Document MJ3ynRDp1BZo32pQp9LgXQMmV
Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection
EPA REGION 6 Enforcement Division INSPECTION REPORT
6/4/2024 1:45 PM (CT) 6/4/2024 3:45 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
Mike's Filter & Supply, Inc. LAR000041269 2277 Denley Rd, Houma, LA 70363 Terrebonne Parish Small Quantity Generator 562111 Mike's Filter & Supply, Inc. provides waste transportation services and operates a solvent parts washer business. 29.548035, -90.682605
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 17:52:51 -04'00'
Vince.Damiano@erg.com
(703) 835-6281
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Mike's Filter & Supply, Inc.
Inspection Date: 06/04/2024
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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Inspection Date: 06/04/2024
Facility General Description
Tenant/Area Mike's Filter & Supply, Inc.
Inspection Date
06/04/24
Process Description
Mike's Filter & Supply, Inc. (Mike's Filter) is a transporter for hazardous, non-hazardous, and universal waste, as well as used oil. The company operates a fleet of vacuum trucks, tanker trucks, roll-off trucks, and box trucks for transporting bulk and containerized waste. Mike's Filter either transports the waste directly to a disposal facility or to its Houma, Louisiana location which acts as a transfer facility for hazardous waste and used oil. The company does not consolidate hazardous waste at its transfer facility. Mike's Filter also operates a solvent parts washer business which includes a solvent distilling system for recycling dirty solvent. Mike's Filter is a small quantity generator (SQG) of hazardous waste and does not maintain a MARPOL COA.
Areas of Concern
Yes
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SECTION II - OBSERVATIONS
Tenant: Mike's Filter & Supply, Inc.
Section: 2.1
Date: 6/4/2024, 1:45 P.M.
Contains AOC: Yes
Lead Inspector: Vince Damiano Attendees: Kerry LaJaunie (VP Operations)
Contains CBI: No
Mike's Filter is a transporter for hazardous, non-hazardous, and universal waste, as well as used oil. The company operates a fleet of vacuum trucks, tanker trucks, roll-off trucks, and box trucks for transporting bulk and containerized waste. The company will either transport the waste directly to a disposal facility or to its Houma, Louisiana location which acts as a transfer facility for hazardous waste and used oil. The company does not consolidate hazardous waste at its transfer facility. Mike's Filter transports used oil, oily materials, and wastewater to American Advanced Technologies (AAT) for disposal. Non-hazardous waste is typically sent to River Birch Landfill or Republic, while universal waste is transported to LEI. The company transports hazardous waste to Giant Resource Recovery and Clean Earth Alabama for disposal.
Mike's Filter also operates a solvent parts washer business which includes a solvent distilling system for recycling dirty solvent. The company services its customers' parts washers and takes the dirty solvent back to its facility for recycling. Once recycled, the clean solvent is sent back out to customers for reuse. The drums used to transport dirty solvent are washed out with clean solvent and reused; the rinsate from washing drums is then processed through the solvent distilling system. The grit/sludge removed from the dirty solvent is managed as a hazardous waste and shipped offsite for disposal to Giant Resource Recovery. Mr. LaJaunie stated that this grit/sludge is the main hazardous waste stream generated at the Mike's Filter. The solvent distilling system also generates used oil which is recycled through AAT. During the inspection, Mr. LaJaunie stated that Mike's Filter had a letter of exemption for solvent recycling from Louisiana DEQ.
Mike's Filter is registered as a transporter and transfer facility for both hazardous waste and used oil (LAR000041269). The facility is an SQG for hazardous waste. Mr. LaJaunie stated that all truck maintenance is performed off site and that no waste from truck maintenance activities is generated at the facility. Mr. LaJaunie also stated that Mike's Filter is certified by the USCG to perform over the water transfers from vessels to trucks, but that the company only does so once or twice a year. He added that most of Mike's Filters business is not related to Port Fourchon. The company does not have its own dock operations and does not maintain a MARPOL COA.
After the opening conference, the inspection team conducted a visual inspection of the facility. Observations and areas of concern (AOCs) are listed below. Records Review
The inspection team conducted a brief review of hazardous waste manifests for waste being stored in the company's 10-day hazardous waste transfer facility. The inspection team observed that the hazardous waste shipped on Manifest #026667162JJK (see Appendix 2) had been received at Mike's Filter on 5/22/2024 and held onsite for 13 days as of the date of inspection (see Appendix 1 - Photos 4 and 5). [AOC #1: Mike's Filter stored hazardous waste for longer than 10 days while operating as a hazardous waste transfer facility- 40 CFR 263.12(a)].
Following the inspection, the inspection team reviewed additional manifests provided by Mike's Filter. The inspection team observed that hazardous waste shipped on multiple manifests (Manifest #026667109JJK, #026667137, #026667124JJK, #026667119JJK, #026667107JJK, and #02667120JJK) had been received at Mike's Filter and held onsite for longer than 10 days before being shipped offsite for disposal (see Appendix 7) [See AOC #1].
The inspection team also identified several manifests (Manifest #026667146JJK, #026667145, #026667098JJK, and #026667068JJK) which Mike's Filter did not correctly date as the transporter
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of the waste. [AOC #2: Mike's Filter incorrectly dated hazardous waste manifest for shipments it transported -263.20(b)]. Central Accumulation Area: The inspection team observed a spill pallet of waste in various sized containers. The spill pallet held three carboys, six 5-gallon buckets, and two boxes containing a total of ten bottles of various chemicals (see Appendix 1 - Photos 1 and 2). All the containers were partially full and unlabeled or labeled with incomplete hazardous waste labels. At the time of the inspection, Mr. LaJaunie stated that he could not identify the waste in any of the containers. [AOC #3: Mike's Filter did not make a hazardous waste determination for waste that it had generated - 40 CFR 262.11]. The inspection team also observed a pallet of universal waste batteries that was labeled as "Batteries" (see Appendix 1 - Photo 3). [AOC #4: Mike's Filter did not label a pallet of universal waste batteries as "Universal Waste--Battery(ies)," or "Waste Battery(ies)," or "Used Battery(ies)"- 40 CFR 273.14(a)]. Transfer Facility: The inspection team observed that the concrete floor of the secondary containment in the transfer facility was not coated (see Appendix 1 - Photo 8). [AOC #5 - The concrete floor of the secondary containment system in the used oil transfer facility was not impervious - 40 CFR 279.45(d)(2)].
After the visual inspection, the inspection team requested the following information from Mike's Filter: The company's most recent RCRA notification (see Appendix 3). A copy of the company's letter of exemption for solvent recycling from Louisiana DEQ (see Appendix 4). Mike's Filter SPCC Plan (see Appendix 5). Mike's Filter Contingency Plan (see Appendix 6). The hazardous waste manifests for shipments transported in May 2024 (see Appendix 7). Mike's Filter procedure for determining the halogen content of used oil (Appendix 8) Any responses to the AOCs identified during the visual inspection (see Appendix 9). Universal waste manifest for the last five shipments it transported (see Appendix 10).
The inspection team did not observe any other apparent 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 3:40 PM with Mike's Filter personnel. The AOCs were communicated to Mike's Filter during the closing conference.
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 AOCs does not constitute a formal compliance determination or violation.
Tenant: Mike's Filter & Supply, Inc.
AOC #1 - Mike's Filter stored hazardous waste for longer than 10 days while operating as a hazardous waste transfer facility. AOC #2 - Mike's Filter incorrectly dated hazardous waste manifest for shipments it transported.
Citation: 40 CFR 263.12(a) Citation: 40 CFR 263.20(b)
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Section: 2.1 Section: 2.1
Mike's Filter & Supply, Inc.
Inspection Date: 06/04/2024
AOC #3 - Mike's Filter did not make Citation: 40 CFR 262.11 a hazardous waste determination for waste that it had generated. AOC #4 - Mike's Filter did not label a Citation: 40 CFR 273.14(a) pallet of universal waste batteries as "Universal Waste--Battery(ies)," or "Waste Battery(ies)," or "Used Battery(ies)."
AOC #5 - The concrete floor of the Citation: 40 CFR 279.45(d)(2) secondary containment system in the used oil transfer facility was not impervious.
Section: 2.1 Section: 2.1
Section: 2.1
SECTION V -FOLLOW UP
Documents or files provided by the facility were transmitted via a file transfer protocol (FTP) link provided by ERG following the inspection.
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Communication Log
After the inspection, additional information was provided to EPA including: 1. 6/8/2024 - Mike's Filter uploaded its Letter of Exemption for Solvent Recycling from Louisiana
DEQ to the FTP site. 2. 6/12/2024 - Mike's Filter uploaded its SPCC Plan to the FTP site. 3. 6/13/2024 - Mike's Filter uploaded its Contingency Plan to the FTP site. 4. 6/17/2024 - Mike's Filter uploaded its May 2024 hazardous waste manifests, its procedure for
determining the halogen content of used oil, and follow-up to the AOCs identified during the inspection to the FTP site. 5. 6/20/2024 - Mike's Filter uploaded the manifests for its last five shipments of universal waste to the FTP site.
SECTION VI - LIST OF APPENDICES Appendix 1 - Photograph Log Appendix 2 Hazardous Waste Manifest 026667162JJK Appendix 3 Mike's Filter RCRA Notification Appendix 4 Mike's Filter Letter of Exemption for Solvent Recycling Appendix 5 Mike's Filter SPCC Plan Appendix 6 Mike's Filter Contingency Plan Appendix 7 Mike's Filter May 2024 Hazardous Waste Manifests Appendix 8 Mike's Filter Procedure for Determining Halogen Content of Used Oil Appendix 9 Mike's Filter Response to AOCs Appendix 10 Mike's Filter Recent Universal Waste Manifests
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1 Photograph Log
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 1
Location: Mike's Filter & Supply, Inc.
City: Houma
County/Parish: Terrebonne
State: Louisiana
Photo File Name: DSCN7310 Date of Photo: 6/04/2024 Time of Photo: 14:38 CST Photographer: Vince Damiano Description: Containers in Mike's Filter's Central Accumulation Area (CAA) holding unidentified waste, some labeled with blank hazardous waste labels. Labels do not have an accumulation start date or an indication of the hazards of the contents of the containers.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 2
Location: Mike's Filter & Supply, Inc.
City: Houma
County/Parish: Terrebonne
State: Louisiana
Photo File Name: DSCN7311 Date of Photo: 6/04/2024 Time of Photo: 14:38 CST Photographer: Vince Damiano Description: Containers in Mike's Filter's CAA holding unidentified waste, some labeled with blank hazardous waste labels. Labels do not have an accumulation start date or an indication of the hazards of the contents of the containers.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 3
Location: Mike's Filter & Supply, Inc.
City: Houma
County/Parish: Terrebonne
State: Louisiana
Photo File Name: DSCN7312 Date of Photo: 6/04/2024 Time of Photo: 15:00 CST Photographer: Vince Damiano Description: Universal waste batteries in Mike's Filter's CAA not labeled in accordance with 40 CFR 273.14(a).
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 4
Location: Mike's Filter & Supply, Inc.
City: Houma
County/Parish: Terrebonne
State: Louisiana
Photo File Name: DSCN7313 Date of Photo: 6/04/2024 Time of Photo: 15:12 CST Photographer: Vince Damiano Description: Drum of hazardous waste in Mike's Filter's 10-day transfer area. The drum was shipped on Manifest #026667162 to Mike's Filter on 5/22/2024 and was still onsite at the time of the inspection on 6/4/2024, 13 days after it arrived on site.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 5
Location: Mike's Filter & Supply, Inc.
City: Houma
County/Parish: Terrebonne
State: Louisiana
Photo File Name: DSCN7314 Date of Photo: 6/04/2024 Time of Photo: 15:12 CST Photographer: Vince Damiano Description: Drum of hazardous waste in Mike's Filter's 10-day transfer area. The drum was shipped on Manifest #026667162 to Mike's Filter on 5/22/2024 and was still onsite at the time of the inspection on 6/4/2024, 13 days after it arrived on site.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 6
Location: Mike's Filter & Supply, Inc.
City: Houma
County/Parish: Terrebonne
State: Louisiana
Photo File Name: DSCN7315 Date of Photo: 6/04/2024 Time of Photo: 15:12 CST Photographer: Vince Damiano Description: Tote of used oil in Mike's Filter's 10-day transfer area.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 7
Location: Mike's Filter & Supply, Inc.
City: Houma
County/Parish: Terrebonne
State: Louisiana
Photo File Name: DSCN7316 Date of Photo: 6/04/2024 Time of Photo: 15:12 CST Photographer: Vince Damiano Description: Totes of used oil in Mike's Filter's 10-day transfer area.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 8
Location: Mike's Filter & Supply, Inc.
City: Houma
County/Parish: Terrebonne
State: Louisiana
Photo File Name: DSCN7317 Date of Photo: 6/04/2024 Time of Photo: 10:20 CST Photographer: Vince Damiano Description: Totes of used oil and drums of hazardous waste in Mike's Filter's 10-day transfer area.
Appendix 2 Hazardous Waste Manifest 026667162JJK
Appendix 3 Mike's Filter RCRA Notification
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Appendix 4 Mike's Filter Letter of Exemption for Solvent Recycling
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Appendix 5 Mike's Filter SPCC Plan
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Appendix 6 Mike's Filter Contingency Plan
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Appendix 7 Mike's Filter May 2024 Hazardous Waste Manifests
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Appendix 8 Mike's Filter Procedure for Determining Halogen Content of Used Oil
Determination of Halogen Content in Used Oil 1. A used oil sample is initially collected from the generator prior to acceptance 2. The sample is delivered to American Advanced Technologies to check for halogens in used oil 3. American Advanced Technologies uses a Dexsil Clor-D-Tect test kit to determine if the amount of
halogen content in the used oil stream is less than 1,000 ppm for acceptance 4. Once sample is accepted for recycling, then Mike's Filter schedules the collection of used oil
from the generator 5. When delivering used oil to American Advanced Technologies, another Dexsil Clor-D-Tect test is
run again to verify halogen content is below 1,000 ppm so used oil can be accepted for recycling 6. If used oil test is below 1,000 ppm and accepted for recycling, then results showing used oil is
less than 1,000 ppm is documented on the collection manifest
Appendix 8 Page 1 of 1
Appendix 9 Mike's Filter Response to AOCs
Mike's Filter & Supply, Inc.
Initial Areas of Concern
1. Waste Determination for waste being stored on spill pallet
The following has been determined through research with my Dispatchers and Warehouse Personnel.
Items of pallet
2 cardboard boxes with sample bottles
The samples were collected from generators with fuel/oil related new products and delivered to American Advanced Technologies to test for acceptance and recycling. These product samples were rejected with the remaining product left in bottle to be returned to the generator by either our sales people or drivers when in route to customer area. The 10 sample bottles of product in the cardboard boxes were returned to customer on 6/6/2024 on ticket # R034394.
2 Empty Paint Thinner Cans
The paint thinner cans labels have been removed and empty metal cans have been sent to scrap yard for recycling.
1 Paint Thinner Can
Paint thinner can is new product. The can has been relocated into an area with other products still being used in our daily operations.
2 5-gallon pails (labels showing generator "Inspectorate America Corp (St. Rose)
The pail label shows manifest # 018007433 FLE. I researched the manifest for this generator and it shows that the manifest was for a pick-up of 2 55-gallon drums of lab waste. The 2 pails with the labels on them have been sampled and sent to a lab for analysis. The analysis should determine if the stream is hazardous as per the generator name on the label or if the stream is what my employees say is a soap product that was put into the container by mistake to be used by our company. When the analysis comes back determining nonhazardous or hazardous Mike's Filter will create a profile and dispose of the waste properly.
1 10-gallon empty poly bucket
The empty 10-gallon bucket has a Mike's Filter & Supply hazardous waste sticker on the container showing Waste Aerosols. Upon a LADEQ unofficial phone call concerning a customer of ours, they were wanting the customer to have a container readily available for aerosols just incase they generated waste. After our phone conversation, I took the initiative to put one in place here at Mike's Filter. Waste stream had been profiled and a label placed on the container.
Appendix 9 Page 1 of 2
1 5-gallon pail (X-Chem written with marker)
Warehouse employee says the container has the new product soap that we use in it. The soap is called AQPW an non-hazardous aqueous part washer solution. Product in containers have been used and containers disposed of.
2 5-gallon pail (No Label)
Warehouse employee says the container has the new product soap that we use in it. The soap is called AQPW an non-hazardous aqueous part washer solution. Product in containers have been used and containers disposed of.
2. Issues with coating of secondary containment used for storing used oil Containment area wall and floor will be pressure washed clean before coating concerned area
3. Hazardous waste container held onsite for longer than 10 days I have reevaluated our operations storing and shipping waste to our two vendors (Clean Earth of Alabama and Giant Resource Recovery) for hazardous waste based on their current acceptance of waste material. Hazardous waste facilities only receive waste when scheduled. We currently have an offload slot scheduled every week on Thursday for Clean Earth of Alabama and every other week on Thursday for Giant Resource Recovery. Giant Resource Recovery can only accommodate us every two weeks due to customer slot availability. Scheduling our customer pickups being shipped to Giant Resource Recovery has been modified to pick-up within our 10-day transfer facility status. Situations occur during scheduling pickups from our customers when the customer plans to have a certain number of drums being picked up, but when we dispatch our truck to pick-up drums, they have more drums to pick-up. This has caused several manifest pickups from generators delayed in being shipped to the hazardous waste facility due to our truck being overloaded on weight or full with drum quantities. Another addition to our procedures is to write the date the shipment is unloading into our transfer facility storage area if it is not on the date of pick-up. The unloading date will be written in the area on our hazardous waste manifest #14 (Special Handling Instructions and Additional Information). Several of our manifest that we exceeded our 10-day limit was due to us picking up on a Friday, but unloading on a Monday.
I have had meetings with all personnel involved with picking up, unloading, or dispatching any type of waste material being held in our 10-day transfer facility area. The evaluation of our process for managing our 10-day transfer facility status should be taken care of when the plans put in place are managed correctly in addition to getting additional offload slots at the hazardous waste facilities when needed if available.
4. Universal waste batteries not labeled Pallet labeled correctly based on type of waste and manifest
Appendix 9 Page 2 of 2
Appendix 10 Mike's Filter Recent Universal Waste Manifests
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