Document 2NaO7ydrRVM1Xmgz12RZG1vdb
Inspection Entry Date/Time Inspection Exit Date/Time
EPA REGION 6 Enforcement Division
INSPECTION REPORT
11/6/2024 15:40 (CT) 11/6/2024 16:30 (CT)
Announced: No (tenants and related facilities) Access: Granted
Regulatory Program Type of Inspection
RCRA Focused Compliance Inspection (FCI)
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
National Tank Services TXD051877348 5055 Washington Blvd. Beaumont, TX 77707 Jefferson County Small Quantity Generator (SQG) 484121 National Tank Services cleans trailers and vacuum trucks used to transport chemical products. 30.0556, -94.1489
Additional Persons Participating in Inspection:
Name
Title
Organization
Angela Hays
Inspector
EPA REGION 6
Sandesh Thapa
Inspector
EPA REGION 6
Jon Herbay
Contractor Eastern Research
Group (ERG)
Email Hays.Angela@epa.gov Thapa.Sandesh@epa.gov Jon.Herbay@erg.com
Phone (214) 665-2285 (214) 665-2265 (412) 780-9931
Lead Inspector: Vince Damiano
Chemical Engineer ERG
Vincent Damiano
Digitally signed by Vincent Damiano Date: 2025.02.06 11:40:02 -05'00'
Vince.Damiano@erg.com
02/06/2025 (703) 633-1732
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National Tank Services
Inspection Date: 11/06/2024
SECTION I - INTRODUCTION
Site Entry and Purpose of the Inspection
The Port of Beaumont 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, verbal or written statements made during or after the on-site inspection, and/or materials shown, demonstrated, or submitted to the Environmental Protection Agency (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 Inspector/Enforcement Officer/EPA Region 6 Inspector/Enforcement Officer/EPA Region 6 RCRA Inspector/ Contractor/ERG National Tank Services
National Tank Services
Name
Phone
Vince Damiano (703) 6331732
Angela Hays
(214) 6652285
Sandesh Thapa (214) 6652265
Jon Herbay
(412) 7809931
Andrew Ferrill (402) 2932772
Reginald Keller (409) 2038501
Email Vince.Damiano@erg.com
Opening Closing Conf. Conf.
Yes Yes
Hays.Angela@epa.gov
Yes Yes
Thapa.Sandesh@epa.gov
Yes Yes
Jon.Herbay@erg.com
Yes Yes
AFerrill@NationalTankServices.com Yes Yes
ReKeller@trimac.com
Yes Yes
Page 2 of 4
National Tank Services
Inspection Date: 11/06/2024
Facility General Description
Tenant/Area National Tank Services
Inspection Date
11/06/24
Process Description National Tank Services (NTS) cleans trailers and vacuum trucks that are used to transport chemical products. Most vehicles it services are a part of its sister company Trimac Transportation. It is a purely land-based facility and does not operate under a MARPOL COA.
Area of Concern
No
SECTION II - OBSERVATIONS
Tenant: National Tank Services
Section: 2.1
Date: 11/06/24, 02:45 PM Contains AOC: No Contains CBI: No
Lead Inspector: Vince Damiano Attendees: Andrew Ferrill (Service Manager), Reginald Keller (Supervisor)
NTS is located in Beaumont and primarily cleans tanker trucks and trailers used to transport chemicals and other products such as oil. NTS removes any tank bottoms or heels from tanker trucks or trailers to ensure no cross-contamination for future transportation. NTS mainly services Trimac Transportation's fleet of tanker trucks. Trimac Transportation and NTS share the same owner. NTS uses a detergent or caustic wash to clean out a non-hazardous tank and a combination of both or small amounts of specialty cleaning chemicals when washing a tank that was previously transporting hazardous materials. NTS will sometimes flare the inside of a tank if required. This depends on the material that was previously transported in the tank. NTS periodically generates hazardous waste from excess products left in tanks. NTS uses the waste profile for the material of concern and consult with the company's environmental team to properly dispose of the waste. NTS is registered as a SQG of hazardous waste with the EPA (TXD051877348).
Following the opening conference, the inspection team began a visual inspection at 4:10 PM. The inspection team first observed the two wash bays where tank cleaning is conducted by NTS. The inspection team then observed NTS's water treatment process where wash water from the wash bays is collected in a sump and then sent through a series of oil water separators, equalizer tanks, clarifier tanks, and biological bug tanks. The inspection team observed the waste storage area located outside of the wash bays. The waste storage area was currently storing three 55-gallon drums of non-hazardous oil-contaminated absorbents and one 55gallon drum of used oil that was properly labeled "Used Oil" and was in good condition and closed.
The inspection team did not observe any apparent areas of concern (AOCs) at the time of the inspection; however, further EPA review may change or add to their potential AOCs. A closing conference was conducted at approximately 4:30 PM with NTS personnel.
SECTION III - RECORDS REVIEW No RCRA-regulated records were reviewed during this focused onsite inspection. SECTION IV - AREAS OF CONCERN
Page 3 of 4
National Tank Services
Inspection Date: 11/06/2024
Not Applicable SECTION V - FOLLOW UP
Follow-Up Any facility follow-up items are as discussed in the observations in Section II. Documents or files provided by the facility were transmitted via email and included responses to AOCs or provision of documents requested.
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