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 Report Printed On : Monday, February 3, 2025 /WINWEB/Profile\Waste Profile.rd( Page 1 of 5 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 Report Printed On : Monday, February 3, 2025 /WINWEB/Profile\Waste Profile.rd! Page 2 of 5 POLYMERIZABLE Clean Harbors Profile No. CH2901234B RADIOACTIVE REACTIVE MATERIAL ~ NONE OF THE ABOVE Report Printed On : Monday, February 3, 2025 /WINWEB/Profile\Waste Profile.rd! Page 3 of 5 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 /WINWEB/Profile\Waste Profile.rdl Page 4 of 5 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 Report Printed On : Monday, February 3, 2025 /WINWEB/Profile\Waste Profile.rd! Page 5 of 5 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 Report Printed On : Tuesday, July 16, 2024 /WINWEB/Profile\Waste Profile.rd! Page 1 of 5 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 Report Printed On : Tuesday, July 16, 2024 /WINWEB/Profile\Waste Profile.rd! Page 2 of 5 POLYMERIZABLE Clean Harbors Profile No. CH2803698B RADIOACTIVE REACTIVE MATERIAL ~ NONE OF THE ABOVE Report Printed On : Tuesday, July 16, 2024 /WINWEB/Profile\Waste Profile.rd! Page 3 of 5 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 /WINWEB/Profile\Waste Profile.rd! Page 4 of 5 D. COMPOSITION Clean Harbors Profile No. CH2803698B Addendum F. REGULATORY STATUS Report Printed On : Tuesday, July 16, 2024 /WINWEB/Profile\Waste Profile.rd! Page 5of 5 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