Document LKVkYvJn2XjoDgwLNO3RZJxy7
f t E A ~ United States
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Environmental Protection
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Agency
EPA REGION 6 Enforcement Division
INSPECTION REPORT
Inspection Entry
4/23/2025 10:45 AM (CT)
Date/Time
Inspection Exit Date/Time 4/23/2025 11:15 AM (CT)
Regulatory Program Type of Inspection
RCRA Compliance Evaluation Inspection (CEI)
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
Environmental Safety & Health Consulting Service Inc. LAR000037069 1085 Bert St.
Laplace, LA 70068 St. John the Baptist Parish N/A 488510 Environmental Safety & Health Consulting Service Inc. (ES&H) conducts emergency response, industrial cleaning, transportation of waste, and environmental remediation services. 30.0831, -90.51403
Additional Persons Participating in Inspection:
Name
Title
Organization Email
Sandesh Thapa
Inspector
EPA REGION 6 Thapa.Sandesh@epa.gov
Joseph Watson
Contractor
Eastern Research Joe.Watson@erg.com Group (ERG)
Lead Inspector: Vince Damiano
ERG
Vincent Damiano
Digitally signed by Vincent Damiano Date: 2025.06.06 15:47:15 -04'00'
Vince.Damiano@erg.com
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Environmental Safety & Health Consulting Service Inc.
Inspection Date: 4/23/2025
SECTION I - INTRODUCTION
Site Entry and Purpose of the Inspection
The Port of New Orleans and surrounding facilities were selected for inspection based on a 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 other records, including photographs taken, 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
RCRA Inspector/ Contractor/ERG
Manager/ES&H
Safety/ES&H
Name
Email
Vince Damiano Vince.Damiano@erg.com
Sandesh Thapa Thapa.Sandesh@epa.gov
Joseph Watson Joe.Watson@erg.com
Bertha Baskin
Marlon Guilbeau
Bbaskin@esandh.com Mguilbeau@esandh.com
Opening Closing Conf. Conf.
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Page 2 of 4
Environmental Safety & Health Consulting Service Inc.
Inspection Date: 4/23/2025
Facility General Description
Tenant/Area Environmental Safety & Health Consulting Service Inc.
Inspection
Date
Process Description
4/23/25 ES&H conducts emergency response, industrial cleaning,
transportation of waste, and environmental remediation
services. The facility does not maintain a MARPOL COA.
Area of Concern
Yes
SECTION II - OBSERVATIONS
Facility: Environmental Safety & Health Consulting Service Inc.
Section: 2.1
Date: 4/23/25, 10:45 AM Contains AOC: No Contains CBI: No
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Lead Inspector: Vince Damiano Attendees: Bertha Baskin (Manager) and Marcory Guilbeau (Safety)
ES&H, located in Laplace, LA, provides emergency environmental response and remediation services, industrial cleaning, waste transportation, and disposal. This location primarily houses the trucking division, which is responsible for transporting customers' waste to designated disposal facilities. ES&H operates five 70-barrel and four 130-barrel vacuum trucks for collecting and hauling liquid waste. The company also offers roll-off containers services. Both roll-offs and vacuum trucks are washed out before returning to the ES&H facility. While ES&H performs tank cleanings for customers, any waste generated from these activities is transported directly from the customer site to disposal and is not brought back to the ES&H facility. According to Ms. Baskin, the only waste generated at the facility is used oil from vehicle maintenance; no other waste streams are transported to or generated at this location. ES&H is registered with the EPA as a hazardous waste and used oil transporter under EPA ID LAR000037069.
After the opening conference, the inspection team observed ES&H's used oil storage area and equipment storage yard. Inside the used oil storage area, the inspection team observed 150-gallon used oil tank, a 40gallon drip bucket, and a 10-gallon drip bucket storing used oil that were not labeled as "used oil" (see Appendix 1 - Photos 1 to 3) [AOC #1 - ES&H did not clearly label containers used to store used oil with the words "Used Oil" - 40 CFR 279.45(g)(1)]. The inspection team then walked through the equipment storage yard and noted no areas of concern (AOCs).
The inspection team did not observe any other 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 11:15 AM with ES&H personnel. The AOCs were communicated during the closing. Following the inspection on 4/25/2025, Ms. Baskin sent a follow-up email in response to the AOCs observed during the inspection, including:
Photos of the used oil tank and containers labeled as used oil (see Appendix 2)
SECTION III - RECORDS REVIEW No RCRA-regulated records were reviewed during this focused onsite inspection.
Page 3 of 4
Environmental Safety & Health Consulting Service Inc.
Inspection Date: 4/23/2025
SECTION IV - AREAS OF CONCERN
The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation. Facility: Environmental Safety & Health Consulting Service Inc.
AOC #1 - ES&H did not clearly label containers used to Citation: 40 CFR 279.45(g)(1) store used oil with the words "Used Oil."
Section: 2.1
SECTION V - 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. 4/25/25 ES&H email - Ms. Baskin provided the inspection team with photos of corrections made towards AOCs observed.
SECTION VI - LIST OF APPENDICES Appendix 1. Photograph Log Appendix 2. 4/25/25 Response from ES&H
Page 4 of 4
APPENDIX 1. PHOTOGRAPH LOG
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Location: ES&H City: Laplace
County/Parish: St. John the Baptist State: Louisiana
Photo No. 1
Photo File Name: DSCN7968 Date of Photo: 4/23/2025 Time of Photo: 1107 hrs. Photographer: Vince Damiano Description: View of a 150-gallon used oil storage tank in the used oil storage area that was not labeled "Used Oil."
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Location: ES&H City: Laplace
County/Parish: St. John the Baptist State: Louisiana
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04 . 23 . 2025
Photo No. 2
Photo File Name: DSCN7969 Date of Photo: 4/23/2025 Time of Photo: 1107 hrs. Photographer: Vince Damiano Description: View of a 40-gallon used oil drip bucket in the used oil storage area that was not labeled "Used Oil."
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Location: ES&H City: Laplace
County/Parish: St. John the Baptist State: Louisiana
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Photo No. 3
Photo File Name: DSCN7970 Date of Photo: 4/23/2025 Time of Photo: 1110 hrs. Photographer: Vince Damiano Description: View of a 10-gallon used oil drip bucket in the used oil storage area that was not labeled "Used Oil."
APPENDIX 2. 4/25/25 RESPONSE FROM E&H
Outlook
RE: Follow-up From EPA Visit on 4/23/2025
From Bertha Baskin <bbaskin@esandh.com> Date Fri 4/25/2025 8:02 PM To Vince Damiano <Vince.Damiano@erg.com> Cc Joe Watson <Joe.Watson@erg.com>; Thapa, Sandesh <Thapa.Sandesh@epa.gov>; Lee Arcement
<larcement@esandh.com>; Marlon Guilbeau <mguilbeau@esandh.com>; Michael Vinci <mvinci@esandh .c o m >
@4 attachments (10 MB)
Used Oil TankJpg; Used Oil Bin (1)Jpg; Used Oil Bucket (shop)Jpeg; Used Oil Bucket (2)Jpeg;
Vince,
CAUTION : Don't open links or attachments unless you recognize the sender and know they are safe.
Attached are photos of the labeled containers. Let me know if you need any additional photos. Thanks.
Regards,
ES&
30th Anniversary
Bertha Baskin
Sales/Trucking Coordinator
"Safety is a full time job - don't make it a part time practice." Our Goal is Always Zero Incidents!
1085 Bert St. Laplace, La 70068 Office: 985-652-0090 Cell: 985-637-1586 www.ESandH.com
Appendix 2 Page 1 of 6
Go Green! Print this email only when necessary. Thanlk you for helping ES&H 1be environmentally responsible.
This e-mail and any attachments are intended solely for the person or entity to which addressed and may contain confidential and/or privileged information. Any review, dissemination, copying, printing or other use of this information 1by persons or entities other than the addressee is prohibited. If you have received this mail in error, please contact the sender immediately and delete the material from any computer.
From: Vince Damiano <Vince.Damiano@erg.com> Sent: Wednesday, April 23, 2025 4:45 PM To: Bertha Baskin <bbaskin@esandh.com> Cc: Joe Watson <Joe.Watson@erg.com>; Thapa, Sandesh <Thapa.Sandesh@epa.gov> Subject: Follow-up From EPA Visit on 4/23/2025
You don't often get email from vince.damiano@gg.Qll. Learn whY. this is imgortant
Hello Bertha,
I am following up with a list of items and notes from our inspection today. Below are initial Areas of Concern and items requested; you may follow up with pictures, write-ups, sample results, or however you see fit:
Unlabeled used oil tank and containers Again, thank you for taking the time out of your day to meet with us. Please let us know if you have any questions or concerns.
Thanks, Vince
ERG
Vince Damiano
Chemical Engineer, Chantilly Office Cell: (703) 835-6281 Vince.Damiano@fil9.&Q!!l
Appendix 2 Page 2 of 6
Appendix 2 Page 3 of 6
USED Oil
Appendix 2 Page 4 of 6
Appendix 2 Page 5 of 6
Appendix 2 Page 6 of 6