Document Rp2vr7rVzoM5qwej4ga9gV6Gv

f t E A ~ United States ..~ . Environmental Protection ~, Agency EPA REGION 6 Enforcement Division INSPECTION REPORT Inspection Entry Date/Time 6/19/2025 11:15 AM (CT) Inspection Exit Date/Time 6/19/2025 11:45 AM (CT) Regulatory Program Type of Inspection RCRA Compliance Evaluation Inspection (CEI) Announced: Yes (tenants and related facilities) Access: Granted Facility or Site Name Facility/Site Identifier Facility/Site Physical Address City, State, Zip Code County/Borough Generator Status NAICS Type of Operation Geographic Coordinates Allwaste Industrial Services, LLC TXR000085082 8718 Unity Drive Baytown, TX 77523 Chambers County Non-generator, Transporter (submitted in 2019 but never used) 48422 Allwaste Industrial Services, LLC (Allwaste) offers hydro excavation services for industries using pipelines. 29.8197, -94.8801 Additional Persons Participating in Inspection: Name Title Organization Andrew Swingler Contractor Eastern Research Group (ERG) Email Andrew.Swingler@erg.com Phone (717) 357-6661 Lead Inspector: Janosh Wolters Janosh WO Ite rs Date: 2025.07.23 20:11 :57 -04'00' Digitally signed by Janosh Wolters ERG IJanosh.Wolters@erg.com (484) 678-8675 Page 1 of 4 Allwaste Industrial Services, LLC Inspection Date: 6/19/2025 SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection The Port of Cedar Bayou and surrounding facilities were selected for inspection based on a Regional initiative to evaluate facilities at ports receiving or transporting Resource Conservation and Recovery Act (RCRA)-regulated hazardous wastes, and/or have an International Convention for the Prevention of Pollution from Ships (MARPOL) Annex V Certificate of Adequacy (COA) issued by the U.S. Coast Guard (USCG). This report is based on information supplied by the facility representatives, inspector observations, portrelated facilities, and other records, including photographs taken, verbal or written statements made during or after the on-site inspection, and/or materials shown, demonstrated, or submitted to the Environmental Protection Agency (EPA) during or after the on-site inspection. In addition, information gathered prior to or after the inspection from a review of EPA, State, and public records may be included in this report. Attendees Title/Organization Lead Inspector/ Contractor/ERG Chemical Engineer/ Contractor/ERG Allwaste Industrial Services, LLC/Supervisor Name Janosh Wolters Andrew Swingler Stephen Smart Opening Conf. Closing Conf. Yes Yes Yes Yes Yes Yes Page 2 of 4 Allwaste Industrial Services, LLC Inspection Date: 6/19/2025 Facility General Description Tenant/Area Allwaste Industrial Services, LLC Inspection Date 6/19/2025 Process Description (Allwaste) provides hydro excavation services for industries using pipelines. The facility does not maintain a MARPOL COA. Area of Concern No SECTION II - OBSERVATIONS Facility: Allwaste Industrial Services, LLC Section: 2.1 Date: 6/19/2025, 11:15 AM Contains AOC: No I Lead Inspector: Janosh Wolters Attendees: Stephen Smart (Supervisor) Contains CBI: No I Allwaste, located in Baymont, TX, provides hydro excavation services to industries, primarly pipelines. Allwaste travels to job sites that require hydro excavation of sediment around pipelines to allow for pipeline repair work. Allwaste uses high pressure water for hydro excavation and collects the sediment/dirt by vacuuming it into a collection tank. The sediment/dirt undergoes analytical testing to ensure it is nonhazardous prior to transportation off the client site. The sediment/dirt analytical includes testing for RCRA metals. Allwaste does not store any hydro-excavated material on site and transports the material directly to Enterprise Cedar Bayou at the completion of services performed. Mr. Smart stated that though material is rarely hazardous, if it is, Allwaste leaves the material on site for the client to handle all hazardous waste generator duties, including transportation of hazardous waste offsite. Allwaste transports all non-hazardous hydro-excavated material using a bill of lading to Enterprise Cedar Bayou, located at 7705 West Bay Road in Baytown, TX 77523. Mr. Smart stated Allwaste does not transport or generate any hazardous waste and that he was unaware the facility had the active EPA ID TXR000085082. Per RCRAInfo, the facility applied for an EPA ID number in 2019 and was registered only as a hazardous waste transporter. After the opening conference, the inspection team observed Allwaste's facility. The facility consisted of an office building, yard, and maintenance shop. The maintenance shop is used for truck maintenance and used oil is generated from maintenance completed on trucks. Inside the maintenance shop, the inspection team observed one 250-gallon tank of used oil that was approximately full. The used oil container was closed and labeled "Used Oil" (see Appendix 1 - Photo 1). Allwaste recycles used oil with Flex Oil Services, which picks up the used oil as needed based on truck maintenance completed. Flex Oil Services picks up the used oil at least once per year. At the time of the inspection, Allwaste was not accumulating any universal waste. Next, the inspection team walked through the yard that is used for parking trucks. The inspection team did not observe any waste being accumulated in the yard. The inspection team did not observe any areas of concern (AOCs) at the time of the inspection. However, further EPA review may change or add to their potential AOCs. A closing conference was conducted at approximately 11:45 AM with Allwaste personnel. Page 3 of 4 Allwaste Industrial Services, LLC Inspection Date: 6/19/2025 SECTION III - RECORDS REVIEW No RCRA-regulated records were reviewed during this focused on-site inspection. SECTION IV - AREAS OF CONCERN No AOCs were identified at the time of the inspection. SECTION V - FOLLOW UP Not Applicable Communication Log 24 hours prior to the on-site inspection, Janosh Wolters from ERG attempted to notify the facility that ERG would be performing a CEI at Allwaste. Janosh Wolters was forwarded to a voicemail and left a message, but did not receive a call back prior to the on-site inspection. SECTION VI - LIST OF APPENDICES Appendix 1. Photograph Log Page 4 of 4 APPENDIX 1. PHOTOGRAPH LOG UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Allwaste Industrial Services, LLC City: Baytown County/Parish: Chambers County I State: Texas I Photo No. 1 Photo File Name: DSCN8777.JPG Date of Photo: 6/19/2025 Time of Photo: 1130 hrs. Photographer: Janosh Wolters Description: View of 250-gallon tank accumulating used oil. The container was approximately full and was labeled with the words "Used Oil."