Document 7QV73ooRzRJ4LN6be3k3eL0B
f t E A ~ United States
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Environmental Protectior
,
Agency
Region 6 - Enforcement & Compliance Assurance Division
INSPECTION REPORT
Inspection Date(s): Media Program: Regulatory Program(s)
03/03/2026 RCRA Generator; Recycler
Company Name: Facility Name: Facility Physical Location:
(city, state, zip code) Mailing address:
(city, state, zip code) County/Parish: Facility Phone Number Facility Contact:
ALX Industries LLC
ALX Industries LLC
2204 Catalina Dr
Pasadena, TX, 77503
Same
Same
Harris
713-410-4517 Candi Stansbury
I I Title: General Manager
Email: candi@alxindustries.com
FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC:
110071381300 TXR000080711 SWR# 91142 331492 3341
Personnel participating in inspection:
Bill Mansfield
US EPA Region 6
Candi Stansbury
ALX Industries LLC
Priscilla Tenorio
ALX Industries LLC
Inspector General Manager Admin Assistant
EPA Lead Inspector Signature/Date
Supervisor Signature/Date
WILLIAM MANSFIELD Date: 2026.04.14 11 :21 :51 -05'00' Digitally signed by WILLIAM MANSFIELD
Bill Mansfield
Date
DEBRA PANDAK
Digitally signed by DEBRA P, NOAK Date: 2026.04.14 11 :35:07 -0 '00'
Debra Pandak
Date
6ENFORM-019-R9 (02/27/2025)
1
ALX Industries 2204 Catalina Dr. Inspection Date 03/03/2026
Section I - INTRODUCTION
PURPOSE OF THE INSPECTION I, Bill Mansfield, EPA Region 6 inspector arrived at ALX Industries at 3:20PM on 03/03/2026 for an announced inspection. I met with Candi Stansbury the General Manager and Priscilla Tenorio the Administrative Assistant. I presented my credentials to Candi and informed her that this was an EPA inspection to determine the facility's compliance with the Resource Conservation and Recovery Act (RCRA). The scope of the inspection is a Compliance Evaluation Inspection (CEI) and includes evaluation of the facility's hazardous waste management activities. I provided the facility representatives with the US EPA Small Business Resources Information Sheet and the Notice Regarding Proprietary/Confidential Business Information form.
FACILITY DESCRIPTION ALX Industries' 2204 Catalina Dr. facility is a recycling facility that processes photographic chemicals and films to reclaim silver. The facility consists of an office area and warehouse. The EPA ID TXR000080711 associated with the facility address of 2204 Catalina Dr last notified as a RCRA transporter, transfer facility, receiver of hazardous waste from off-site, and a recycler of hazardous waste in August of 2012.
Section II - OBSERVATIONS During the opening conference I was informed by the General Manager that the founder of the company had passed away in October 2024 and the facility's bank account was frozen for about 4 months. The General Manager also shared that Amy Alexander is the Dependent Administrator and Legal Final Signatory of ALX Industries. During the walk-through of the facility, I observed the waste management containment and procedures. Warehouse: During the inspection I observed approximately 80 totes stacked two and three high throughout the warehouse (Appendix 1, photos 1 and 2). It was difficult to move around the containers as there was little to no aisle spacing (Appendix 1, photos 1 and 2). The containers that I could get to had small cards (business card style) sitting on top with a date to indicate when the material was received. The totes are full of either fixer or developer solutions used in photographic processing. I observed the electrolytic recovery area (Appendix 1, photo 1). I then observed the peristaltic recovery area that had two totes used for processing (Appendix 1, photo 3) . A map of the warehouse and operating areas was provided, and I took a picture for documentation (Appendix 1, photo 4). I observed a tote with a cutoff top in the post treatment POTW discharge area (Appendix 1, photo 7) and per the General Manager, it is rinse water from washing totes.
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ALX Industries 2204 Catalina Dr. Inspection Date 03/03/2026
Section III - AREAS OF CONCERN (AOC) The closing meeting was attended by me, Bill Mansfield (EPA Inspector), Candi Stansbury (General Manager), and Pricilla Tenorio (Administrative Assistant). I discussed the following AOC with them:
AOC(1) Aisle spacing and General Housekeeping. There was little to no room to walk or
maneuver between the totes. Although there are no regulatory requirements, the ability to detect leaks or address emergencies may be hindered. I fielded questions from facility personnel and provided information about the next steps in the inspection process. Section IV - FOLLOW UP EPA is waiting for information requested from the facility. 1. POTW Permit 2. Sampling results to meet permit discharge limits 3. Payment records for penalty from 2023 EPA enforcement Order 4. eManifest SOP 5. Records showing 75% of incoming hazardous waste has been processed for the year 2025 (40 C.F.R. 261.1 (c)(8)). Section V - LIST OF APPENDICES Appendix 1 - Photo Log - 8 photos taken 03/03/2026
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ALX Industries 2204 Catalina Dr. Inspection Date(s) 03/03/2026
Appendix 1 Photograph Log
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Facility/Location:
Photo No. 1
ALX Industries 2204 Catalina Dr.
City: Pasadena
County: Harris
Filename: TWC_0863.JPG
Photo Date:
Photographer: Bill Mansfield
State: TX 03/03/2026
Witness Name:
Direction: W Time: 17:00:12 NA
Description: Totes of fixer and developer to be processed.
Latitude: N/A
Longitude: N/A
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Facility/Location:
Photo No. 2
ALX Industries 2204 Catalina Dr.
City: Pasadena
County: Harris
Filename: TWC_0864.JPG
Photo Date:
Photographer: Bill Mansfield
State: TX 03/03/2026
Witness Name:
Direction: W Time: 17:08:58 NA
Description: Totes of fixer and developer to be processed.
Latitude: N/A
Longitude: N/A
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Facility/Location:
Photo No. 3
ALX Industries 2204 Catalina Dr.
City: Pasadena
County: Harris
Filename: TWC_0865.JPG
Photo Date:
Photographer: Bill Mansfield
State: TX 03/03/2026
Witness Name:
Direction: NW Time: 17:17:47 NA
Description: Peristaltic treatment process. Latitude: N/A
Longitude: N/A
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Facility/Location:
Photo No. 4
ALX Industries 2204 Catalina Dr.
City: Pasadena
County: Harris
Filename: TWC_0866.JPG
Photo Date:
Photographer: Bill Mansfield
State: TX 03/03/2026
Witness Name:
Direction: Time: 17:20:24 NA
-
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31
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Description: Facility layout diagram. Latitude: N/A
Longitude: N/A
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Facility/Location:
Photo No. 5
ALX Industries 2204 Catalina Dr.
City: Pasadena
County: Harris
Filename: TWC_0867.JPG
Photo Date:
Photographer: Bill Mansfield
State: TX 03/03/2026
Witness Name:
Direction: N Time: 17:23:57 NA
Description: Containers of material awaiting treatment in the final electrolytic treatment area.
Latitude: N/A
Longitude: N/A
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Facility/Location:
Photo No. 6
ALX Industries 2204 Catalina Dr.
City: Pasadena
County: Harris
Filename: TWC_0868.JPG
Photo Date:
Photographer: Bill Mansfield
State: TX 03/03/2026
Witness Name:
Direction: N Time: 17:26:59 NA
Description: Conical container and tote in the iron treatment area.
Latitude: N/A
Longitude: N/A
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Facility/Location:
Photo No. 7
ALX Industries 2204 Catalina Dr.
City: Pasadena
County: Harris
Filename: TWC_0869.JPG
Photo Date:
Photographer: Bill Mansfield
State: TX 03/03/2026
Witness Name:
Direction: N Time: 17:29:08 NA
Description: Open top tote of rinse water and post treatment POTW discharge area.
Latitude: N/A
Longitude: N/A
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Photo No. 8
Facility/Location:
I ALX Industries 2204 Catalina Dr.
City: Pasadena
County: I Harris
Filename: TWC_0870.JPG
Photo Date:
Photographer: Bill Mansfield
I State: I TX
I Direction: I W
03/03/2026 I
Time: I 17:42:29
Witness Name: l NA
Description: Front of facility. Latitude: N/A
Longitude: N/A