Document GQjyVXYLv0KdJjJgDvz7vdpY

Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 6 Enforcement Division INSPECTION REPORT 04/15/2024 1:00 (CT) 04/15/2024 2:00 (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 Dunham Price Group LA0001014588 210 Mike Hooks Rd Westlake, LA 70669 Calcasieu Parish None N/A Dunham Price Group is a concrete manufacturing company. 30.232592, -93.251989 Additional Persons Participating in Inspection: Name Title Organization Elizabeth Pham Inspector EPA REGION 6 Sandesh Thapa Inspector EPA REGION 6 Anshul Paripati Contractor Eastern Research Group (ERG) Email Pham.elizabeth@epa.gov Thapa.sandesh@epa.gov Anshul.Paripati@erg.com Phone (214) 665-8354 (214) 665-2265 (571) 535-1503 Lead Inspector: Cameron Tanaka Cameron Tanaka Date: 2024.07.24 22:25:52 -04'00' Digitally signed by Cameron Tanaka ERG Cameron.Tanaka@erg.com 07/24/2024 (703) 633-1632 ext. 11632 Page 1 of 6 Dunham Price Group Inspection Date(s): 04/15/2024 SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection Type of inspection: Focused Compliance Inspection (FCI) The Port of Lake Charles 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, port related 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 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 RCRA Inspector/ Contractor/ERG Inspector/Enforcement Officer/EPA Region 6 Inspector/Enforcement Officer/EPA Region 6 Name Phone Email Opening Closing Conf. Conf. Cameron Tanaka (703) 633-1632 Cameron.Tanaka@erg.com Yes No ext. 11632 Anshul Paripati (571) 535-1503 Anshul.Paripati@erg.com Yes Yes Elizabeth Pham (214) 665-8354 Pham.elizabeth@epa.gov Yes Yes Sandesh Thapa (214) 665-2265 Thapa.sandesh@epa.gov Yes Yes Page 2 of 6 Dunham Price Group Inspection Date(s): 04/15/2024 Facility General Description Tenant/Area Dunham Price Group Inspection Date 04/15/24 Process Description Dunham Price Group (DPG) is a concrete manufacturer. Their cement operations do not generate any hazardous waste. The only material they remove from ships is aggregates for their concrete manufacturing. DPG does not load ships. The facility has a MARPOL Annex I and V COA. According to facility personnel, none of the Annex I or V waste would cross their property. DPG personnel could not recall ever receiving waste from vessels. Area of Concern Yes Page 3 of 6 Dunham Price Group Inspection Date(s): 04/15/2024 SECTION II - OBSERVATIONS Tenant: Dunham Price Group Section: 2.1 Date: 04/15/24, 1:00 PM Contains AOC: Yes Contains CBI: No Lead Inspector: Cameron Tanaka Attendees: Kevin Landreneau (Equipment Manager) and Jody Singletary (COO) DPG is a concrete manufacturer. Their cement operations do not generate any hazardous wastes. The facility has a stormwater discharge permit. The only material that they take off ships is aggregates for their concrete manufacturing, and they do not load ships. DPG has a MARPOL Annex I and V COA from the USCG and they have an EPA ID for stormwater discharges (LA0001014588). In the case of MARPOL services, no MARPOL waste would cross their property, and the facility personnel could not recall ever receiving MARPOL wastes from vessels. The facility generates waste in the form of used oil, used antifreeze/coolant, and used batteries. These wastes are all taken off site by third parties, and the batteries are recycled. Approximately every quarter, they generate about 300 to 400 gallons of used oil which are pumped into an aboveground metal tank and removed by third party vacuum trucks. Their used antifreeze is stored in a barrel with a screen over it taken off site by the same vendors. In a follow-up email response (see Appendix 2), Ms. Linda Ash included used oil shipping receipts (see Appendix 3). There were no issues noted by the inspection team with these receipts. During the inspection, the inspection team visually inspected the locations where waste is stored at the facility. The inspection team viewed DPG's used oil tank and its secondary containment (see Appendix 1 - Photo 1, 2). The tank had a used oil label that was legible but faded. Ms. Ash included a photo of this used oil tank with a new label in her follow-up email (see Appendix 2, Appendix 4 - Photo 1). The inspection team also viewed the facility's used antifreeze drum and noted that the label was not legible and the drum was not dated (see Appendix 1 - Photo 3) [AOC #1 - DPG did not label or mark clearly their used antifreeze with one of the following phrases: "Universal Waste- Antifreeze," or "Waste Antifreeze," or "Used Antifreeze."- La. Admin. Code tit. 33, V-3823 A.8.; AOC #2 - DPG did not provide a demonstration of the length of time that the universal waste has been accumulated from the date it becomes a waste or is received - La. Admin. Code tit. 33, V-3825 C.]. Ms. Ash included a photo of this antifreeze drum with a new label in her follow-up email (see Appendix 2, Appendix 4 - Photo 2). The inspection team also noted that their used batteries were not properly labeled or dated [AOC #3 - DPG did not label or mark clearly their used batteries with any one of the following phrases: "Universal Waste-Battery(ies)," or "Waste Battery(ies)," or "Used Battery(ies)." - 40 CFR 273.14(a); AOC #4 - DPG did not provide a demonstration of the length of time that the universal waste has been accumulated from the date it becomes a waste or is received - 40 CFR 273.15(c)]. Ms. Ash included a photo of this used battery area with a label above it in her follow-up email (see Appendix 2, Appendix 4 - Photo 3). No other apparent AOCs were observed by the inspection team the time of the inspection. A closing conference was conducted at approximately 1:50 PM with DPG personnel. The inspection team departed at 2:00 PM. Page 4 of 6 Dunham Price Group Inspection Date(s): 04/15/2024 SECTION III - RECORDS REVIEW No RCRA regulated records reviewed during this focused onsite inspection. SECTION IV - APPARENT AREAS OF CONCERN The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation. Tenant: Dunham Price Group AOC #1 - DPG did not label or mark clearly their used antifreeze with one of the following phrases: "Universal Waste- Antifreeze," or "Waste Antifreeze," or "Used Antifreeze." Citation: La. Admin. Code tit. 33, V- Section: 2.1 3823 A.8. AOC #2 - DPG did not provide a demonstration of the length of time that the universal waste has been accumulated from the date it becomes a waste or is received. Citation: La. Admin. Code tit. 33, V- Section: 2.1 3825 C. AOC #3 - DPG did not label or mark clearly their used batteries with any one of the following phrases: "Universal Waste-Battery(ies)," or "Waste Battery(ies)," or "Used Battery(ies)." Citation: 40 CFR 273.14(a) Section: 2.1 AOC #4 - DPG did not provide a demonstration of the length of time that the universal waste has been accumulated from the date it becomes a waste or is received Citation: 40 CFR 273.15(c) Section 2.1 SECTION V - FOLLOW UP Follow-Up Any facility follow-up items are as discussed in each facility's observations in Section II. Documents or files provided by the facilities were transmitted via email and included responses to areas of concern or provision of documents requested. Communication Log During and after the inspection, additional information was emailed to EPA including: 1. 04/23/24 DPG email - Linda Ash sent several photographs of corrective actions implemented at the site and the documents requested during the inspection. Page 5 of 6 Dunham Price Group SECTION VI - LIST OF APPENDICES Appendix 1. Photograph Log Appendix 2. Follow-Up Email from Dunham Price Appendix 3. Used Oil Shipping Receipts from Dunham Price Appendix 4. Follow-Up Photographs from Dunham Price Inspection Date(s): 04/15/2024 Page 6 of 6 APPENDIX 1. PHOTOGRAPH LOG UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: Dunham Price Group City: Westlake County/Parish: Calcasieu State: Louisiana Photo File Name: DSCN7173 Date of Photo: 04/15/2024 Time of Photo: 1:42 hrs. Photographer: Anshul Paripati Description: Overview of DPG's used oil tank directly outside of their main office building. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: Dunham Price Group City: Westlake County/Parish: Calcasieu State: Louisiana Photo File Name: DSCN7174 Date of Photo: 04/15/2024 Time of Photo: 1:43 hrs. Photographer: Anshul Paripati Description: Overview of DPG's used oil tank with its secondary containment directly outside of their main office building. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: Dunham Price Group City: Westlake County/Parish: Calcasieu State: Louisiana Photo File Name: DSCN7175 Date of Photo: 04/15/2024 Time of Photo: 1:49 hrs. Photographer: Anshul Paripati Description: DPG's 55-gallon used antifreeze drum with an unclear label in the facility's maintenance shop. APPENDIX 2. FOLLOW-UP EMAIL FROM DUNHAM PRICE Appendix 2 Page 1 of 1 APPENDIX 3. USED OIL SHIPPING RECEIPTS FROM DUNHAM PRICE Appendix 3 Page 1 of 2 Appendix 3 Page 2 of 2 APPENDIX 4. FOLLOW-UP PHOTOGRAPHS FROM DUNHAM PRICE Appendix 4 Page 1 of 3 Appendix 4 Page 2 of 3 Appendix 4 Page 3 of 3