Document 3eNBgNVkbxoeEBOVL6VKmBXeE
Region 6 - Enforcement & Compliance Assurance Division
INSPECTION REPORT
inspection Date(s): Media Program: Regulatory Program(s)
January 16-18, 2024 RCRA Small Quantity Generator
Company Name: Facility Name: Facility Physical Location:
(City, State, Zip Code) Mailing address:
(City, State, Zip Code) County/Parish: Facility Phone Number Facility Contact:
K-Solv K-Solv Chemical Distribution and Maritime Services 1007 Lakeside Drive Channelview, Texas 77530 1007 Lakeside Drive Channelview, Texas 77530 Harris County
Bernard Nelson bnelson@ksolv.com
Environmental Manager
FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC:
110031302365 NA RCRA ID: TXR000068908 424690 - Other Chemical and Allied Products Merchant Wholesalers
Personnel participating in inspection:
John Penland
USEPA Region 6 (ECDSR)
Jhamila Perrier Gary Weatherly Bernard Nelson Kodi Scott Tracey Simeon Beau McDonald Paul Pentecost
TCEQ Region 12 K-Solv K-Solv K-Solv K-Solv K-Solv AARC Group
Senior Environmental Scientist Inspector Hazardous Waste Investigator Executive Vice President - Operations Registered Environmental Manager Compliance Coordinator
EHS Manager
EPA Lead Inspector Signature/Date
JOHN PENLAND Date: 2024.02.16 11:39:52 -06'00' Digitally signed by JOHN PENLAND
John Penland - Senior Environmental Scientist (ECDSR) Date
Supervisor Signature/Date
DEBRA PANDAK Date: 2024.02.16 12:10:28 -06'00' Digitally signed by DEBRA PANDAK
Debra Pandak - Section Chief (ECDSR)
Date
6ENFORM-019-R8.2 (02/12/2020)
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Section I - INTRODUCTION
K-Solv Chemical and Maritime Services January 16-18, 2024
PURPOSE OF THE INSPECTION
During the week of January 16, 2024, I, John Penland, conducted an unannounced inspection of the KSolv Chemical and Maritime Services facility (K-Solv) located at 1007 Lakeside Drive in Channelview, Texas, for compliance with the Resource Conservation and Recovery Act (RCRA). I was accompanied on this inspection by Texas Commission on Environmental Quality (TCEQ) investigator Jhamila Perrier. The inspection included walkthroughs of the facility's hazardous waste generation and management units and a review of the facility records related to solid and hazardous waste management.
The K-Solv facility was targeted for inspection as part of the EPA Region 6's evaluation of chemical container cleaning operations in response to EPA's November 2022 Drum Reconditioner Damage Case Report. This inspection was also conducted as a follow-up to EPA's December 6, 2023, inspection of the K-Solv facility as part of Region 6's evaluation of ports and maritime support operations.
FACILITY DESCRIPTION
The K-Solv Channelview facility is home to two distinct operations: chemical distribution and maritime services.
K-Solv Chemical Distribution operates container and tank storage units for the blending and distribution of commercial chemical products. These products are received as heels from barges cleaned by the Barge Services group, bought as off-specification heels from other container cleaning operations, or bought as off-specification or virgin product from chemical manufacturers. Wastes routinely generated in the chemical storage and distribution process include methanol contaminated rinse water for flushing transfer equipment, contaminated filter bags from product filtering, contaminated rags and personal protective equipment (PPE), polymerized styrene, and glass laboratory waste.
K-Solv Maritime Services is hired to clean and conduct maintenance on chemical barges. The heels drained from this operation are transferred into containers or frac tanks to be resold by the K-Solv Chemical Distribution group. Wastes routinely generated in this process include wastewater, rust and scale, and contaminated PPE.
The K-Solv facility currently notifies as a Small Quantity Generator of hazardous waste and is assigned the EPA ID: TXR000068908.
Section II - INSPECTION SUMMARY
January 16, 2024 We arrived at the K-Solv facility at approximately 10:15 a.m. Central Time and began the inspection with an opening conference. During this conference, we presented our credentials to Mr. Gary Weatherly and informed him that we were there to conduct an inspection of the facility under the authority of Section 3007 of RCRA. During this conference, we also discussed the purpose and scope of the inspection and notified them of the facility's right to assert a claim for Confidential Business Information for records collected during this inspection.
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K-Solv Chemical and Maritime Services January 16-18, 2024
Following the opening conference, we conducted our walkthrough of the facility's process and storage areas. This walkthrough was focused on inspector orientation of the site. Due to extremely low temperatures, the facility was idle.
We departed the facility at approximately 12:15 p.m. Central Time.
For our detailed observations, inspection notes, and records request, see the Daily Summary for January 16, 2024, in Appendix 2.
January 17, 2024 We arrived at the facility at approximately 9:10 a.m. Central Time to begin our inspection day. We began the day with a more comprehensive walkthrough of the facility focusing on each of the facility process areas. During this walkthrough, we evaluated the facility's compliance with the hazardous waste container and tank standards as well as the facility's general duty to prevent releases of hazardous waste or hazardous constituents to the environment. Following this walkthrough, we discussed the facility's operating procedures and records management.
We concluded our inspection day at approximately 5:10 p.m. Central Time.
For our detailed observations, inspection notes, and records request, see the Daily Summary for January 17, 2023, in Appendix 2.
January 18, 2024 We arrived at the facility at approximately 9:00 a.m. Central Time to conduct a closing conference. During this conference, we summarized the inspection and presented our preliminary findings as described in Section III of this report. We concluded the closing conference at approximately 10:00 a.m. and departed the site.
Section III - PRELIMINARY FINDINGS
1.Documentation of Waste Determinations - 40 CFR 262.11(f) Small quantity generators of hazardous waste are required to document and maintain records related to their hazardous waste determinations.
Alcohol Rinse Water - The facility generates this alcohol rinse water from the cleaning of equipment used to transfer or store alcohol products. This rinse is stored in 2 storage tanks prior to shipment for offsite disposal as a non-hazardous waste. However, this determination depends on procedural controls to ensure that the concentration of alcohol in the rinse water never exceeds the 24% limit set forth in the characteristic of ignitibility for hazardous waste (40 CFR 261.21). The facility has not been able to provide analytical documentation to verify adherence to this limit.
Product Filter bags - The facility generates spent filter bags from the filtration of various products. These bags are comingled with K-Solv's oily rags and wipes waste stream prior to shipment for offsite disposal as a nonhazardous waste. However, the bags are used to filter various products including some that
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K-Solv Chemical and Maritime Services January 16-18, 2024
could result in the waste carrying in a hazardous waste characteristic. The facility has been unable to provide documentation showing that this waste is generated in a manner which would exclude potentially hazardous waste characteristics. Rust and Scale - K-Solv generates rust and scale from the cleaning of product barges. This waste is accumulated in vacuum boxes prior to shipment for offsite disposal as nonhazardous waste. One analytical report was provided for this waste stream from a barge sampled on July 24, 2023. The sample results indicate that the sample is non-hazardous. However, this sample is a single grab from a larger batch of rust and scale from a barge where the last held contents were not indicated. Since this waste is generated by a batch process with a variety of potential contaminants, this single sample is insufficient for a more generally applicable waste determination. Section IV - LIST OF APPENDICES Appendix 1 - Photo Log Appendix 2 - Daily Summary of Inspection Notes and Observations
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APPENDIX 1 PHOTO LOG
Photo Number
1
2
3
File Name P1170594 P1170595 P1170596
Date
Time Photographer
.JPG 17-Jan-24 1035 Jhamilla Perrier
.JPG 17-Jan-24 1035 Jhamilla Perrier
.JPG 17-Jan-24 1036 Jhamilla Perrier
Description Vacuum box used for the accumulation of Rust and Scale waste from barge cleaning. Tote used for emissions control (organic odor reduction) for wastewater storage tanks Vacuum box used for the accumulation of Rust and Scale waste from barge cleaning. Tote used for emissions control (organic odor reduction) for wastewater storage tanks Vacuum box used for the accumulation of Rust and Scale waste from barge cleaning. Tote used for emissions control (organic odor reduction) for wastewater storage tanks
4 P1170597 .JPG 17-Jan-24
5 P1170598 .JPG 17-Jan-24
6 P1170599 .JPG 17-Jan-24
7 P1170600 .JPG 17-Jan-24
8 P1170601 .JPG 17-Jan-24
9 P1170602 .JPG 17-Jan-24
10 P1170603 .JPG 17-Jan-24
11 P1170604 .JPG 17-Jan-24
1036 Jhamilla Perrier 1045 Jhamilla Perrier 1045 Jhamilla Perrier 1046 Jhamilla Perrier 1047 Jhamilla Perrier 1048 Jhamilla Perrier
1051 Jhamilla Perrier
1051 Jhamilla Perrier
Carbon Drums used for emissions control at barge cleaning area. 275-gallon tote of reacted styrene found in product storage area 275-gallon tote of reacted styrene found in product storage area 275-gallon tote of reacted styrene found in product storage area 275-gallon tote of reacted styrene found in product storage (second) 275-gallon tote of reacted styrene found in product storage area (second) Frac Tanks used for the accumulation of petroleum distillate heels and oil from barge cleaning. Frac Tanks used for the accumulation of petroleum distillate heels and oil from barge cleaning.
Photo Number
12 13 14 15 16 17 18 19 20 21 22
File Name P1170605 P1170606 P1170607 P1170608 P1170609 P1170610 P1170611 P1170612 P1170613 P1170614 P1170615
Date
Time Photographer
.JPG 17-Jan-24 1052 Jhamilla Perrier
.JPG 17-Jan-24 1052 Jhamilla Perrier
.JPG 17-Jan-24 1052 Jhamilla Perrier
.JPG 17-Jan-24 1052 Jhamilla Perrier
.JPG 17-Jan-24 1053 Jhamilla Perrier
.JPG 17-Jan-24 1053 Jhamilla Perrier
.JPG 17-Jan-24 1053 Jhamilla Perrier
.JPG 17-Jan-24 1053 Jhamilla Perrier
.JPG 17-Jan-24 1053 Jhamilla Perrier
.JPG 17-Jan-24 1053 Jhamilla Perrier
.JPG 17-Jan-24 1053 Jhamilla Perrier
Description Frac Tanks used for the accumulation of petroleum distillate heels and oil from barge cleaning. Frac Tanks used for the accumulation of petroleum distillate heels and oil from barge cleaning. Frac Tanks used for the accumulation of petroleum distillate heels and oil from barge cleaning. Frac Tanks used for the accumulation of petroleum distillate heels and oil from barge cleaning. Frac Tanks used for the accumulation of petroleum distillate heels and oil from barge cleaning. Frac Tanks used for the accumulation of petroleum distillate heels and oil from barge cleaning. Frac Tanks used for the accumulation of petroleum distillate heels and oil from barge cleaning. Frac Tanks used for the accumulation of petroleum distillate heels and oil from barge cleaning. Frac Tanks used for the accumulation of petroleum distillate heels and oil from barge cleaning. Frac Tanks used for the accumulation of petroleum distillate heels and oil from barge cleaning. Frac Tanks used for the accumulation of petroleum distillate heels and oil from barge cleaning.
Photo Number
23 24 25 26 27 28
29
30
31
32
File Name P1170616 P1170617 P1170618 P1170619 P1170620 P1170621
P1170622
P1170623
P1170624
P1170625
Date
Time Photographer
.JPG 17-Jan-24 1055 Jhamilla Perrier
.JPG 17-Jan-24 .JPG 17-Jan-24
1055 Jhamilla Perrier 1055 Jhamilla Perrier
.JPG 17-Jan-24 1102 Jhamilla Perrier
.JPG 17-Jan-24 1102 Jhamilla Perrier
.JPG 17-Jan-24 1102 Jhamilla Perrier
.JPG 17-Jan-24 1103 Jhamilla Perrier
.JPG 17-Jan-24 1103 Jhamilla Perrier
.JPG 17-Jan-24 1103 Jhamilla Perrier
.JPG 17-Jan-24 1103 Jhamilla Perrier
Description Totes labeled Bottoms/Solids Petroleum Distillates in product storage area Totes labeled Bottoms/Solids Petroleum Distillates in product storage area Tote Labeled Line Flush in product storage area Hazardous waste container accumulation area located outside of QA laboratory. Hazardous waste container accumulation area located outside of QA laboratory. Hazardous waste container accumulation area located outside of QA laboratory. label close up on containers in hazardous waste accumulation area located outside lab. Totes are not hazardous waste but lab samples being returned to the product area label close up on containers in hazardous waste accumulation area located outside lab. Totes are not hazardous waste but lab samples being returned to the product area label close up on containers in hazardous waste accumulation area located outside lab. Totes are not hazardous waste but lab samples being returned to the product area label close up on containers in hazardous waste accumulation area located outside lab. Totes are not hazardous waste but lab samples being returned to the product area
Photo Number
33
34
35
36 37 38 39 40 41 42 43
File Name
P1170626
P1170627
P1170628
P1170629 P1170630 P1170631 P1170632 P1170633 P1170634 P1170635 P1170636
Date
Time Photographer
.JPG 17-Jan-24 1103 Jhamilla Perrier
.JPG 17-Jan-24 1103 Jhamilla Perrier
.JPG 17-Jan-24 1103 Jhamilla Perrier
.JPG 17-Jan-24 1103 Jhamilla Perrier .JPG 17-Jan-24 1108 Jhamilla Perrier .JPG 17-Jan-24 1110 Jhamilla Perrier .JPG 17-Jan-24 1110 Jhamilla Perrier .JPG 17-Jan-24 1110 Jhamilla Perrier .JPG 17-Jan-24 1110 Jhamilla Perrier .JPG 17-Jan-24 1110 Jhamilla Perrier .JPG 17-Jan-24 1111 Jhamilla Perrier
Description label close up on containers in hazardous waste accumulation area located outside lab. Totes are not hazardous waste but lab samples being returned to the product area label close up on containers in hazardous waste accumulation area located outside lab. Totes are not hazardous waste but lab samples being returned to the product area label close up on containers in hazardous waste accumulation area located outside lab. Totes are not hazardous waste but lab samples being returned to the product area label close up on containers in hazardous waste accumulation area located outside lab. Totes are not hazardous waste but lab samples being returned to the product area View of product stroage area from QA lab hazardous waste accumulation area Hazardous waste container accumulation area located on North end of facility Hazardous waste container accumulation area located on North end of facility Hazardous waste container accumulation area located on North end of facility Hazardous waste container accumulation area located on North end of facility Hazardous waste container accumulation area located on North end of facility Hazardous waste container accumulation area located on North end of facility
Photo Number
44
45
46
47 48 49 50 51 52 53
File Name
P1170637
P1170638
P1170639 P1170640 P1170641 P1170642 P1170643 P1170644 P1170645 P1170646
Date
Time Photographer
.JPG 17-Jan-24 1111 Jhamilla Perrier
.JPG 17-Jan-24 1112 Jhamilla Perrier
.JPG 17-Jan-24 .JPG 17-Jan-24 .JPG 17-Jan-24 .JPG 17-Jan-24 .JPG 17-Jan-24 .JPG 17-Jan-24 .JPG 17-Jan-24 .JPG 17-Jan-24
1112 Jhamilla Perrier 1114 Jhamilla Perrier 1114 Jhamilla Perrier 1114 Jhamilla Perrier 1114 Jhamilla Perrier 1115 Jhamilla Perrier 1115 Jhamilla Perrier 1115 Jhamilla Perrier
Description Hazardous waste container accumulation area located on North end of facility Newly reconstructed container storage area on west side of Lakeside Drive Newly reconstructed container storage area on west side of Lakeside Drive Product Containers stored in new container storage area Product Containers stored in new container storage area Product Containers stored in new container storage area Product Containers stored in new container storage area Product Containers stored in new container storage area Product Containers stored in new container storage area Product Containers stored in new container storage area
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55 .JPG
56 .JPG
57 .JPG
58 .JPG
59 .JPG
60 .JPG
61 .JPG
62 .JPG
63 .JPG
64 .JPG
John Penland
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APPENDIX 2
SUMMARY OF INPSECTION NOTES AND OBSERVATIONS
Penland, John
From: Sent: To: Cc: Subject:
Attachments:
Penland, John Tuesday, January 16, 2024 9:58 PM gary@ksolv.com; Jhamila Perrier Pandak, Debra (she/her/hers) Daily Summary - January 16, 2024 - EPA RCRA Inspection of the Ksolv Chemicals and Maritime facility in Channelview, TX (TXR000068908) CBI_Notice_QandAs-12-14-20-final_version.pdf; General_CBI_Notice_12_2022.pdf
All, Here is a summary of my notes from today's inspection. If there are any errors or omissions please let me know.
Introduction During the week of June 26, 2023, I, John Penland, will be conducting an unannounced inspection of the Ksolv Chemical and Maritime Services facility (Ksolv) located at 1007 Lakeside Drive in Channelview, Texas, for compliance with the Resource Conservation and Recovery Act (RCRA). I will be accompanied on this inspection by Texas Commission on Environmental Quality (TCEQ) investigator Jhamila Perrier. The inspection will include walkthroughs of the facility's hazardous waste generation and management units and a review of the facility records related to solid and hazardous waste management.
Purpose The Ksolv facility was targeted for inspection as part of the Region 6's evaluation of chemical container cleaning operations in response to EPA's November 2022 Drum Reconditioner Damage Case Report. This inspection is also being conducted as a follow-up to EPA's December 6, 2023 inspection of the Ksolv facility as part of Region 6's evaluation of ports. This December investigation determined that the Ksolv facility was not a port under that initiative.
Name John Penland Jhamila Perrier Gary Weatherly Bernard Nelson
Brian Unruh
Title Lead Hazardous Waste Inspector Hazardous Waste Investigator Executive Vice President Registered Environmental Manager Plant Manager
Representing US EPA Region 6 TCEQ Region 12 Ksolv Ksolv
Ksolv
Phone 214-665-9717 713-767-3690 713-829-6297 713-539-1304
832-773-1987
Email Penland.john@epa.gov Jhamila.perrier@tceq.texas.gov gary@ksolv.com
bunruh@ksolv.com
Daily Summary Initial Entry to the facility - approximately 10:15am Opening meeting start - 10:30am I presented my credentials to Mr. Gary Weatherly and informed him that we were there to conduct an inspection of the facility under the authority of section 3007 of the Resource Conservation and Recovery Act.
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We discussed the authority for the inspection - RCRA Section 3007 - For purposes of developing or assisting in the development of any regulation or enforcing the provisions of this chapter, any person who generates, stores, treats, transports, disposes of, or otherwise handles or has handled hazardous wastes shall, upon request of any officer, employee or representative of the Environmental Protection Agency, duly designated by the Administrator, or upon request of any duly designated officer, employee or representative of a State having an authorized hazardous waste program, furnish information relating to such wastes and permit such person at all reasonable times to have access to, and to copy all records relating to such wastes. For the purposes of developing or assisting in the development of any regulation or enforcing the provisions of this chapter, such officers, employees or representatives are authorized-- (1)to enter at reasonable times any establishment or other place where hazardous wastes are or have been generated, stored, treated, disposed of, or transported from; (2)to inspect and obtain samples from any person of any such wastes and samples of any containers or labeling for such wastes.
We discussed the purpose of EPA's inspection - In response to the Drum Reconditioner Damage Case Report, EPA Region 6 began conducting inspections at facilities where issues similar to those identified in the report might occur. This inspection is intended to: Assess the Ksolv facility's regulatory status (ie, LQG/transporter, SQG, VSQG); Evaluate the facility's waste identification and characterization procedures; and Identify facility operations which could pose a risk of release of hazardous waste or hazardous constituents to the air, water, or land.
Discussed the right of Ksolv to assert a Confidential Business Information claim for records requested by EPA (see attachment)
Discussed the process for transferring electronic records - EPA has set up a access limited to the inspection participants.
Microsoft OneDrive folder with
Discussed the inspection process - the inspection will be conducted during the week of January 15, 2024. The participants will meet at the facility at 9:00am each day to conduct the onsite portion of the inspection and discuss the findings of the ongoing records review. The records review will be conducted by the inspectors independently offsite throughout the week. Daily summaries will be provided by the inspectors at the end of each day to ensure a clear communication of questions and findings. EPA will schedule a closing conference, where EPA will summarize the overall findings of the inspection to that point and provide a plan for concluding any unfinished evaluation.
General Facility Process - The Ksolv facility is divided into two separate operational units: chemical barge washing; and chemical repackaging and distribution. These operations process generate: wastewater; used ppe; contaminated glassware and laboratory waste; oily rags and debris; rust and scale residues removed from the barges; discarded and off-spec commercial chemical products.
Initial request for compliance records, including: 1) Current arrangements with local authorities and emergency procedures 2) Facility Maps identifying solid waste management units 3) Facility waste profiles for any solid waste generated since 2021. Include documentation relevant to the waste determination made for each waste (i.e. analytical reports or documentation to support generator knowledge; see 40 CFR 262.11(f)) 4) Facility SOPs related to the generation or management of hazardous waste 5) RCRA Unit inspection records since 2021 for container storage areas 6) Currently effective CAA Title V and NSR permits for hazardous waste management units
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Facility Walkthrough Beginning at approximately 11:00am- This walkthrough of the facility was focused on familiarizing the inspection team with the operations and layout of the facility and to identify readily apparent management concerns. A more focused process review is planned for 01/17/2024 The facility was mostly idle due to extremely cold temperatures but planned to resume normal operations on 1/17. While touring the facility we found that the manway hatches were not secured in the closed position on all of the frac tanks used for the accumulation of barge heels. Departed Facility at approximately 12:15pm Topics for inspection on January 17, 2024 Start to finish process walkthrough Solid waste unit identification Waste profile and determination review Identification of process management records Identification of personnel for training review Discussion of EPA ID changes John Penland Senior Environmental Scientist (ECDSR) Enforcement and Compliance Assurance Division Waste Enforcement Branch EPA Region 6 1201 Elm St., Suite 500 Dallas, Texas 75270 (214)665-9717
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Penland, John
From: Sent: To:
Cc: Subject:
Penland, John Thursday, January 18, 2024 12:04 AM Jhamila Perrier; ppentecost@aarcgroup.com; jarmendariz@aarcgroup.com; gary@ksolv.com; bnelson@ksolv.com; kodi@ksolv.com; tracey@ksolv.com; beau@ksolv.com Pandak, Debra (she/her/hers) Daily Summary - January 17, 2024 - EPA RCRA Inspection of the Ksolv Chemicals and Maritime facility in Channelview, TX (TXR000068908)
All, Here is a summary of my notes from today's inspec on. If there are any errors or omissions please let me know.
Name John Penland
Jhamila Perrier
Gary Weatherly
Bernard Nelson
Paul Pentecost Jaime Armendariz Kodi Sco
Tracey Simeon Beau McDonald
Title Lead Hazardous Waste Inspector Hazardous Waste Inves gator Execu ve Vice President Registered Environmental Manager EHS Manager Marke ng Manager Compliance Coordinator
Represenng US EPA Region 6 TCEQ Region 12 Ksolv Ksolv
AARC Group AARC Group Ksolv Ksolv Ksolv
Phone 214-665-9717 713-767-3690 713-829-6297 713-539-1304
713-818-3799 281-254-2914 713-828-1895 985-232-8676
Email Penland.john@epa.gov Jhamila.perrier@tceq.texas.gov gary@ksolv.com
ppentecost@aarcgroup.com jarmendariz@aarcgroup.com kodi@ksolv.com tracey@ksolv.com beau@ksolv.com
Daily Summary
Inspec on Day start - approximately 09:10am Recap of Previous day
Process Walkthrough - Ksolv Barge Services is hired to clean and conduct maintenance on chemical barges. The heels drained from this opera on are transferred into containers or frac tanks to be resold by the Ksolv Chemical distribu on group. Wastes rou nely generated in this process include wastewater, rust and scale, and contaminated PPE.
-Wastewater is sent to Delta Water as "Oily Water" for disposal (recycling) and is not counted by Ksolv as a solid waste.
-Rust and scale waste and the contaminated PPE are sent for disposal at the WCA Ft. Bend Regional Landfill as non-hazardous Class 1 waste under the same profile and TX waste code 00054891 for "Rags, PPE, and Oily Sludge". Ksolv chemical distribu on operates container and tank storage units for the blending and distribu on of commercial chemical products. These products are received as heels from barges cleaned by the Barge Services group, bought as offspec heels from other container cleaning opera ons, or bought as off-spec or virgin product from chemical
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manufacturers. Wastes rou nely generated in the chemical storage and distribu on process include methanol contaminated rinse water for flushing transfer equipment, contaminated filter bags from product filtering, contaminated rags and PPE, polymerized styrene, and glass laboratory waste.
-Methanol contaminated rinse water is sent to Delta Water as "Alcohol Rinse Water". According to the profile, the waste water has a flash point <150F but is exempt from the D001 hazardous waste characteris c since it is composed of <24% alcohol and >50% water by weight. Ksolv has the Class 1 waste code 00252011 assigned for this waste but has not reported its genera on. The profile an cipates a genera on of up to 5,000 gallons per month. -contaminated filter bags, rags, and PPE are sent for disposal at the WCA Ft. Bend Regional Landfill as nonhazardous Class 1 waste under the same profile as listed for Barge Services waste, TX waste code 00054891 for "Rags, PPE, and Oily Sludge". -polymerized styrene is generated when the inhibitors in the styrene monomer product become to dilute, o en as a result of water contamina on, and the monomer begins to auto-polymerize. This occurs rapidly and can generate enough heat to melt the storage container. Once the reac on has completed, the resul ng polymerized styrene is disposed at the WCA Ft. Bend Regional Landfill as non-hazardous Class 1 waste under TX waste code 00144091. -glass laboratory waste is generated by the facility QA lab. The waste is comprised of used and broken glassware. The liquid product samples are returned to the product tanks. This waste stream is disposed at the WCA Ft. Bend Regional Landfill as non-hazardous Class 1 waste under TX waste code 00383881.
Facility Walkthrough
opera
Barge Dock 1xVacuum box used for the accumula on of Rust and scale from barge washing opera ons 2xRoll off box used from the accumula on of used PPE, oily rags, and rust and scale from barge washing ons 1xTote of Natures Edge product used as voc emissions control for the waste water tanks 2xdrums of ac vated carbon used as voc emissions control for the waste water tanks 2xtanks for waste water
Chemical Storage and distribu on 2xtanks for alcohol rinse water 1xcontainer storage area for waste styrene - evidence of styrene spills present. No containers in area. 2 reacted styrene containers found in product storage areas 1xcontainer storage area for laboratory waste
Waste Determina on review
Barge Washwater - determina on made on process knowledge. The facility washes barges which last held a variety of commercial chemicals including alcohols, diesel, gasoline, MEK, and others which could poten ally generate a characteris c wastewater. However the facility's process requires the barges to be vapor free prior to washing so that employees can enter and manually wash the containers as opposed to using an automa c spray head. This process means that the organic content of the wastewater is lower than wash waters at other facili es. Ksolv has determined that this reduc on is sufficient to preclude the genera on of characteris c wastewater.
Rust and Scale - determina on based largely on process knowledge. One analy cal report was provided for this waste stream from a barge sampled on July 24, 2023. The sample results indicate that the sample is non-hazardous. However, this sample is a single grab from a larger batch of rust and scale from a barge where the last held contents were not indicated. Since this waste is generated by a batch process with a variety of poten al contaminants, this determina on may be insufficient
Contaminated PPE - determina on based on process knowledge
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Laboratory Glassware - determina on based on process knowledge Polymerized styrene - determina on based on process knowledge with accompanying SDS Alcohol Rinse Water - determina on based on process knowledge. However, this determina on has a dependence on procedural control to ensure that the concentra on of alcohol never exceeds 24%. The facility has not been able to provide analy cal documenta on to verify adherence to this limit. Product Filter bags - This determina on is based on process knowledge. However, the bags are used to filter various products included some that could result in the waste carrying in a hazardous waste characteris c. The facility has been unable to provide documenta on showing that this waste is generated in a manner which would exclude poten al hazardous waste characteris cs. Training Documenta on Reviewed a list of computer based training modules that apply to all opera ons personnel at the facility. No concerns iden fied at this me Facility inspec on records The facility provided a daily walkthrough checklist that applies to all tanks and containers at the facility. This record is complete but does not individually iden fy waste management units or areas Emergency Procedures The facility provided a copy of their emergency ac on plan. This plan has been provided to the LEPC and Ksolv will provide documenta on to that effect. Close out mee ng planned for 1/18/2024
John Penland Senior Environmental Scientist (ECDSR) Enforcement and Compliance Assurance Division Waste Enforcement Branch EPA Region 6 1201 Elm St., Suite 500 Dallas, Texas 75270 (214)665-9717
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