Document EmYpdwxeZMZR2XMQb87v0RpxL

Inspection Entry Date/Time EPA REGION 6 Enforcement Division INSPECTION REPORT 11/4/2024 9:42 (CT) Inspection Exit Date/Time 11/4/2024 10:55 (CT) Regulatory Program Type of Inspection RCRA Focused Compliance Inspection (FCI) Announced: No (tenants and related facilities) 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 P.C. Pfeiffer Co., Inc. N/A 1255 Main St. Beaumont, TX 77701 Jefferson County Non-generator 488320 P.C. Pfeiffer offloads cargo from vessels and loads it onto trucks and railcars for delivery 30.079435, -94.09214 Additional Persons Participating in Inspection: Name Title Organization Email Angela Hays Inspector EPA REGION 6 Hays.Angela@epa.gov Sandesh Thapa Inspector EPA REGION 6 Thapa.Sandesh@epa.gov Jon Herbay Contractor Eastern Research Jon.Herbay@erg.com Group (ERG) 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 11:49:17 -05'00' Vince.Damiano@erg.com 02/06/2025 (703) 633-1732 Page 1 of 5 P.C. Pfeiffer, Co., Inc. Inspection Date: 11/04/2024 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 P.C. Pfeiffer, Co., Inc. Name Vince Damiano Phone Email (703) 633-1732 Vince.Damiano@erg.com Opening Conf. Yes Closing Conf. 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 Chris Gobert (409) 299-7097 ChrisG@PCPfeifferco.com Yes Yes Page 2 of 5 P.C. Pfeiffer, Co., Inc. Inspection Date: 11/04/2024 Facility General Description Tenant/Area P.C. Pfeiffer Co., Inc. Inspection Date 11/04/2024 Process Description P.C. Pfeiffer (PCP) offloads cargo from vessels and loads it onto trucks and railcars for delivery. PCP is covered under the Port of Beaumont's MARPOL COA for Annexes I and V. Area of Concern Yes SECTION II - OBSERVATIONS Tenant: P.C. Pfeiffer Co., Inc. Section: 2.1 Date: 11/04/24, 09:42 AM Contains AOC: Yes Lead Inspector: Vince Damiano Attendees: Chris Gobert (Superintendent) Contains CBI: No PCP is located within the Port of Beaumont and removes cargo from vessels and loads it onto railcars and trucks for delivery. Primarily, PCP handles pulp paper, project cargo, motors, steel, and rails. PCP stores the cargo in their warehouse before loading it for delivery. PCP uses its own equipment to move cargo which includes heavy-lift forklifts, small forklifts, and yard trucks. PCP generates used oil and oil filters from maintenance on its equipment which is picked up by Action Oil (TXR000085911) for recycling. PCP is covered under Port of Beaumont's MARPOL COA, but Mr. Gobert stated they do not remove trash or waste from vessels. PCP is not registered with the EPA and is considered a non-generator of hazardous waste. Following the opening conference, the inspection team conducted a visual inspection of PCP's maintenance area and fuel tank shed. The inspection team first entered the fuel shed where two fuel tanks were found: one 500-gallon tank contained unleaded gasoline and one 1000-gallon tank contained diesel fuel. Inside the fuel tank shed, the inspection team observed several containers and drums of material that appeared to be waste due to the condition of the containers. Mr. Gobert was unsure of the contents of the following containers found in the fuel shed: Four 1-gallon containers were found on a shelf behind the fuel tanks which were one-quarter full to three-quarters full of material (see Appendix 1 - Photo 1). Mr. Gobert stated he believes the two blue 1-gallon containers are stencil dye, but they have not used that product in many years. One half-full 5-gallon container which was unlabeled and appeared to contain oily liquid (see Appendix 1 - Photo 3). Several 55-gallon drums were found in poor condition, three of which were storing material. The 55gallon drum pictured in Photo 4 (one-quarter full), the red 55-gallon drum with the words waste oil pictured in Photo 5 (full), and the 55-gallon drum pictured in Photos 5-6 (full). Mr. Godert stated these drums had been stored here since before his time at the facility and was unsure of their contents. One 55-gallon drum that was half-full of material was found next to the fuel tanks (see Appendix 1 - Photo 9). The inspection team requested waste determinations on all of the drums and containers discussed above [AOC #1 - PCP did not make a waste determination - 40 CFR 262.11]. The inspection team also observed four 3 of 5 P.C. Pfeiffer, Co., Inc. Inspection Date: 11/04/2024 discarded used oil filters in the fuel tank shed (see Appendix 1 - Photos 2 and 8). The filters were discarded for what appeared to be a long time and did not contain any free-flowing oil at the time of the inspection. Behind the fuel shed, the inspection team observed an oily sheen found accumulating on the water and concrete pad which shows evidence of an oil spill that was not properly managed (see Appendix 1 - Photos 10 to 11) [AOC #2 - PCP did not respond to and properly manage a release of used oil - 40 CFR 279.22 (d)]. The inspection team moved into the maintenance area where PCP repairs their equipment. The inspection team observed several instances of used oil spills accumulating on the concrete floor throughout the maintenance area (see Appendix 1 - Photos 12 and 17 to 20) [see AOC#2]. PCP staff was actively cleaning up and containing used oil spills while the inspection team was conducting the visual inspection, as shown in Photo 12. Next, the inspection team observed PCP's used oil storage area found within the maintenance area. The inspection team observed one 500-gallon used oil container that was labeled "Used Oil." The container was closed and in good condition. PCP has three other 500-gallon containers that are no longer in use. On the ground of the used oil storage area, the inspection team observed six 5-gallon containers and one 10-gallon container storing used oil filters that still contained used oil (see Appendix 1 - Photos 12 to 14). Above the containers on the ground, there were several used oil filters draining into drip pads (see Appendix 1 - 15 and 16). Since the used oil filters were not drained by one of the methods in 40 CFR 261.4(b)(13), the used oil filters should be properly managed and labeled as "Used Oil" [AOC #3: PCP did not clearly label containers used to store used oil with the words "Used Oil." - 40 CFR 279.22 (c)(1)]. The inspection moved outside of the maintenance area where two 55-gallon drums were found storing liquid; both drums were approximately three-quarters full (see Appendix 1 - Photos 21 and 22). Mr. Gobert was uncertain about the contents of the two drums but guessed it may be rainwater. The inspection requested a waste determination (see AOC#1). The inspection team continued to conduct the visual inspection along the perimeter of the maintenance building and observed two discarded aerosol cans (see Appendix 1 - Photos 23 and 24). The aerosol cans were rusted and appeared to be left outside for some time. 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 their potential AOCs. A closing conference was conducted at approximately 11:00 AM with PCP personnel. The AOCs were communicated during the closing. 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 The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation. Tenant: P.C. Pfeiffer Co., Inc. AOC #1 - PCP did not make a waste determination. Citation: 40 CFR 262.11 Section: 2.1 AOC #2 - PCP did not respond to and properly manage Citation: 40 CFR 279.22 (d) a release of used oil. 4 of 5 Section: 2.1 P.C. Pfeiffer, Co., Inc. Inspection Date: 11/04/2024 AOC #3 - PCP 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 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 the provision of documents requested. SECTION VI - LIST OF APPENDICES Appendix 1. Photograph Log 5 of 5 APPENDIX 1. PHOTOGRAPH LOG UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: P.C. Pfeiffer Co., Inc. City: Beaumont County/Parish: Jefferson State: Texas Photo No. 1 Photo File Name: DSCN7620 Date of Photo: 11/04/2024 Time of Photo: 10:16 hrs. Photographer: Vince Damiano Description: View of four 1-gallon containers found on a shelf in the fuel tank shed containing material that was unidentified at the time of the inspection. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: P.C. Pfeiffer Co., Inc. City: Beaumont County/Parish: Jefferson State: Texas Photo No. 2 Photo File Name: DSCN7621 Date of Photo: 11/04/2024 Time of Photo: 10:16 hrs. Photographer: Vince Damiano Description: View of a discarded used oil filter that was found on the floor of the fuel tank shed. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: P.C. Pfeiffer Co., Inc. City: Beaumont County/Parish: Jefferson State: Texas Photo No. 3 Photo File Name: DSCN7622 Date of Photo: 11/04/2024 Time of Photo: 10:18 hrs. Photographer: Vince Damiano Description: View of a half-full 5-gallon container found in the fuel tank shed; the contents were unknown at the time of the inspection but appeared to be an oily liquid. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: P.C. Pfeiffer Co., Inc. City: Beaumont County/Parish: Jefferson State: Texas Photo No. 4 Photo File Name: DSCN7623 Date of Photo: 11/04/2024 Time of Photo: 10:19 hrs. Photographer: Vince Damiano Description: View a 55-gallon drum found in the fuel tank shed that was full of an unknown material. The drum appeared to be old and rusted. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: P.C. Pfeiffer Co., Inc. City: Beaumont County/Parish: Jefferson State: Texas Photo No. 5 Photo File Name: DSCN7625 Date of Photo: 11/04/2024 Time of Photo: 10:20 hrs. Photographer: Vince Damiano Description: View of two full 55-gallon drums (red drum in the front and the drum directly behind the red one) found in the fuel tank shed that was storing unknown material at the time of the inspection. The other drums pictured were empty. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: P.C. Pfeiffer Co., Inc. City: Beaumont County/Parish: Jefferson State: Texas Photo No. 6 Photo File Name: DSCN7626 Date of Photo: 11/04/2024 Time of Photo: 10:22 hrs. Photographer: Vince Damiano Description: View of a label on one of the 55-gallon drums found in the fuel tank shed found to be storing unknown liquids. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: P.C. Pfeiffer Co., Inc. City: Beaumont County/Parish: Jefferson State: Texas Photo No. 7 Photo File Name: DSCN7627 Date of Photo: 11/04/2024 Time of Photo: 10:22 hrs. Photographer: Vince Damiano Description: Another view of the drums discussed above in Photos 5 and 6. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: P.C. Pfeiffer Co., Inc. City: Beaumont County/Parish: Jefferson State: Texas Photo No. 8 Photo File Name: DSCN7628 Date of Photo: 11/04/2024 Time of Photo: 10:23 hrs. Photographer: Vince Damiano Description: View of three discarded used oil filters found in the fuel tank shed. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: P.C. Pfeiffer Co., Inc. City: Beaumont County/Parish: Jefferson State: Texas Photo No. 9 Photo File Name: DSCN7629 Date of Photo: 11/04/2024 Time of Photo: 10:25 hrs. Photographer: Vince Damiano Description: View of a half-full 55-gallon drum found inside the fuel tank shed that was storing an unidentified liquid at the time of the inspection. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: P.C. Pfeiffer Co., Inc. City: Beaumont County/Parish: Jefferson State: Texas Photo No. 10 Photo File Name: DSCN7630 Date of Photo: 11/04/2024 Time of Photo: 1028 hrs. Photographer: Vince Damiano Description: View of the concrete pad behind the fuel tank shed that had evidence of a used oil spill that was not properly cleaned up. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: P.C. Pfeiffer Co., Inc. City: Beaumont County/Parish: Jefferson State: Texas Photo No. 11 Photo File Name: DSCN7631 Date of Photo: 11/04/2024 Time of Photo: 10:28 hrs. Photographer: Vince Damiano Description: Another view of the concrete pad behind the fuel tank shed that had evidence of a used oil spill that was not properly cleaned up. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: P.C. Pfeiffer Co., Inc. City: Beaumont County/Parish: Jefferson State: Texas Photo No. 12 Photo File Name: DSCN7632 Date of Photo: 11/04/2024 Time of Photo: 10:31 hrs. Photographer: Vince Damiano Description: View of used oil spills found inside the maintenance area. PCP personnel were actively cleaning the spills during the inspection which are the piles of absorbent seen in the photo. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: P.C. Pfeiffer Co., Inc. City: Beaumont County/Parish: Jefferson State: Texas Photo No. 13 Photo File Name: DSCN7633 Date of Photo: 11/04/2024 Time of Photo: 10:32 hrs. Photographer: Vince Damiano Description: View of four 5-gallon containers storing used oil filters that were not labeled found in the used oil storage area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: P.C. Pfeiffer Co., Inc. City: Beaumont County/Parish: Jefferson State: Texas Photo No. 14 Photo File Name: DSCN76234 Date of Photo: 11/04/2024 Time of Photo: 10:32 hrs. Photographer: Vince Damiano Description: View of one 10-gallon container storing used oil filters which was not labeled found in the used oil storage area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: P.C. Pfeiffer Co., Inc. City: Beaumont County/Parish: Jefferson State: Texas Photo No. 15 Photo File Name: DSCN7635 Date of Photo: 11/04/2024 Time of Photo: 10:32 hrs. Photographer: Vince Damiano Description: View of two drip pads storing used oil filters which were not labeled found in the used oil storage area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: P.C. Pfeiffer Co., Inc. City: Beaumont County/Parish: Jefferson State: Texas Photo No. 16 Photo File Name: DSCN7636 Date of Photo: 11/04/2024 Time of Photo: 10:32 hrs. Photographer: Vince Damiano Description: Overview of the used oil storage area including inactive oil storage tanks and used oil filters. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: P.C. Pfeiffer Co., Inc. City: Beaumont County/Parish: Jefferson State: Texas Photo No. 17 Photo File Name: DSCN7637 Date of Photo: 11/04/2024 Time of Photo: 10:32 hrs. Photographer: Vince Damiano Description: View of a used oil spill found on the concrete floor of the maintenance area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: P.C. Pfeiffer Co., Inc. City: Beaumont County/Parish: Jefferson State: Texas Photo No. 18 Photo File Name: DSCN7638 Date of Photo: 11/04/2024 Time of Photo: 10:32 hrs. Photographer: Vince Damiano Description: View of a used oil spill found on the concrete floor of the maintenance area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: P.C. Pfeiffer Co., Inc. City: Beaumont County/Parish: Jefferson State: Texas Photo No. 19 Photo File Name: DSCN7639 Date of Photo: 11/04/2024 Time of Photo: 10:33 hrs. Photographer: Vince Damiano Description: View of a used oil spill found on the concrete floor of the maintenance area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: P.C. Pfeiffer Co., Inc. City: Beaumont County/Parish: Jefferson State: Texas Photo No. 20 Photo File Name: DSCN7640 Date of Photo: 11/04/2024 Time of Photo: 10:33 hrs. Photographer: Vince Damiano Description: View of a used oil spill found on the concrete floor of the maintenance area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: P.C. Pfeiffer Co., Inc. City: Beaumont County/Parish: Jefferson State: Texas Photo No. 21 Photo File Name: DSCN7641 Date of Photo: 11/04/2024 Time of Photo: 10:41 hrs. Photographer: Vince Damiano Description: View of a 55-gallon drum that was found in front of the main entrance to the msintenance area storing unkown liquid; approximatley full. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: P.C. Pfeiffer Co., Inc. City: Beaumont County/Parish: Jefferson State: Texas Photo No. 22 Photo File Name: DSCN7642 Date of Photo: 11/04/2024 Time of Photo: 10:41 hrs. Photographer: Vince Damiano Description: View of a 55-gallon drum that was found in front of the main entrance to the msintenance area storing unkown liquid; approximatley full. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: P.C. Pfeiffer Co., Inc. City: Beaumont County/Parish: Jefferson State: Texas Photo No. 23 Photo File Name: DSCN7643 Date of Photo: 11/04/2024 Time of Photo: 10:43 hrs. Photographer: Vince Damiano Description: View of a discarded aerosol can found on the ground along the perimeter of the maintenance building. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: P.C. Pfeiffer Co., Inc. City: Beaumont County/Parish: Jefferson State: Texas Photo No. 24 Photo File Name: DSCN7644 Date of Photo: 11/04/2024 Time of Photo: 10:43 hrs. Photographer: Vince Damiano Description: View of a discarded aerosol can found on the ground along the perimeter of the maintenance building. Location: P.C. Pfeiffer Co., Inc. City: Beaumont County/Parish: Jefferson State: Texas Photo No. 25 Photo File Name: DSCN7645 Date of Photo: 11/04/2024 Time of Photo: 10:48 hrs. Photographer: Vince Damiano Description: View of a 1-gallon container found on a shelf inside the fuel tank shed. The container was abiut fullfull of unknown liquid.