Document 827N2Re3r9gOVND2wv0vX515o
Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection
EPA REGION 6 Enforcement Division INSPECTION REPORT
6/5/2024 2:45 PM (CT) 6/5/2024 3:30 PM (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
Tri-State Environmental, LLC LAR000103140 512 Dudley Bernard Rd Golden Meadow, LA 70357 Lafourche Parish Non-generator 488310, 213112 Tri-State Environmental, LLC provides cleaning services for stationary equipment at Port Fourchon and loads supplies onto vessels for tenants renting dock space from it. 29.137588, -90.207553
Additional Persons Participating in Inspection:
Name
Title
Organization Email
Phone
Joyce Johnson
Inspector
EPA REGION 6 Johnson.Joyce-r6@epa.gov (214) 665-8548
Dedriel Gardner
Inspector
EPA REGION 6 Gardner.Dedriel@epa.gov (281) 983-2133
Neil Rapp
Contractor
Eastern Research Neil.Rapp@erg.com Group (ERG)
(480) 450-6517
Lead Inspector: Vince Damiano
Vincent Damiano
ERG
Digitally signed by Vincent Damiano Date: 2024.09.09 17:53:33 -04'00'
Vince.Damiano@erg.com
(703) 835-6281
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Tri-State Environmental, LLC
Inspection Date: 06/05/2024
SECTION I - INTRODUCTION
Site Entry and Purpose of the Inspection Type of inspection: Focused Compliance Inspection (FCI)
Port Fourchon 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 maintaining 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 verbal or written statements made during or after the on-site inspection, and 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
Name
Lead Inspector/ Contactor/ERG
RCRA Inspector/ Contractor/ERG
Inspector/Enforcement Officer/EPA Region 6
Inspector/Enforcement Officer/EPA Region 6
Vince Damiano Neil Rapp
Joyce Johnson Dedriel Gardner
Phone
Email
(703) 835-6281 Vince.Damiano@erg.com
Opening Conf.
Yes
Closing Conf.
Yes
(480) 450-6517 Neil.Rapp@erg.com
Yes
Yes
(214) 665-8548 Johnson.Joyce-r6@epa.gov Yes
Yes
(281) 983-2133 Gardner.Dedriel@epa.gov Yes
Yes
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Tri-State Environmental, LLC Facility General Description
Inspection Date: 06/05/2024
Tenant/Area
Inspection Date
Tri-State Environmental, LLC 06/05/24
Process Description
Tri-State Environmental, LLC (Tri-State) provides cleaning services for stationary equipment at the port. However, Tri-State only provides the cleaning crew for these services, and all waste is managed by its customers at their own facilities. Tri-State also leases space in its yard and dock to two tenants, Walter Oil & Gas and Petrifac. Tri-State loads supplies (i.e., water, groceries, chemicals) onto vessels for Walter Oil & Gas's offshore rigs and offloads domestic trash for tenants at its dock space. The company loads the domestic trash directly into dumpsters, which are managed by the tenants. Tri-State does not receive any waste besides municipal trash. TriState is a non-generator of hazardous waste. Facility personnel stated that Tri-State maintains a MARPOL COA for Annex V.
Areas of Concern
No
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Tri-State Environmental, LLC
Inspection Date: 06/05/2024
SECTION II - OBSERVATIONS
Tenant: Tri-State Environmental, LLC
Section: 2.1
Date: 6/5/2024, 2:45 P.M.
Contains AOC: No Contains CBI: No
Lead Inspector: Vince Damiano
Attendees: Michael Joiner (Manager), Scott Carter (Operations), Ron Johnson (Crane/Dispatch)
Mr. Joiner provided the inspection team with a summary of operations at Tri-State. The company provides cleaning services for stationary equipment at Port Fourchon. However, Tri-State only provides the cleaning crew for these services, and all waste is managed by its customers at their own facilities. Mr. Joiner stated that no waste is transported back to Tri-State for disposal. Mr. Joiner added that Tri-State planned to enter the waste transportation business and had recently submitted its notification to EPA to register as a used oil transporter.
Tri-State also leases space in its yard and dock to two tenants, Walter Oil & Gas and Petrifac. Tri-State loads supplies (i.e., water, groceries, chemicals) onto vessels for Walter Oil & Gas's offshore rigs and offloads domestic trash for tenants at its dock space. Tri-State places the domestic trash directly into dumpsters, which are managed by the tenants. Mr. Joiner stated that Tri-State maintains a MARPOL COA for Annex V and that Tri-State does not receive any waste across its dock besides domestic trash. Mr. Joiner also stated that Tri-State is a non-generator of hazardous waste, and that the facility does not perform any equipment maintenance that generates used oil.
After the opening conference, the inspection team conducted a visual inspection of the facility's dock space and yard. No areas of concern (AOCs) were identified during the visual inspection; however, further EPA review may change or add to their potential AOCs. A closing conference was conducted at approximately 3:20 PM with Tri-State personnel. The inspection team requested a copy of the Tri-State's MARPOL COA, an example of the shipping documentation for the domestic trash offloaded at its dock, and a copy of the notification sent to EPA for its transporter ID. At the time of writing this report, the inspection team had not received the requested documentation from Tri-State.
SECTION III - RECORDS REVIEW
No RCRA regulated records were reviewed during this focused onsite inspection besides those mentioned in Section II.
SECTION IV - AREA OF CONCERN No apparent AOCs were identified during this inspection. SECTION V -FOLLOW UP No documents or files were provided by the facility.
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