: Environmental Response Services
City: Lake Charles
County/Parish: Calcasieu
State: Louisiana
Photo File Name: IMG_7701 Date of Photo: 04/16/2024 Time of Photo: 12:01 hrs. Photographer: Anshul Paripati Description: Overview of used battery containers in the universal waste storage area with universal waste labels, observed.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 19
Location: Environmental Response Services
City: Lake Charles
County/Parish: Calcasieu
State: Louisiana
Photo File Name: IMG_7702 Date of Photo: 04/16/2024 Time of Photo: 12:02 hrs. Photographer: Anshul Paripati Description: View of expired flares handled as universal waste in ERS' universal waste storage area.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 20
Location: Environmental Response Services
City: Lake Charles
County/Parish: Calcasieu
State: Louisiana
Photo File Name: IMG_7703 Date of Photo: 04/16/2024 Time of Photo: 12:03 hrs. Photographer: Anshul Paripati Description: Overview of expired flares handled as universal waste in ERS' universal waste storage area.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 21
Location: Environmental Response Services
City: Lake Charles
County/Parish: Calcasieu
State: Louisiana
Photo File Name: IMG_7704 Date of Photo: 04/16/2024 Time of Photo: 12:03 hrs. Photographer: Anshul Paripati Description: View of two pallets of used batteries that had not been labeled in ERS' universal waste storage area.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 22
Location: Environmental Response Services
City: Lake Charles
County/Parish: Calcasieu
State: Louisiana
Photo File Name: IMG_7705 Date of Photo: 04/16/2024 Time of Photo: 12:04 hrs. Photographer: Anshul Paripati Description: View of a pile of expired fluorescent lamps that had not been labeled in ERS' universal waste storage area.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 23
Location: Environmental Response Services
City: Lake Charles
County/Parish: Calcasieu
State: Louisiana
Photo File Name: IMG_7706 Date of Photo: 04/16/2024 Time of Photo: 12:04 hrs. Photographer: Anshul Paripati Description View of 8 used oil drums without secondary containment or labels in ERS' universal waste storage area.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 24
Location: Environmental Response Services
City: Lake Charles
County/Parish: Calcasieu
State: Louisiana
Photo File Name: IMG_7707 Date of Photo: 04/16/2024 Time of Photo: 12:05 hrs. Photographer: Anshul Paripati Description: Close-up of one of the used oil drums shown in Photo No. 38 with a faded label.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 25
Location: Environmental Response Services
City: Lake Charles
County/Parish: Calcasieu
State: Louisiana
Photo File Name: IMG_7708 Date of Photo: 04/16/2024 Time of Photo: 12:06 hrs. Photographer: Anshul Paripati Description: View of contaminated soil from spill observed to be coming from a drum that Mr. Clark indicated contained grease in ERS' general yard area.
APPENDIX 2. LDEQ INSPECTION REPORT FOR ERS
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APPENDIX 3. FOLLOW-UP EMAIL FROM ERS APRIL 18
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APPENDIX 4. ERS UNIVERSAL WASTE MANIFEST
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APPENDIX 5. ERS HAZARDOUS WASTE MANIFEST PAINT AND AEROSOL LIQUID
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APPENDIX 6. ERS PROFILE FOR PAINT AND AEROSOL LIQUID
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Click on link for FR list of 172 PFAS substances, https://www.govinfo.gov/content/pkg/FR-2020-06-22/pdf/2020-10990.pdf
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APPENDIX 7. ERS RECEIPT OF USED OIL FROM LAND-BASED FACILITY
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APPENDIX 8. ERS MOST RECENT SPILL RESPONSE REPORT
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APPENDIX 9. ERS RECEIPT OF USED OIL FROM VESSEL
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APPENDIX 10. FOLLOW-UP EMAIL FROM ERS APRIL 25
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APPENDIX 11. PHOTO OF WASTE PAINT DRUM IN FOLLOW-UP EMAIL FROM ERS APRIL 25
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APPENDIX 12. PHOTO OF AEROSOL CAN MANAGEMENT DRUMS IN FOLLOW-UP EMAIL FROM ERS APRIL 25
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