Document 7Mrex7LpZ5Np2z9y8jB3R4BaR
Inspection Entry Date/Time
Inspection Exit Date/Time Regulatory Program Type of Inspection
EPA REGION 6 Enforcement Division
INSPECTION REPORT
11/6/2024 8:40 (CT) 11/6/2024 9:25 (CT)
Announced: No (tenants and related facilities) Access: Granted
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
Sun Coast Resources TXR000081384 5255 W Cardinal Drive Beaumont, TX 77705 Jefferson County Non-generator 424720 Sun Coast Resources is a fuel delivery company and transfer facility for used oil. 30.045709, -94.13958
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 12:10:31 -05'00'
Vince.Damiano@erg.com
02/06/2025 (703) 633-1732
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Sun Coast Resources
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, portrelated 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 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 Sun Coast Resources
Sun Coast Resources Sun Coast Resources
Name
Phone
Vince Damiano (703) 633-1732
Email Vince.Damiano@erg.com
Opening Closing Conf. Conf.
Yes
Yes
Angela Hays (214) 665-2285 Hays.Angela@epa.gov
Yes
Yes
Sandesh Thapa (214) 665-2265 Thapa.Sandesh@epa.gov Yes
Yes
Jon Herbay (412) 780-9931 Jon.Herbay@erg.com
Yes
Yes
Ken Herbert (409) 295-1952 KHerbert@SunCostResourc Yes
Yes
es.com
Susan Tyler
Susan.Tyler@Reladyne.com Yes
Yes
Taylor Schauder
T.Schauder@SunCoastReso Yes
Yes
urces.com
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Sun Coast Resources Facility General Description
Inspection Date: 11/06/2024
Tenant/Area Sun Coast Resources
Inspection Date
11/06/24
Process Description Sun Coast Resources (SCR) is a fuel delivery company and transfer facility for used oil. SCR is also registered as a used oil transporter. The facility is land-based and does not operate under a MARPOL COA.
SECTION II - OBSERVATIONS
Area of Concern
Yes
Tenant: Sun Coast Resources
Section: 2.1
Date: 11/06/24, 08:40 AM Contains AOC: Yes Contains CBI: No
Lead Inspector: Vince Damiano Attendees: Ken Herbert (Manager), Susan Tyler, Taylor Schauder
SCR is located in Beaumont, TX, and operates as a fuel delivery company mainly delivering dyed diesel and lubricants to local customers. SCR also operates as a used oil transporter and transfer facility (TXR000081384). SCR typically picks up used oil in 300-gallon totes, used oil filters in 55-gallon drums, and oily water is transported by a vacuum truck. However, SCR's vacuum truck has been out of service for approximately three months at the time of the inspection. SCR stores used oil on site for two weeks before being shipped on a box truck to the Sun Coast Resources Headquarters in Houston to be recycled (TX0000095067). Mr. Herbert explained to the inspection team that SCR will sometimes store used oil in their 4,000-gallon used oil tank, but they typically do not manage enough used oil to use the tank. Any used oil generated by SCR operations will be drummed up and stored on-site until it is shipped to the headquarters for recycling with used oil from customers. SCR does not operate on dock spaces and a MARPOL COA would not apply to their operations.
Following the opening conference, the inspection team conducted a visual inspection of SCR's storage areas. The inspection team first observed the transfer used oil storage area located behind the facility on a loading dock. The inspection team observed eleven 300-gallon totes, but only six of the totes were storing used oil (Appendix 1 - Photos 1 to 5). The used oil was not stored in a secondary containment system which is a requirement for a used oil transfer facility [AOC #1: SCR, a used oil transfer facility, did not store used oil in secondary containment - 40 CFR 279.45(d)]. The inspection team observed that two of the totes storing used oil did not contain a label or marking "Used Oil" (see Appendix 1 - Photos 4 and 5) [AOC #2: SCR did not clearly label containers used to store used oil with the words "Used Oil." - 40 CFR 279.22 (c)(1)]. On the same loading dock where the used oil is stored, the inspection team observed three 55-gallon drums that were labeled as empty, but two of the drums were half-full storing liquid. At the time of the inspection, Mr. Herbert was unsure about the contents of the two drums storing liquid [AOC #3: SCR did not make a hazardous waste determination - 40 CFR 262.11]. The inspection team walked through the operating area and observed the 4,000-gallon used oil tank. However, the storage tank was empty at the time of the inspection.
The inspection team did not observe other areas of concern (AOCs) at the time of the inspection; however, further EPA review may change or add to these potential AOCs. The closing conference was conducted at approximately 09:20 AM with SCR personnel. The AOCs were communicated during the closing. Following the inspection on 11/12/2024, Taylor Schauder sent an email to the inspection team responding to the AOCs observed during the inspection. In the response, SCR added labels to any used oil totes missing labels, added an expandable soft berm to act as a secondary containment for used oil, and determined the two unknown
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Sun Coast Resources
Inspection Date: 11/06/2024
55-gallon drums were used oil. The response includes photographs (see Appendix 2).
SECTION III - RECORDS REVIEW
No RCRA-regulated records were reviewed during this focused onsite inspection.
SECTION IV - AREAS OF CONCERN
The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation. Tenant: Sun Coast Resources
AOC #1 - SCR, a used oil transfer facility, did not store used oil in secondary containment.
Citation: 40 CFR 279.45(d)
Section: 2.1
AOC #2 - SCR 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 #2 - SCR did not make a hazardous waste determination.
Citation: 40 CFR 262.11
Section: 2.1
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.
Communication Log During and after the inspection, additional information was emailed to EPA including: 1. 11/12/24 SCR email - Taylor Schauder sent a follow-up addressing concerns found during the inspection.
SECTION VI - LIST OF APPENDICES Appendix 1. Photograph Log Appendix 2. SCR 11/12/24 Response
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APPENDIX 1. PHOTO LOG
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Location: Sun Coast Resources
City: Beaumont
County/Parish: Jefferson
State: Texas
Photo No. 1
Photo File Name: DSCN7656 Date of Photo: 11/06/2024 Time of Photo: 09:07 hrs. Photographer: Vince Damiano Description: View of four 300-gallon totes (far right tote is empty) storing used oil on SCR's used oil storage area located on its loading dock.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Location: Sun Coast Resources
City: Beaumont
County/Parish: Jefferson
State: Texas
Photo No. 2
Photo File Name: DSCN7657 Date of Photo: 11/06/2024 Time of Photo: 09:07 hrs. Photographer: Vince Damiano Description: View of four 300-gallon totes (far right tote is empty) storing used oil on SCR's used oil storage area located on its loading dock.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Location: Sun Coast Resources
City: Beaumont
County/Parish: Jefferson
State: Texas
Photo No. 3
Photo File Name: DSCN7658 Date of Photo: 11/06/2024 Time of Photo: 09:07 hrs. Photographer: Vince Damiano Description: Overview of used oil storage loading dock. The totes on the left side of the photos and the totes on the right side are storing used oil.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Location: Sun Coast Resources City: Beaumont
County/Parish: Jefferson
State: Texas
Photo No. 4
Photo File Name: DSCN7659 Date of Photo: 11/06/2024 Time of Photo: 09:08 hrs. Photographer: Vince Damiano Description: View of a half-full 300-gallon tote in the used oil storage dock that was not labeled as "Used Oil."
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Location: Sun Coast Resources City: Beaumont
County/Parish: Jefferson
State: Texas
Photo No. 5
Photo File Name: DSCN7660 Date of Photo: 11/06/2024 Time of Photo: 09:08 hrs. Photographer: Vince Damiano Description: View of a half-full 300-gallon tote on the used oil storage dock that was not labeled as "Used Oil."
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Location: Sun Coast Resources City: Beaumont
County/Parish: Jefferson
State: Texas
Photo No. 6
Photo File Name: DSCN7661 Date of Photo: 11/06/2024 Time of Photo: 09:11 hrs. Photographer: Vince Damiano Description: View of three 55-gallon drums found on the loading dock that were labeled as empty. However, the drums on the right and left of the photo were half-full of an unknown liquid.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Location: Sun Coast Resources City: Beaumont
County/Parish: Jefferson
State: Texas
Photo No. 7
Photo File Name: DSCN7662 Date of Photo: 11/06/2024 Time of Photo: 09:11 hrs. Photographer: Vince Damiano Description: View of product label on one of the 55-gallon drums storing liquid on the loading dock.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Location: Sun Coast Resources City: Beaumont
County/Parish: Jefferson
State: Texas
Photo No. 8
Photo File Name: DSCN7663 Date of Photo: 11/06/2024 Time of Photo: 09:11 hrs. Photographer: Vince Damiano Description: Close-up view of the top of one of the 55-gallon drums storing liquid where the "empty" label is visible.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Location: Sun Coast Resources
City: Beaumont
County/Parish: Jefferson
State: Texas
Photo No. 9
Photo File Name: DSCN7664 Date of Photo: 11/06/2024 Time of Photo: 0911 hrs. Photographer: Vince Damiano Description: Overview of three 55-gallon drums found on the loading dock that were labeled as empty. However, the drums on the right and left of the photo were half-full of an unknown liquid.
APPENDIX 2. SCR 11/12/24 RESPONSE
November 11, 2024 Mr. Vince Damiano US Environmental Protection Agency Region 6 1201 Elm Street, Suite 500 Dallas, TX 75270 Subject: EPA RCRA Investigation at Sun Coast Resources Beaumont Terminal Dear Mr. Damiano: The following serves as Sun Coast Resources LLC (SCR) response to the US Environmental Protection Agency (EPA) RCRA investigation at 5255 W Cardinal Dr., Beaumont, TX 77705. During the investigation three Areas of Concern (AOC) were noted by the investigators. SCR has completed the corrective actions for the three AOC and have documentation below. Area of Concern 1: Some used oil totes were not visibly labeled (side facing out) as used oil. Corrective action- SCR has placed outward facing labels on all used oil totes that required them. Please see below for photographic documentation.
6405 Cavalcade Street Building 1 Houston, Texas 77026 800-677-FUEL (3835) 713-844-9600
www.suncoastresources.com
6405 Cavalcade Street Building 1 Houston, Texas 77026 800-677-FUEL (3835) 713-844-9600
www.suncoastresources.com
Area of Concern 2: Two drums were mistakenly labeled as empty; one filter drum did not have a lock ring securing the lid. Corrective action- Labels were placed on the two unlabeled drums and a lock ring was installed on the third drum securing the lid. Please see below for photographic documentation.
6405 Cavalcade Street Building 1 Houston, Texas 77026 800-677-FUEL (3835) 713-844-9600
www.suncoastresources.com
Area of Concern 3: Used oil tote storage area did not have secondary containment. Corrective action- Used oil totes were moved inside an expandable soft berm on the loading dock.
6405 Cavalcade Street Building 1 Houston, Texas 77026 800-677-FUEL (3835) 713-844-9600
www.suncoastresources.com
If you have questions or need additional information, please do not hesitate to contact me at (713) 969-3809. Thank you for your assistance in this matter. Sincerely, Taylor Schauder Environmental Compliance Specialist
6405 Cavalcade Street Building 1 Houston, Texas 77026 800-677-FUEL (3835) 713-844-9600
www.suncoastresources.com