Document OEzEdxQX2MgMJ85Ok50Bva9av
f t E A ~ United States
..~ .
Environmental Protection
~,
Agency
Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection
EPA REGION 6 Enforcement Division
INSPECTION REPORT
3/25/2025 15:10 (CT) 3/26/2025 13:00 (CT) 3/26/2025 14:15 (CT)
Announced: No Access: Granted
RCRA Compliance Evaluation Inspection (CEI)
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
National Marine Environmental LLC N/A 1010 Jackson Rd. (Office) Amelia, LA 70380 St. Mary Non-generator 48411 National Marine Environmental LLC (NME) collects used oil from customers and stores it before sending it to be recycled. 29.6642, -91.1239
Additional Persons Participating in Inspection:
Name
Title
Organization
John Penland
Inspector
EPA REGION 6
Erin Young-Dahl
Inspector
EPA REGION 6
Janosh Wolters
Contractor
Eastern Research Group (ERG)
Email Penland.John@epa.gov Youngdahl.Erin@epa.gov Janosh.Wolters@erg.com
Lead Inspector: Vince Damiano
ERG
Vincent
Digitally signed by Vincent Damiano
Damiano - 16:35:03 -04'00' Date: 2025.05.01
IVince.Damiano@erg.com
Page 1 of 5
National Marine Environmental LLC
SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection
Inspection Date: 3/26/2025
The Port of Morgan City 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, port related facilities, and other 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 NME/Operations
Name Vince Damiano John Penland Erin Young-Dahl Janosh Wolters Bubba Nini
Email Vince.Damiano@erg.com
Opening Closing Conf. Conf.
Yes
Yes
Penland.John@epa.gov
Yes
Yes
Youngdahl.Erin@epa.gov
Yes
Yes
Janosh.Wolters@erg.com
Yes
Yes
bubba.nationalcompanies@gmail.co Yes
Yes
m
Page 2 of 5
National Marine Environmental LLC Facility General Description
Inspection Date: 3/26/2025
Tenant/Area National Marine Environmental LLC
Inspection
Date
Process Description
3/26/25 NME handles customers' used oil and stores it before
sending it for recycling. NME is land-based and does not
operate under a MARPOL COA.
Area of Concern
Yes
SECTION II - OBSERVATIONS
Facility: National Marine Environmental LLC
Section: 2.1
Date: 3/26/25, 1:00 PM
Contains AOC: Yes Contains CBI: No
I
I
Lead Inspector: Vince Damiano Attendees: Bubba Nini (Manager)
National Marine Environmental LLC (NME), located in Morgan City, LA, operates as a used oil transporter and transfer facility. NME has two vacuum trucks used to collect waste oil, bilge water, and used oil from customers before bringing it back to the facility for storage. The used oil is consolidated into tanks at NME and then transported to one of the following facilities for disposal: Plaquemines Processing & Recovery LLC in Belle Chasse, LA; Clean Harbors in White Castle, LA; or Mikes Filters in Houma, LA. NME has five storage frac tanks, each with a capacity of 20,000 gallons. NME is not registered with the EPA as a used oil transporter nor a used oil transfer facility.
The inspection team originally arrived at NME's waste consolidation facility, 958 Lake Palourde Road, Morgan City, LA, to conduct the unannounced inspection on 3/25/2025 at 3:10 PM, but there were no relevant staff present to conduct the inspection. Inspector Penland was able to reach Mr. Nini by telephone and spoke with Mr. Nini for general facility information and to reschedule the inspection for the following day. Mr. Nini granted access to the inspection team to observe the waste consolidation facilities while on-site on 3/25; photos from the observation can be found in Appendix 1. After photographing the storage tanks, the inspection team departed.
The inspection team arrived at the office location on 3/26/2025 at approximately 1:00 PM to continue the inspection. After the opening conference, the inspection team discussed NME's used oil storage operations. The inspection team asked Mr. Nini if NME has an EPA ID number. Mr. Nini stated that NME had not applied for an EPA ID number [AOC #1 - Used Oil Transporters who have not previously complied with the notification requirements of RCRA section 3010 must comply with these requirements and obtain an EPA identification number" - 40 CFR 279.42 (a)]. The inspection team observed three 55-gallon containers approximately full during the visual inspection of the waste consolidation facility (see Appendix 1 - Photos 4 and 8). Mr. Nini stated that the 55-gallon containers observed are used to store residuals from the vacuum trucks. The inspection team asked Mr. Nini if he had knowledge of the material in NME's storage tanks and the containers observed at the waste consolidation facility. At the time of the inspection, Mr. Nini stated that Tank 0 held 3,000 gallons of oily water waste; Tank 1 held 4,000 gallons of oily water waste; Tank 2 held 8,300 gallons of used oil; Tank 3 was empty; and Tank 4 held 20,000 gallons of contaminated oily water with diesel fuel. The inspection team explained to Mr. Nini that the 55-gallon containers, Tanks 0, 1, 2, and 4 were not labeled to indicate their used oil contents (see Appendix 1- Photos 4 to 7) [AOC #2 - NME did not clearly label containers used to store used oil with the words "Used Oil" - 40 CFR 279.45(g)(1))]. The inspection team also mentioned that the used oil 55-gallon containers must be stored in secondary containment as a used oil
Page 3 of 5
National Marine Environmental LLC
Inspection Date: 3/26/2025
transfer facility. The 55-gallon containers observed during the visual inspection were not stored in secondary
containment [AOC#3 - NME stored used oil as a transfer facility without a secondary containment system - 40
CFR 279.45(d)]. The inspection team also observed a roll-off container, which Mr. Nini stated was storing non-
hazardous mud from a cleaning (see Appendix 1 - Photo 7).
All AOCs observed by the inspection team at the time of the inspection are documented above. However, upon further review, EPA may change or add additional AOCs. A closing conference was conducted at approximately 2:15 PM with Mr. Nini. The AOCs observed throughout the visual inspection were communicated during the closing conference. Following the inspection on 3/27/2025 and 4/10/2025, Mr. Nini sent follow-up emails in response to the AOCs observed during the inspection including:
Waste profile from the roll-off container found at the consolidation facility (Appendix 2)
Waste profile from frac tank 4 (Appendix 3) NME response letter to the AOCs observed from 4/10/2025 (Appendix 4)
Photos of used oil tanks and containers labeled as well as secondary containment implemented
(Appendix 5).
SECTION III - RECORDS REVIEW No RCRA-regulated records were reviewed during this focused onsite inspection.
SECTION IV - AREAS OF CONCERN The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation.
Facility: National Marine Environmental LLC
AOC #1 - Used Oil Transporters who have not previously complied with the notification requirements of RCRA section 3010 must comply with these requirements and obtain an EPA identification number.
Citation: 40 CFR 279.42 (a)
AOC #2 - NME did not clearly label containers used to Citation: 40 CFR 279.22(c) store used oil with the words "Used Oil"
Section: 2.1 Section: 2.1
AOC #3 - NME stored used oil as a transfer facility without a secondary containment system.
Citation: 40 CFR 279.45(d)
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.
Page 4 of 5
National Marine Environmental LLC Communication Log
Inspection Date: 3/26/2025
During and after the inspection, additional information was emailed to EPA including: 1. 3/27/25 NME email - Mr. Nini provided the inspection team with waste profiles for the Frac Tank 4 and non-hazardous roll-off container. 2. 4/10/25 NME email - Mr. Nini provided the inspection team with photos of the secondary containment system installed, used oil labels, and an update on obtaining an EPA ID
SECTION VI - LIST OF APPENDICES
Appendix 1. Photograph Log Appendix 2. NME Response on 3/27/2025 and Roll-off Waste Profile Appendix 3. Frac Tank 4 Waste Profile Appendix 4. NME Response Letter on 4/10/2025 Appendix 5. Photos from NME Response on 4/10/2025
Page 5 of 5
APPENDIX 1. PHOTOGRAPH LOG
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Location: National Marine Environmental LLC
City: Morgan City
County/Parish: St. Mary
State: Louisiana
Photo No. 1
Photo File Name: WIN_20250325_15_26_46_Pro Date of Photo: 3/25/2025 Time of Photo: 15:26 hrs. Photographer: John Penland Description: Overview of NME's used oil consolidation facility.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Location: National Marine Environmental LLC
City: Morgan City
County/Parish: St. Mary
State: Louisiana
Photo No. 2
Photo File Name: WIN_20250325_15_27_06_Pro Date of Photo: 3/25/2025 Time of Photo: 15:27 hrs. Photographer: John Penland Description: Overview of NME's used oil consolidation facility with empty totes and empty 55-gallon drums in the background.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Location: National Marine Environmental LLC
City: Morgan City
County/Parish: St. Mary
State: Louisiana
Photo No. 3
Photo File Name: WIN_20250325_15_27_26_Pro Date of Photo: 3/25/2025 Time of Photo: 15:27 hrs. Photographer: John Penland Description: View of empty totes and 55-gallon drums at the used oil consolidation facility.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Location: National Marine Environmental LLC
City: Morgan City
County/Parish: St. Mary
State: Louisiana
Photo No. 4
Photo File Name: WIN_20250325_15_27_54_Pro Date of Photo: 3/25/2025 Time of Photo: 15:27 hrs. Photographer: John Penland Description: Overview of NME's used oil frac tanks in secondary containment at the used oil consolidation facility and a view of one of the 55-gallon drums storing used oil which was not labeled.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Location: National Marine Environmental LLC
City: Morgan City
County/Parish: St. Mary
State: Louisiana
Photo No. 5
Photo File Name: WIN_20250325_15_28_16_Pro Date of Photo: 3/25/2025 Time of Photo: 15:28 hrs. Photographer: John Penland Description: View of frac tank 0 (right) and frac tank 1 (left). Frac tank 0 was storing water, and frac tank 1 was storing 4,000 gallons of oily water; the frac tank was not labeled as used oil.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Location: National Marine Environmental LLC
City: Morgan City
County/Parish: St. Mary
State: Louisiana
Photo No. 6
Photo File Name: WIN_20250325_15_28_19_Pro Date of Photo: 3/25/2025 Time of Photo: 15:28 hrs. Photographer: John Penland Description: View of frac tank 2 (right), frac tank 3 (middle), and frac tank 4 (left). Frac tank 2 was storing 8,300 gallons of used oil (not labeled), frac tank 3 was empty, and frac tank 4 was storing 20,000 gallons of oily water/diesel; the frac tank was not labeled as used oil.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Location: National Marine Environmental LLC
City: Morgan City
County/Parish: St. Mary
State: Louisiana
Photo No. 7
Photo File Name: WIN_20250325_15_28_30_Pro Date of Photo: 3/25/2025 Time of Photo: 15:28 hrs. Photographer: John Penland Description: View of the roll-off container that was storing non-hazardous mud.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Location: National Marine Environmental LLC
City: Morgan City
County/Parish: St. Mary
I
IState: Louisiana
Photo No. 8
Photo File Name: WIN_20250325_15_28_42_Pro Date of Photo: 3/25/2025 Time of Photo: 15:28 hrs. Photographer: John Penland Description: View of two full 55-gallon drums of used oil that were not labeled.
APPENDIX 2. NME RESPONSE ON 3/27/2025 AND ROLL-OFF WASTE PROFILE
Outlook
Re: Follow-up from EPA Inspection on 3/26/2025
From Bubba <bubba.nationalcompanies@gmail.com> Date Thu 3/27/2025 9:18 AM To Vince Damiano <Vince.Damiano@erg.com> Cc Janosh Wolters <janosh.wolters@erg.com>; Young-Dahl, Erin <YoungDahl.Erin@epa.gov>; Penland, John
< Penland.John@epa.gov>
@2 attachments (468 KB)
Roll Top Profile.pdf; Tank Profile.pdf;
CAUTION : Don't open links or attachments unless you recognize the sender and know they are safe.
Hey, GM , guys, it's never enjoyable to go through an inspection, but I will commend each of you on your professional approach and understanding , you made the process bearable, Thanks I will send pictures soon of the totes and drums in containment, also Used Oil written on tanks until stickers or made. Attached is the profiles that you requested. We will start working on The LA EPA#. I will send follow up emails with updates as I get them, Thanks. Kind Regards, Bubba Nini
On Wed, Mar 26, 2025 at 5:30PM Vince Damiano <Vince.Damiano@erg.com > wrote:
Hello Bubba,
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 :
No EPA ID number as used oil transporter and transfer facility (refer to 40 CFR 279.42) Used oil frac tanks were not labeled as "Used Oil" No secondary containment for 55-gallon drums of used oil as a transfer facility (refer to 40 CFR 279
Subpart E)
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@erg.com
WASTE MATERIAL PROFILE SHEET
Clean Harbors Profile No. CH2901234B
A. GENERAL INFORMATION GENERATOR EPA ID #/REGISTRATION# GENERATOR CODE (Assigned by Clean Harbors) ADDRESS 1010 Jackson Road
CUSTOMER CODE (Assigned by Clean Harbors) ADDRESS 1010 Jackson Road
NONHAZTRANSP NA31190
NA31190
GENERATOR NAME: CITY Morgan City
CUSTOMER NAME: CITY Morgan City
National Marine Environmental
STATE/PROVINCE LA ZIP/POSTAL CODE
PHONE: (985) 354-6003 National Marine Environmental STATE/PROVINCE LA ZIP/POSTAL CODE
70380 70380
B. WASTE DESCRIPTION WASTE DESCRIPTION: Tank Bottoms
PROCESS GENERATING WASTE:
Washing boats and barges Tank Bottoms
IS THIS WASTE CONTAINED IN SMALL PACKAGING CONTAINED WITHIN A LARGER SHIPPING CONTAINER? No
C. PHYSICAL PROPERTIES (at 25C or 77F)
PHYSICAL STATE SOLID WITHOUT FREE LIQUID POWDER
MONOLITHIC SOLID
~ LIQUID/SOLID MIXTURE LIQUID WITH NO SOLIDS
% FREE LIQUID % SETTLED SOLID
5.00-10.00 90.00 - 95.00
% TOTAL SUSPENDED SOLID
SLUDGE
GAS/AEROSOL
NUMBER OF PHASES/LAYERS
1~ 2
3
TOP
% BY VOLUME (Approx.)
MIDDLE
BOTTOM
10.00 0.00 90.00
ODOR
~
NONE MILD STRONG
Describe:
BOILING POINT F (C) <= 95 (<=35) 95 - 100 (35-38) 101 -129 (38-54)
~ >= 130 (>54)
VISCOSITY (If liquid present)
~ 1 - 100 (e.g. Water)
101 - 500 (e.g. Motor Oil) 501 -10,000 (e.g. Molasses) > 10,000
COLOR
Brown/Bia ck
MELTING POINT F (C)
< 140 (<60) 140-200 (60-93)
~ > 200 (>93)
TOTAL ORGANIC CARBON(%)
<= 1
~ >1 -<10
>= 10
FLASH POINT F (C) < 73 (<23) 73 - 100 (23-38)
101 -140 (38-60) 141 -200 (60-93) ~ >200(>93)
pH <=2
~ 2.1 - 6.9
7 (Neutral) 7.1 -12.4
>= 12.5
SPECIFIC GRAVITY < 0.8 (e.g. Gasoline) 0.8-1 .0 (e.g. Ethanol) 1.0 (e.g. Water)
1.0-1.2 (e.g. Antifreeze)
~ > 1.2 (e.g. Methylene Chloride)
ASH
< 0.1 0.1 -1 .0 1.1 -5.0 5.1 -20.0
> 20
~ Unknown
BTU/LB (MJ/kg)
~ < 2,000 (<4.6)
>=2,000-4,999 (>=4.6-11.62) >=5,000-10,000 (>=11 .63-23.2) > 10,000 (>23.2)
Actual:
D. COMPOSITION (List the complete composition of the waste, include any inert components and/or debris. Ranges for individual components are acceptable. If a trade name is used, please s, 1ppI)f ao MSDS Please do oo1 ,rse abbreHiatioos )
CHEMICAL
MIN
MAX UOM
BARIUM
94.0000000
94.0000000 PPM
-C-A-L-C-I-U-M-------------------------------------------------------------------------------2-1-0-3-.0-0-0-0-0-00-----2-1-0-3-.0-0-0-0-0--P-P-M---
00
COPPER
0.6400000
0.6400000 PPM
-D-I-R-T-&--M-U-D-----------------------------------------------------------------------8-5-.-0-00-0-0-0-0------9-0-.0-0-0-0-0-0-0---%----
-M-A-G--N-E-S-IU--M----------------------------------------------------------------------------3-1-0-.3-5-0-0-0-0-0----3-1-0-.3-5-0-0-0-0-0--P-P-M---
OIL&GREASE
0.0000000
5.0000000 %
SODIUM
6335.0000000 6335.00000 PPM 00
WATER
5.0000000 -- 10.0000000 %
ZINC
3.4600000
3.4600000 PPM
DOES THIS WASTE CONTAIN ANY HEAVY GAUGE METAL DEBRIS OR OTHER LARGE OBJECTS (EX., METAL PLATE OR PIPING >1/4" THICK OR >12" LONG, METAL REINFORCED HOSE >12" LONG, METAL WIRE >12" LONG, METAL VALVES, PIPE FITTINGS, CONCRETE REINFORCING BAR OR PIECES OF CONCRETE >3")?
If yes, describe, including dimensions:
DOES THIS WASTE CONTAIN ANY METALS IN POWDERED OR OTHER FINELY DIVIDED FORM?
DOES THIS WASTE CONTAIN OR HAS IT CONTACTED ANY OF THE FOLLOWING; ANIMAL WASTES, HUMAN BLOOD, BLOOD PRODUCTS, BODY FLUIDS, MICROBIOLOGICAL WASTE, PATHOLOGICAL WASTE, HUMAN OR ANIMAL DERIVED SERUMS OR PROTEINS OR ANY OTHER POTENTIALLY INFECTIOUS MATERIAL?
I acknowledge that this waste material is neither infectious nor does it contain any organism known to be a threat to human health. This certification is based on my knowledge of the material. Select the answer below that applies:
YES ~ NO
YES ~ NO YES ~ NO
The waste was never exposed to potentially infectious material. Chemical disinfection or some other form of sterilization has been applied to the waste. I ACKNOWLEDGE THAT THIS PROFILE MEETS THE CLEAN HARBORS BATTERY PACKAGING REQUIREMENTS.
YES
NO
YES
NO
YES
NO
I ACKNOWLEDGE THAT MY FRIABLE ASBESTOS WASTE IS DOUBLE BAGGED AND WETTED.
YES
NO
SPECIFY THE SOURCE CODE ASSOCIATED WITH THE WASTE.
G13
SPECIFY THE FORM CODE ASSOCIATED WITH THE WASTE. W609
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Clean Harbors Profile No. CH2901234B
E. CONSTITUENTS
Are these values based on testing or knowledge?
~ Knowledge
Testing
If based on knowledge, please describe in detail, the rationale applied to identify and characterize the waste material. Please include reference to Material Safety Data Sheets (MSDS) when applicable. Include the chemical or trade-name represented by the MSDS, and or detailed process or operating procedures which generate the waste.
Process knowledge of washing boats and barges ; sample sent to White Caste
Please indicate which constituents below apply. Concentrations must be entered when applicable to assist in accurate review and expedited approval of your waste profile. Please note that the total regulated metals and other constituents sections require answers.
RCRA REGULATED METALS
REGULATORY TCLP
TOTAL
UOM
NOT APPLICABLE
LEVEL (mg/I)
mg/I
D004
ARSENIC
5.0
~
.cio"os ... -BARIUM - "1DO.Cl.... - ............................................. ~ - ....... .
D006
CADMIUM
1.0
0001 - CHROMIUM - 5 ~0- - ~ -
.cio"oa ... -LEAC> ................... - .... 5~0- - ~ -
.cioog ... -MERcuRv - a~ .... - ............................................. ~ -....... .
0010 -SELENiuM - ;~o- - ~ i
.............. -.............................................. - ...................... -.. .. .. .. .. .. .. .. .. .... .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .... .. .. .. .. .. .. .. .. .. .... .. .. .. .. .. .. ............ ..
D011
SILVER
5.0
<I
VOLATILE COMPOUNDS
D018
BENZENE
0.5
D019
CARBON TETRACHLORIDE
0.5
D021
CHLOROBENZENE
100.0
D022
CHLOROFORM
6.0
D028
1,2-DICHLOROETHANE
0.5
D029
1,1-DICHLOROETHYLENE
0.7
.............. -.............................................. - ...................... -.................. ..
D035
METHYL ETHYL KETONE
200.0
D039
TETRACHLOROETHYLENE
0.7
D040
TRICHLOROETHYLENE
0.5
D043
VINYL CHLORIDE
0.2
D023
SEMI-VOLATILE COMPOUNDS o-CRESOL
200.0
D024
m-CRESOL
200.0
D025
p-CRESOL
200.0
............ -.............................................. -............... -.................. ..
D026
CRESOL (TOTAL)
200.0
D027
1,4-DICHLOROBENZENE
7.5
D030
2,4-DINITROTOLUENE
0.13
D032
HEXACHLOROBENZENE
0.13
D033
HEXACHLOROBUTADIENE
0.5
D034
HEXACHLOROETHANE
3.0
D036
NITROBENZENE
2.0
D037
PENTACHLOROPHENOL
100.0
D038
PYRIDINE
5.0
D041
2,4,5-TRICHLOROPHENOL
400.0
.............. -.............. .............. .................. -...................... -.................. ..
D042
2,4,6-TRICHLOROPHENOL
2.0
------------------------------------------------------
PESTICIDES AND HERBICIDES
D012
ENDRIN
0.02
D013
LINDANE
0.4
D014
METHOXYCHLOR
10.0
D015
TOXAPHENE
0.5
D016
2,4-D
10.0
D017
2,4,5-TP (SILVEX)
1.0
D020
CHLORDANE
0.03
D031
HEPTACHLOR (AND ITS EPOXIDE)
0.008
OTHER CONSTITUENTS
BROMINE CHLORINE FLUORINE IODINE SULFUR POTASSIUM SODIUM AMMONIA CYANIDE AMENABLE CYANIDE REACTIVE CYANIDE TOTAL SULFIDE REACTIVE
HOCs
~ NONE < 1000 PPM >= 1000 PPM
MAX UOM
NOT APPLICABLE
~
PCBs
~ NONE < 50 PPM >=50 PPM
IF PCBS ARE PRESENT, IS THE WASTE REGULATED BY TSCA 40 CFR 761?
YES
~ NO
ADDITIONAL HAZARDS DOES THIS WASTE HAVE ANY UNDISCLOSED HAZARDS OR PRIOR INCIDENTS ASSOCIATED WITH IT, WHICH COULD AFFECT THE WAY IT SHOULD BE HANDLED?
YES ~ NO (If yes, explain)
CHOOSE ALL THAT APPLY
DEA REGULATED SUBSTANCES
EXPLOSIVE
FUMING
OSHA REGULATED CARCINOGENS
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POLYMERIZABLE
Clean Harbors Profile No. CH2901234B
RADIOACTIVE
REACTIVE MATERIAL
~ NONE OF THE ABOVE
Report Printed On : Monday, February 3, 2025
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Clean Harbors Profile No. CH2901234B
F. REGULATORY STATUS
YES 0 NO USEPA HAZARDOUS WASTE?
YES 0 NO DO ANY STATE WASTE CODES APPLY?
I
Texas Waste Code
YES 0 NO DO ANY CANADIAN PROVINCIAL WASTE CODES APPLY?
I YES 0 NO IS THIS WASTE PROHIBITED FROM LAND DISPOSAL WITHOUT FURTHER TREATMENT PER 40 CFR PART 268? LDR CATEGORY: Not subject to LDR VARIANCE INFO: :
YES 0 NO IS THIS A UNIVERSAL WASTE? YES 0 NO IS THE GENERATOR OF THE WASTE CLASSIFIED AS A VERY SMALL QUANTITY GENERATOR (VSQG) OR A STATE EQUIVALENT
DESIGNATION?
YES
NO IS THIS MATERIAL GOING TO BE MANAGED AS A RCRA EXEMPT COMMERCIAL PRODUCT, WHICH IS FUEL (40 CFR 261 .2 (C)(2)(11))?
YES 0 NO DOES TREATMENT OF THIS WASTE GENERATE A F006 OR F019 SLUDGE?
YES
NO IS THIS WASTE STREAM PROHIBITED FROM INCINERATION BASED ON THE INORGANIC METAL BEARING WASTE PROHIBITION FOUND AT 40 CFR
268.3(C)?
YES 0 NO IS THIS WASTE STREAM "USED OIL" WHICH IS TO BE MANAGED UNDER 40 CFR PART 279- STANDARDS FOR THE MANAGEMENT OF USED OIL? YES 0 NO DOES THIS WASTE CONTAIN VOC'S IN CONCENTRATIONS >=500 PPM?
YES
NO DOES THE WASTE CONTAIN GREATER THAN 20% OF ORGANIC CONSTITUENTS WITH A VAPOR PRESSURE>= .3KPA (.044 PSIA)?
YES 0 NO DOES THIS WASTE CONTAIN AN ORGANIC CONSTITUENT WHICH IN ITS PURE FORM HAS A VAPOR PRESSURE> 76.6 KPA (11 .1 PSIA)?
YES 0 NO IS THIS CERCLA REGULATED (SUPERFUND) WASTE? YES 0 NO IS THE WASTE SUBJECT TO ONE OF THE FOLLOWING NESHAP RULES?
Hazardous Organic NESHAP (HON) rule (subpart G)
Pharmaceuticals production (subpart GGG)
YES
NO IF THIS IS A US EPA HAZARDOUS WASTE, DOES THIS WASTE STREAM CONTAIN BENZENE?
YES
NO Does the waste stream come from a facility with one of the SIC codes listed under benzene NESHAP or is this waste regulated under the benzene
NESHAP rules because the original source of the waste is from a chemical manufacturing , coke by-product recovery, or petroleum refinery process?
YES
NO Is the generating source of this waste stream a facility with Total Annual Benzene (TAB) >10 Mg/year?
What is the TAB quantity for your facility?
..__ _ _ _ _ __. Megagram/year (1 Mg= 2,200 lbs)
The basis for this determination is: Knowledge of the Waste Or Test Data
Knowledge
Testing
Describe the knowledge :
G. DOT/TDG INFORMATION DOT/TDG PROPER SHIPPING NAME:
NON DOT REGULATED MATERIAL, (TANK BOTTOM)
H. TRANSPORTATION REQUIREMENTS
ESTIMATED SHIPMENT FREQUENCY 0 ONE TIME
CONTAINERIZED 0-0 CONTAINERS/SHIPMENT
STORAGE CAPACITY: CONTAINER TYPE:
PORTABLE TOTE TANK
BOXICARTONICASE
WEEKLY MONTHLY QUARTERLY YEARLY OTHER
0 BULK LIQUID
BULK SOLID
GALLONS/SHIPMENT: 2000.00 Min -4000.00 GAL. Max
SHIPMENT UOM:
TON
TONS/YARDS/SHIPMENT: 0 Min 0 Max
CUBIC YARD BOX OTHER:
I. SPECIAL REQUEST
DRUM DRUM SIZE:
YARD
COMMENTS OR REQUESTS: Approve For WT
GENERATOR'S CERTIFICATION
I certify that I am authorized to execute this document as an authorized agent. I hereby certify that all information submitted in this and attached documents is correct to the best of my knowledge.I also certify that any samples submitted are representative of the actual waste.If Clean Harbors discovers a discrepancy during the approval process, Generator grants Clean Harbors the authority to amend the profile, as Clean Harbors deems necessary, to reflect the discrepancy.
AUTHORIZED SIGNATURE
NAME /PRINT)
TITLE
DATE
Report Printed On : Monday, February 3, 2025
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D. COMPOSITION
Clean Harbors Profile No. CH2901234B
Addendum
Reactive Metals Certification Waste material will be shipped under a visible layer of mineral oil. Metal containers will be used for shipment.
F. REGULATORY STATUS
0 YES
NO
0 YES
NO
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APPENDIX 3. FRAC TANK 4 WASTE PROFILE
WASTE MATERIAL PROFILE SHEET
Clean Harbors Profile No. CH2803698B
A. GENERAL INFORMATION GENERATOR EPA ID #/REGISTRATION# GENERATOR CODE (Assigned by Clean Harbors)
ADDRESS 1010 Jackson Road
CUSTOMER CODE (Assigned by Clean Harbors) ADDRESS 1010 Jackson Road
PENDING NA31190
NA31190
GENERATOR NAME: CITY Morgan City
CUSTOMER NAME: CITY Morgan City
National Marine Environmental
STATE/PROVINCE LA ZIP/POSTAL CODE
PHONE: National Marine Environmental STATE/PROVINCE LA ZIP/POSTAL CODE
70380 70380
B. WASTE DESCRIPTION WASTE DESCRIPTION: Oily Wastewater
PROCESS GENERATING WASTE:
Washing boats and barges
IS THIS WASTE CONTAINED IN SMALL PACKAGING CONTAINED WITHIN A LARGER SHIPPING CONTAINER? No
C. PHYSICAL PROPERTIES (at 25C or 77F)
PHYSICAL STATE SOLID WITHOUT FREE LIQUID POWDER
MONOLITHIC SOLID
~ LIQUID/SOLID MIXTURE LIQUID WITH NO SOLIDS
% FREE LIQUID % SETTLED SOLID
95.00 - 97.00 3.00-5.00
% TOTAL SUSPENDED SOLID
SLUDGE
GAS/AEROSOL
FLASH POINT F (C) < 73 (<23) 73 - 100 (23-38) 101 -140 (38-60) 141 -200 (60-93)
~ >200(>93)
pH <=2
~ 2.1 - 6.9
7 (Neutral) 7.1 -12.4
>= 12.5
NUMBER OF PHASES/LAYERS
1
2~ 3
TOP
% BY VOLUME (Approx.)
MIDDLE
BOTTOM
1.00 95.00 4.00
ODOR NONE MILD
~ STRONG
Describe: OILY
SPECIFIC GRAVITY < 0.8 (e.g. Gasoline) 0.8-1.0 (e.g. Ethanol) 1.0 (e.g. Water)
~ 1.0-1.2 (e.g. Antifreeze)
> 1.2 (e.g. Methylene Chloride)
BOILING POINT F (C) <= 95 (<=35) 95 - 100 (35-38) 101 -129 (38-54)
~ >= 130 (>54)
ASH
< 0.1
0.1 -1 .0
~
1.1 -5.0
5.1 -20.0
VISCOSITY (If liquid present)
~ 1 - 100 (e.g. Water)
101 - 500 (e.g. Motor Oil) 501 -10,000 (e.g. Molasses) > 10,000
COLOR
Brown/Bia ck
MELTING POINT F (C)
~ < 140 (<60)
140-200 (60-93) > 200 (>93)
TOTAL ORGANIC CARBON
~ <= 1%
1-9%
>=10%
> 20 Unknown
BTU/LB (MJ/kg)
~ < 2,000 (<4.6)
2,000-5,000 (4.6-11 .6) 5,000-10,000 (11 .6-23.2) > 10,000 (>23.2)
Actual:
D. COMPOSITION (List the complete composition of the waste, include any inert components and/or debris. Ranges for individual components are acceptable. If a trade name is used, please s, 1ppI)f ao MSDS Please do oo1 ,rse abbreHiatioos )
CHEMICAL
MIN
MAX UOM
BARIUM
1.2600000
1.2600000 PPM
-C-A-L-C-I-U-M-------------------------------------------------------------------------------2-7-.6-4-0-0-0-0-0--------2-7-.6-4-0-0-0-0-0--P-P-M---
COPPER
0.6400000
0.6400000 PPM
-D-I-R-T-&--M-U-D-----------------------------------------------------------------------3-.-0-0-00-0-0-0--------5-.0-0-0-0-0-0-0---%----
MAGNESIUM
7 .0100000
7.0100000 PPM
-O-I-L-&--G-R-E-A-S-E---------------------------------------------------------------------2-.0-0-0-0-0-0-0--------5.-0-0-0-0000---%----
SODIUM
46.6000000 -- 46.6000000 PPM
W--A-T-E-R--------------------------------------------------------------------------9-0-.0-0-0-0-0-00------- --9-5.-0-0-0-0000 ---%--- -
ZINC
11.6900000 -- 11.6900000 PPM
DOES THIS WASTE CONTAIN ANY HEAVY GAUGE METAL DEBRIS OR OTHER LARGE OBJECTS (EX., METAL PLATE OR PIPING >1/4" THICK OR >12" LONG, METAL REINFORCED HOSE >12" LONG, METAL WIRE >12" LONG, METAL VALVES, PIPE FITTINGS, CONCRETE REINFORCING BAR OR PIECES OF CONCRETE >3")?
If yes, describe, including dimensions:
DOES THIS WASTE CONTAIN ANY METALS IN POWDERED OR OTHER FINELY DIVIDED FORM?
DOES THIS WASTE CONTAIN OR HAS IT CONTACTED ANY OF THE FOLLOWING; ANIMAL WASTES, HUMAN BLOOD, BLOOD PRODUCTS, BODY FLUIDS, MICROBIOLOGICAL WASTE, PATHOLOGICAL WASTE, HUMAN OR ANIMAL DERIVED SERUMS OR PROTEINS OR ANY OTHER POTENTIALLY INFECTIOUS MATERIAL?
YES ~ NO
YES ~ NO YES ~ NO
I acknowledge that this waste material is neither infectious nor does it contain any organism known to be a threat to human health. This certification is based on my knowledge of the material. Select the answer below that applies:
The waste was never exposed to potentially infectious material. Chemical disinfection or some other form of sterilization has been applied to the waste. I ACKNOWLEDGE THAT THIS PROFILE MEETS THE CLEAN HARBORS BATTERY PACKAGING REQUIREMENTS.
YES
NO
YES
NO
YES
NO
I ACKNOWLEDGE THAT MY FRIABLE ASBESTOS WASTE IS DOUBLE BAGGED AND WETTED.
YES
NO
SPECIFY THE SOURCE CODE ASSOCIATED WITH THE WASTE.
G13
SPECIFY THE FORM CODE ASSOCIATED WITH THE WASTE. W609
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Clean Harbors Profile No. CH2803698B
E. CONSTITUENTS
Are these values based on testing or knowledge?
~ Knowledge
Testing
If based on knowledge, please describe in detail, the rationale applied to identify and characterize the waste material. Please include reference to Material Safety Data Sheets (MSDS) when applicable. Include the chemical or trade-name represented by the MSDS, and or detailed process or operating procedures which generate the waste.
Process knowledge of washing boats and barges ; sample sent to White Caste
Please indicate which constituents below apply. Concentrations must be entered when applicable to assist in accurate review and expedited approval of your waste profile. Please note that the total regulated metals and other constituents sections require answers.
RCRA REGULATED METALS
REGULATORY TCLP
TOTAL
UOM
NOT APPLICABLE
LEVEL (mg/I)
mg/I
D004
ARSENIC
5.0
~
.cio"os ... -BARIUM - "1DO.Cl.... - ............................................. ~ - ....... .
D006
CADMIUM
1.0
0001 - CHROMIUM - 5 ~0- - ~ -
.cio"oa ... -LEAC> ................... - .... 5~0- - ~ -
.cioog ... -MERcuRv - a~ .... - ............................................. ~ -....... .
0010 -SELENiuM - ;~o- - ~ i
.............. -.............................................. - ...................... -.. .. .. .. .. .. .. .. .. .... .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .... .. .. .. .. .. .. .. .. .. .... .. .. .. .. .. .. ............ ..
D011
SILVER
5.0
<I
VOLATILE COMPOUNDS
D018
BENZENE
0.5
D019
CARBON TETRACHLORIDE
0.5
D021
CHLOROBENZENE
100.0
D022
CHLOROFORM
6.0
D028
1,2-DICHLOROETHANE
0.5
D029
1,1-DICHLOROETHYLENE
0.7
.............. -.............................................. - ...................... -.................. ..
D035
METHYL ETHYL KETONE
200.0
D039
TETRACHLOROETHYLENE
0.7
D040
TRICHLOROETHYLENE
0.5
D043
VINYL CHLORIDE
0.2
D023
SEMI-VOLATILE COMPOUNDS o-CRESOL
200.0
D024
m-CRESOL
200.0
D025
p-CRESOL
200.0
............ -.............................................. -............... -.................. ..
D026
CRESOL (TOTAL)
200.0
D027
1,4-DICHLOROBENZENE
7.5
D030
2,4-DINITROTOLUENE
0.13
D032
HEXACHLOROBENZENE
0.13
D033
HEXACHLOROBUTADIENE
0.5
D034
HEXACHLOROETHANE
3.0
D036
NITROBENZENE
2.0
D037
PENTACHLOROPHENOL
100.0
D038
PYRIDINE
5.0
D041
2,4,5-TRICHLOROPHENOL
400.0
.............. -.............. .............. .................. -...................... -.................. ..
D042
2,4,6-TRICHLOROPHENOL
2.0
------------------------------------------------------
PESTICIDES AND HERBICIDES
D012
ENDRIN
0.02
D013
LINDANE
0.4
D014
METHOXYCHLOR
10.0
D015
TOXAPHENE
0.5
D016
2,4-D
10.0
D017
2,4,5-TP (SILVEX)
1.0
D020
CHLORDANE
0.03
D031
HEPTACHLOR (AND ITS EPOXIDE)
0.008
OTHER CONSTITUENTS
BROMINE CHLORINE FLUORINE IODINE SULFUR POTASSIUM SODIUM AMMONIA CYANIDE AMENABLE CYANIDE REACTIVE CYANIDE TOTAL SULFIDE REACTIVE
HOCs
~ NONE < 1000 PPM >= 1000 PPM
MAX UOM
NOT APPLICABLE
~
PCBs
~ NONE < 50 PPM >=50 PPM
IF PCBS ARE PRESENT, IS THE WASTE REGULATED BY TSCA 40 CFR 761?
YES
~ NO
ADDITIONAL HAZARDS DOES THIS WASTE HAVE ANY UNDISCLOSED HAZARDS OR PRIOR INCIDENTS ASSOCIATED WITH IT, WHICH COULD AFFECT THE WAY IT SHOULD BE HANDLED?
YES ~ NO (If yes, explain)
CHOOSE ALL THAT APPLY
DEA REGULATED SUBSTANCES
EXPLOSIVE
FUMING
OSHA REGULATED CARCINOGENS
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POLYMERIZABLE
Clean Harbors Profile No. CH2803698B
RADIOACTIVE
REACTIVE MATERIAL
~ NONE OF THE ABOVE
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Clean Harbors Profile No. CH2803698B
F. REGULATORY STATUS
YES ~ NO USEPA HAZARDOUS WASTE?
YES ~ NO DO ANY STATE WASTE CODES APPLY?
I
Texas Waste Code
YES ~ NO DO ANY CANADIAN PROVINCIAL WASTE CODES APPLY?
I YES ~ NO IS THIS WASTE PROHIBITED FROM LAND DISPOSAL WITHOUT FURTHER TREATMENT PER 40 CFR PART 268? LDR CATEGORY: Not subject to LDR VARIANCE INFO: :
YES ~ NO IS THIS A UNIVERSAL WASTE? YES ~ NO IS THE GENERATOR OF THE WASTE CLASSIFIED AS A VERY SMALL QUANTITY GENERATOR (VSQG) OR A STATE EQUIVALENT
DESIGNATION?
YES
NO IS THIS MATERIAL GOING TO BE MANAGED AS A RCRA EXEMPT COMMERCIAL PRODUCT, WHICH IS FUEL (40 CFR 261 .2 (C)(2)(11))?
YES ~ NO DOES TREATMENT OF THIS WASTE GENERATE A F006 OR F019 SLUDGE?
YES
NO IS THIS WASTE STREAM PROHIBITED FROM INCINERATION BASED ON THE INORGANIC METAL BEARING WASTE PROHIBITION FOUND AT 40 CFR
268.3(C)?
YES
NO IS THIS WASTE STREAM "USED OIL" WHICH IS TO BE MANAGED UNDER 40 CFR PART 279- STANDARDS FOR THE MANAGEMENT OF USED OIL?
YES ~ NO DOES THIS WASTE CONTAIN VOC'S IN CONCENTRATIONS >=500 PPM?
YES
NO DOES THE WASTE CONTAIN GREATER THAN 20% OF ORGANIC CONSTITUENTS WITH A VAPOR PRESSURE>= .3KPA (.044 PSIA)?
YES ~ NO DOES THIS WASTE CONTAIN AN ORGANIC CONSTITUENT WHICH IN ITS PURE FORM HAS A VAPOR PRESSURE> 76.6 KPA (11 .1 PSIA)?
YES ~ NO IS THIS CERCLA REGULATED (SUPERFUND) WASTE? YES ~ NO IS THE WASTE SUBJECT TO ONE OF THE FOLLOWING NESHAP RULES?
Hazardous Organic NESHAP (HON) rule (subpart G)
Pharmaceuticals production (subpart GGG)
YES
NO IF THIS IS A US EPA HAZARDOUS WASTE, DOES THIS WASTE STREAM CONTAIN BENZENE?
YES
NO Does the waste stream come from a facility with one of the SIC codes listed under benzene NESHAP or is this waste regulated under the benzene
NESHAP rules because the original source of the waste is from a chemical manufacturing , coke by-product recovery, or petroleum refinery process?
YES
NO Is the generating source of this waste stream a facility with Total Annual Benzene (TAB) >10 Mg/year?
What is the TAB quantity for your facility?
..__ _ _ _ _ __. Megagram/year (1 Mg= 2,200 lbs)
The basis for this determination is: Knowledge of the Waste Or Test Data
Knowledge
Testing
Describe the knowledge :
G. DOT/TDG INFORMATION DOT/TDG PROPER SHIPPING NAME:
NON DOT REGULATED MATERIAL, (WASTEWATER)
H. TRANSPORTATION REQUIREMENTS ESTIMATED SHIPMENT FREQUENCY ONE TIME
WEEKLy
MONTHLy ~ QUARTERLY
YEARLY
OTHER Other
CONTAINERIZED 0-0 CONTAINERS/SHIPMENT
STORAGE CAPACITY: CONTAINER TYPE:
PORTABLE TOTE TANK
BOXICARTONICASE
~ BULK LIQUID
GALLONS/SHIPMENT: 3000.00 Min -5000.00 GAL. Max
BULK SOLID
SHIPMENT UOM:
TON
TONS/YARDS/SHIPMENT: 0 Min 0 Max
CUBIC YARD BOX OTHER:
I. SPECIAL REQUEST
DRUM DRUM SIZE:
YARD
COMMENTS OR REQUESTS:
GENERATOR'S CERTIFICATION
I certify that I am authorized to execute this document as an authorized agent. I hereby certify that all information submitted in this and attached documents is correct to the best of my knowledge.I also certify that any samples submitted are representative of the actual waste.If Clean Harbors discovers a discrepancy during the approval process, Generator grants Clean Harbors the authority to amend the profile, as Clean Harbors deems necessary, to reflect the discrepancy.
AUTHORIZED SIGNATURE
NAME /PRINT)
TITLE
DATE
Report Printed On : Tuesday, July 16, 2024
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D. COMPOSITION
Clean Harbors Profile No. CH2803698B
Addendum
F. REGULATORY STATUS
Report Printed On : Tuesday, July 16, 2024
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APPENDIX 4. NME RESPONSE LETTER ON 4/10/2025
~ ~ _ .~.
~ TIONAL MARI~ ENVIRONMENTAL
April 10, 2024
Vince Damiano Vince.Damiano@erg.com EPA Inspection 2025
NME has been actively taking steps since our meeting to resolve all issues that were discussed. I have attached pictures showing the labeling "USED OIL" on the Frac tanks. Also, the totes and drums in secondary containment under the covered area. The Drums in picture have since been brought to MIKE's for disposal.
The HW-1 form has been filled out and emailed over to Small Business Assistance DEQ as of 4/9/25, it was submitted to Aylissa Auzenne(337-262-5581). I am awaiting a reply. Other Correspondence that I have personally talked with are DEQ Jennifer Willaims (225-219-1352), DEQ Daniel(225-219-1333) . Once DEQ reviews then it will be forwarded to permits division, then back to DEQ. Thanks.
Kind Regards,
Kenneth Bubba Nini
Please contact us with any questions.
_______________________________
Bubba Nini
National Marine Environmental Operations
Cell: 985-312-3151 Office: 985-354-6003 E-mail: bubba .nationalcompanies@gmail.com
1010 Jackson Road Morgan City, La 70380 Office: 985-354-6003
APPENDIX 5. PHOTOS FROM NME RESPONSE ON 4/10/2025