Document YGkDk5xrj2XnZkxzvYqN241QK

Click or tap here to enter text. Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 6 Enforcement Division INSPECTION REPORT 12/12/2023 01:50 PM (CT) 12/12/2023 04:25 PM (CT) RCRA RCRA Compliance Evaluation Inspection Announced: No Access: Granted Company Name 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 Mailing Address/Secondary Address City, State, Zip Code Brownsville Gulfside Warehouse, Inc. Brownsville Gulfside Warehouse, Inc. TXR000076653 400 RL Ostos Road Brownsville, TX 78521 Cameron Non-generator 488310 Port located on the U.S.-Mexico border. 25.931543, -97.498768 400 RL Ostos Road Brownsville, TX 78521 Permit Number (If Applicable) Not Applicable Additional Persons Participating in Inspection: Name Title Organization Email Phone Raymond P. Everitt Environmental Investigator Texas Commission on Environmental Quality (TCEQ), Region 15 Harlingen raymond.everitt@tceq.texas.gov (956) 430-6025 Lead Inspector: Dedriel Gardner [Signature] DEDRIEL GARDNER Digitally signed by DEDRIEL GARDNER Date: 2024.06.11 18:04:54 -05'00' EPA REGION 6 Gardner.Dedriel@epa.gov [Date] (913) 551-7049 Supervisor Review: Debra Pandak [Signature] DEBRA PANDAK PANDAK Digitally signed by DEBRA [Date] Date: 2024.06.12 16:23:24 -05'00' EPA REGION 6 Pandak.debra@epa.gov 1 of 6 Brownsville Gulfside Warehouse, Inc. Inspection Date(s): 12/12/2023 Click or tap here to enter text. SECTION I - INTRODUCTION Purpose of the Inspection Type of inspection: Compliance Evaluation Inspection On December 12, 2023, I, Dedriel Gardner, conducted an unannounced inspection of the Brownsville Gulfside Warehouse, Inc. (BGW) facility located at 400 RL Ostos Road in Brownsville, Texas, for compliance with the Resource Conservation and Recovery Act (RCRA). The CEI was needed following a September 28, 2023, focused RCRA inspection conducted at the Port of Brownsville (POB) and its tenants. Ramiro Yanez, Foreman, acted as the facility representative. I informed him this inspection would be evaluating the paint related materials EPA observed onsite during the previous September 28, 2023, inspection. This report is based on information supplied by Mr. Yanez, inspector observations, and records including photographs taken, verbal or written statements made during or after the onsite 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. Photographs taken during the inspection to document onsite observations are included as Appendix 1. Attendees Title/Organization Name Phone Lead Inspector/ Dedriel Enforcement Gardner Officer/EPA Region 6 Environmental Investigator/Texas Commission on Environmental Quality (TCEQ), Region 15 Harlingen Raymond P. Everitt Foreman/BGW Ramiro Yanez Logistics Coordinator Rachel /BGW Sarquis (913) 5517049 (956) 4306025 (956) 4668521 (956) 8314241 Email Gardner.Dedriel@epa.gov Opening Closing Conf. Conf. Yes Yes raymond.everitt@tceq.texas.gov Yes No egutierrez@brownsvillegulfside.com Yes Yes rsarquis@brownsvillegulfside.com No Yes 2 of 6 Brownsville Gulfside Warehouse, Inc. Inspection Date(s): 12/12/2023 Click or tap here to enter text. SECTION II - OPENING CONFERENCE/OBSERVATIONS During the previous September 28, 2023, inspection, over 1000 containers of apparent paint related materials were observed stored onsite in a waste like manner (see the September 28, 2023, POB inspection report). This inspection concentrated on the status of the paint related materials EPA observed during the previous inspection. The following was noted: 1. On December 12, 2023, Raymond Everitt (TCEQ) and I arrived at BGW at about 1:50 P.M. 2. I asked for Belinda Vasquez, the facility contact from the previous inspection. However, I was told that she was in a meeting and the Foreman will be conducting the inspection. Ramiro Yanez, Foreman, arrived about 2:05 P.M. and acted as the facility representative. Mr. Yanez has worked for BGW approximately 38 years and at the POB for 53 years. 3. Mr. Yanez spoke Spanish and Mr. Everitt acted as his interpreter during this inspection. 4. Mr. Everitt and I introduced ourselves and presented our credentials to Mr. Yanez. I informed him we were there to conduct a inspection under the authority of Section 3007 of RCRA. I discussed EPA Region 6's Confidentiality Notice (40 CFR Section 2.203) for any, potential Business Confidentiality Information claims by BGW. At the conclusion of the inspection, Mr. Yanez stated through an interpreter (Rachel Sarquis, BGW Logistics Coordinator) that nothing was confidential, and they were not making any claims. 5. Mr. Yanez stated the following regarding the paint related materials currently onsite and those EPA observed during the previous September 28, 2023, inspection: a. The warehouses were built in the 1970s. b. Partoque Padre located in Matamoros, Mexico, leases the space at BGW. They pay rent but do not have a written lease agreement. Also, Partoque Padre does not have any rent receipts as they pay in cash. As discussed below, it is normal for BGW's customers to use the warehouse as needed and not have written lease agreements. c. An unknown named company located in McAllen, Texas, sent the materials to BGW for storage in the space leased by Partoque Padre. d. He believes Partoque Padre is a paint processor that will mix/reprocess these paint related materials and/or resale them as is. e. Partoque Padre has a transportation company to transport the materials from BGW to Partoque Padre in Mexico. I asked for the shipping papers, and he stated that EPA would have to get them from Partoque Padre. f. I asked how long Partoque Padre has been leasing this space and he stated about two years. However, I reminded him that during the previous inspection, he stated that some of the material had been there six years. He stated yes, they have been leasing for six years. g. Since the previous inspection, paints have been removed from Warehouses #1 and #2. He stated that about 150 pallets of paints were removed from Warehouse #1 and about 200 pallets of paints removed from Warehouse #2 over the past one to one and half months. Some were last removed about two weeks ago from Warehouse #2. All had been shipped 3 of 6 Brownsville Gulfside Warehouse, Inc. Inspection Date(s): 12/12/2023 Click or tap here to enter text. to Partoque Padre in Mexico. Nothing has been removed from Warehouse #3 but will be after he completes the removal from the other two warehouses. h. He expects to have all the materials onsite removed within a week. i. He has no relations to the McAllen or Partoque Padre companies. j. I observed spilled paint pens on the ground on the south side of Warehouse #1 (see Photos 31 - 38). He stated that about a month ago, a pallet was being loaded onto a truck for transport to Mexico. The pallet was damaged by the forklift which caused the pens to spill onto the ground. He plans to pick them up, store them at BGW while he tries to sell them. If he cannot sell them, he will dispose of them. [AOC #1a: No documentation, as required, to demonstrate the crushed spilled pens are not a solid waste - 40 CFR 261.2(f)]. 6. During the walk-through, I observed over 500 partially full to full containers of apparently waste like paint related materials. The container sizes included approximately 250-gallon totes, 1-cubic yard boxes, 55-gallon drums, 5-gallon pails, small pens, and 1-gallon, 1-quart, and 1-pint cans. The containers appeared waste-like based on they were old and stored haphazardly, i.e., some had cobwebs attached, a thick layer of dust, separated into phases, open lids with hardened contents, paint spilled on sides, limited access due to inadequate aisle space, and containers falling off pallets. Observations at each warehouse include the following: a. Warehouse #1 - During the previous inspection, the EPA observed approximately 164 pallets of the various size containers of apparently waste-like materials being stored. It appeared that about a third to a half of the materials had been removed. The containers I observed remaining included containers that were unlabeled, and others labeled as stated in the previous inspection report and shown in Photos 1 thru 51. See the Warehouse #1 facility layout with the current and past photo locations in Appendix 1). The unlabeled containers included about six pallets of apparent 1-quart cans that had the labels removed and Mr. Yanez stated he did not know why (see Photos 14 - 16, 19, and 20). Also, I observed two unlabeled 5-gallon plastic jugs that had a solvent type of odor. Mr. Yanez stated that they came over with the electrical box stored next to them and he did not know what they were. [AOC #1b: No documentation as, required, to demonstrate that materials stored in Warehouse #1 are not a solid waste - 40 CFR 261.2(f)]. b. Warehouse #2 - During the previous inspection, the EPA observed over 220 containers of the various sizes. It appeared that about a half of the materials had been removed since the previous inspection. The containers I observed remaining included containers that were unlabeled, and others labeled as stated in the previous inspection report and shown in Photos 52 thru 96. See the Warehouse #2 facility layout with the current and past photo locations in Appendix 1). [AOC #1c: No documentation, as required, to demonstrate that materials stored in Warehouse #2 are not a solid waste - 40 CFR 261.2(f)] c. Warehouse #3 - During the previous inspection, the EPA observed over 750 containers of waste-like materials being stored. None of the materials observed during the previous inspection had been removed. I was not able to see completely into the warehouse as supersacks of cement were blocking the doors as shown in Photos 97 and 98. See the Warehouse #3 facility layout with the current and past photo locations in Appendix 1). [AOC #1d: No documentation, as required, to demonstrate that materials stored in Warehouse #3 are not a solid waste - 40 CFR 261.2(f)] 4 of 6 Brownsville Gulfside Warehouse, Inc. Inspection Date(s): 12/12/2023 Click or tap here to enter text. 7. In Warehouses #7 and #9, I did not observe any apparent changes regarding the types of materials stored, i.e., no apparent wastes were being stored. SECTION IV - AREA OF CONCERN The Area(s) of Concern do not constitute a formal compliance determination or violation. Mr. Yanez stated that he did not have records and did not provide any. I asked Mr. Yanez to verify that the above materials were not solid wastes including information on where the paint related materials were being sent and how recycle. According to 40 CFR 261.2(f), a company that claims certain materials are not solid waste or is exempt from regulation, must demonstrate that there is a known market or disposition for the material, and that they meet the terms of the exemption. In doing so, they must provide appropriate documentation (such as contracts showing that a second person uses the material as an ingredient in a production process) to demonstrate that the material is not a waste or is exempt from regulation. a. AOC #1a: No documentation, as required, to demonstrate the crushed spilled pens are not a solid waste - 40 CFR 261.2(f). b. AOC #1b: No documentation, as required, to demonstrate that materials stored in Warehouse #1, are not a solid waste - 40 CFR 261.2(f). c. AOC #1c: No documentation, as required, to demonstrate that materials stored in Warehouse #2 are not a solid waste - 40 CFR 261.2(f). d. AOC #1d: No documentation, as required, to demonstrate that materials stored in Warehouse #3 are not a solid waste - 40 CFR 261.2(f). SECTION V - CLOSING CONFERENCE AND FOLLOW UP Mr. Yanez stated he would try to locate the contact information for the McAllen and Mexico companies that day. I informed him that I would return at about 9:00 A.M. the following day (December 13, 2023) to collect it. However, I closed out the inspection with Mr. Yanez and Ms. Sarquis on December 12, 2023, in case I received the information prior to my returning. Mr. Yanez stated through an interpreter (Rachel Sarquis, BGW Logistics Coordinator) that nothing was confidential, and they were not making any confidentiality claims. On December 13, 2023, Ms. Sarquis called me prior to my arriving at BGW. Ms. Sarquis stated she emailed me the contact names for the company that sends the materials to BGW and for the Mexico company, where materials are sent (see Appendix 2). Therefore, I did not return to BGW. I asked Ms. Sarquis if BGW has a contract with the Mexico company and she stated no. She stated that none of their customers have written contracts and they use the warehouse as long as needed. I asked if they had rent receipts and Ms. Sarquis stated EPA would have to ask BGW's bookkeeper. According to Appendix 2, CBD-International Inc, New Braunswick, New Jersey 08901 sends the paint related materials to BGW and provided a contact name and number (correct company name later determined to be GBD). Also, the company in Mexico, where the paint materials are being sent, is Sr. Paco Martinez, Calle 12 #900A, Laguna Santa Maria, Esquina Colonia Ind, H. Matamoros Tamaulipas. On 5 of 6 Brownsville Gulfside Warehouse, Inc. Inspection Date(s): 12/12/2023 Click or tap here to enter text. December 13, 2023, I contacted Mike at the New Jersey company. He stated that his name is Mike Reys, Salesman and they are a paint vendor and have customers throughout the country. This includes their customer Jose Elizondo who sends materials to BGW. Mr. Reyes also stated that the warehouse materials are sent to Paint (but spelled in Spanish) Que Pardre. He gave the name "Heather" as the GBD bookkeeper who would have the shipping documents of the materials sent to BGW. On December 13, 2023, I contacted Heather who stated that the company's name is GBD and not CBD. She stated that she would send me all the shipping docs for the past three years. She also stated that the company in Mexico buys the materials that are sent to BGW. She stated that GBD would not have any documents of where the material was sent from BGW to Mexico. SECTION VI - LIST OF APPENDICES Appendix 1 - Photo Log and Photo Layout Appendix 2 - 12/13/2023 BGW Email with Contact Names for GBD and Company in Mexico 6 of 6 12-12-23 Inspection Report APPENDIX 1 - Photo Locations and Photo Log Brownsville Gulfside Warehouse Inc., Brownsville, TX - TXR000076653 Inspection Date(s): 12/12/2023 APPENDIX 1: PHOTO LOG PHOTO 1 BGW Warehouse #1 P1010001.JPG 12/12/2023 02:30 PM No CBI No PII Photographer: Dedriel Gardner Pallets of off-spec paints/coatings. Orange labels say "Marking Restriction. Must be Relabeled." PHOTO 2 BGW Warehouse #1 P1010002.JPG 12/12/2023 02:30 PM No CBI No PII Photographer: Dedriel Gardner Pallets of off-spec paints/coatings. Super sacks contain cement. 1 of 49 Brownsville Gulfside Warehouse Inc., Brownsville, TX - TXR000076653 Inspection Date(s): 12/12/2023 PHOTO 3 BGW Warehouse #1 P1010003.JPG 12/12/2023 02:30 PM No CBI No PII Photographer: Dedriel Gardner Close-up of a label on one of the 5-gallon pails of off-spec paint (shown in photo 1). Orange label says "Marking Restriction. Must be Relabeled." PHOTO 4 BGW Warehouse #1 P1010004.JPG 12/12/2023 02:31 PM No CBI No PII Photographer: Dedriel Gardner Pallets of off-spec paints/coatings. Orange labels say "Marking Restriction. Must be Relabeled." 2 of 49 Brownsville Gulfside Warehouse Inc., Brownsville, TX - TXR000076653 Inspection Date(s): 12/12/2023 PHOTO 5 BGW Warehouse #1 P1010005.JPG 12/12/2023 02:31 PM No CBI No PII Photographer: Dedriel Gardner Pallets of off-spec paints/coatings. Orange labels say "Marking Restriction. Must be Relabeled." PHOTO 6 BGW Warehouse #1 P1010006.JPG 12/12/2023 02:32 PM No CBI No PII Photographer: Dedriel Gardner Pallets of apparent paint related material. Top tote dated 2011 and 15 totes. Bottom tote labeled "Diamond Collection Latex Interior/Exterior Base Paint For Factory". 3 of 49 Brownsville Gulfside Warehouse Inc., Brownsville, TX - TXR000076653 Inspection Date(s): 12/12/2023 PHOTO 7 BGW Warehouse #1 P1010007.JPG 12/12/2023 02:32 PM No CBI No PII Photographer: Dedriel Gardner Pallets of apparent paint related material. Top tote labeled "Diamond Collection Latex Interior/Exterior Base Paint For Factory". Bottom tote labeled "Trashy" and dated 7/5/2011. Small label to the left printed with "SEKO WORLDWIDE LRD." PHOTO 8 BGW Warehouse #1 P1010008.JPG 12/12/2023 02:32 PM No CBI No PII Photographer: Dedriel Gardner Close-up of label of tote of apparent paint-related material in photo 7. Labeled "Trashy" and dated 7/5/2011. 4 of 49 Brownsville Gulfside Warehouse Inc., Brownsville, TX - TXR000076653 Inspection Date(s): 12/12/2023 PHOTO 9 BGW Warehouse #1 P1010009.JPG 12/12/2023 02:33 PM No CBI No PII Photographer: Dedriel Gardner Spilled pallet of containers of apparent paint-related material. PHOTO 10 BGW Warehouse #1 P1010010.JPG 12/12/2023 02:34 PM No CBI No PII Photographer: Dedriel Gardner Close-up of a label on a 1-gallon can shown in photo 15. " Can labeled "Danger! Flammable Liquid and Vapor. Vapor Harmful. Causes Eye Irritation. May be Fatal or Cause Blindness If Swallowed." Orange labels say "Marking Restriction. Must be Relabeled. 5 of 49 Brownsville Gulfside Warehouse Inc., Brownsville, TX - TXR000076653 Inspection Date(s): 12/12/2023 PHOTO 11 BGW Warehouse #1 P1010011.JPG 12/12/2023 02:34 PM No CBI No PII Photographer: Dedriel Gardner Close-up of a label on a 1-gallon can shown in photo 15. Contains toluene, MEK, isobutyl acetate, isopropanol, and methanol. VOC content <= 680 g/L. PHOTO 12 BGW Warehouse #1 P1010012.JPG 12/12/2023 02:34 PM No CBI No PII Photographer: Dedriel Gardner Close-up of label on one of the 1-gallon cans shown in photo 15. Orange label say "Marking Restriction. Must be Relabeled." Can labeled "Danger! Flammable Liquid and Vapor. Vapor Harmful. Causes Eye Irritation. May be Fatal or Cause Blindness If Swallowed." 6 of 49 Brownsville Gulfside Warehouse Inc., Brownsville, TX - TXR000076653 Inspection Date(s): 12/12/2023 PHOTO 13 BGW Warehouse #1 P1010013.JPG 12/12/2023 02:35 PM No CBI No PII Photographer: Dedriel Gardner Close-up of an open 1-gallon can labeled as enamel shown in photo 15. PHOTO 14 BGW Warehouse #1 P1010014.JPG 12/12/2023 02:36 PM No CBI No PII Photographer: Dedriel Gardner Close-up of the unlabeled 1-quart cans where the labels appeared to have been removed shown in photo 15. 7 of 49 Brownsville Gulfside Warehouse Inc., Brownsville, TX - TXR000076653 Inspection Date(s): 12/12/2023 PHOTO 15 BGW Warehouse #1 P1010015.JPG 12/12/2023 02:36 PM No CBI No PII Photographer: Dedriel Gardner Pallets of off-spec paints/coatings. Orange labels say "Marking Restriction. Must be Relabeled." 1-gallon cans labeled "Danger! Flammable Liquid and Vapor. Vapor Harmful. Causes Eye Irritation. May be Fatal or Cause Blindness If Swallowed." Pallet on right contained unlabeled approximately 1-quart cans where the labels appeared to have been removed. PHOTO 16 BGW Warehouse #1 P1010016.JPG 12/12/2023 02:36 PM No CBI No PII Photographer: Dedriel Gardner Close-up of the unlabeled approximately 1-quart cans where the labels appeared to have been removed shown in photo 15. 8 of 49 Brownsville Gulfside Warehouse Inc., Brownsville, TX - TXR000076653 Inspection Date(s): 12/12/2023 PHOTO 17 BGW Warehouse #1 P1010017.JPG 12/12/2023 02:37 PM No CBI No PII Photographer: Dedriel Gardner Close-up of the 1-gallon cans of enamels shown in photo 18. PHOTO 18 BGW Warehouse #1 P1010018.JPG 12/12/2023 02:37 PM No CBI No PII Photographer: Dedriel Gardner Pallets of off-spec paints/coatings. Orange labels say "Marking Restriction. Must be Relabeled." 9 of 49 Brownsville Gulfside Warehouse Inc., Brownsville, TX - TXR000076653 Inspection Date(s): 12/12/2023 PHOTO 19 BGW Warehouse #1 P1010019.JPG 12/12/2023 02:38 PM No CBI No PII Photographer: Dedriel Gardner Pallet of unlabeled 1-quart cans where the labels appeared to have been removed. PHOTO 20 BGW Warehouse #1 P1010020.JPG 12/12/2023 02:40 PM No CBI No PII Photographer: Dedriel Gardner Pallets of unlabeled 1-quart cans where the labels appeared to have been removed. 10 of 49 Brownsville Gulfside Warehouse Inc., Brownsville, TX - TXR000076653 Inspection Date(s): 12/12/2023 PHOTO 21 BGW Warehouse #1 P1010021.JPG 12/12/2023 02:41 PM No CBI No PII Photographer: Dedriel Gardner Pallets of apparent paint related material. Tote labeled "Trashy" and dated 7/5/2011. PHOTO 22 BGW Warehouse #1 P1010022.JPG 12/12/2023 02:42 PM No CBI No PII Photographer: Dedriel Gardner Close-up of label on tote of apparent paint related material printed with "SEKO WORLDWIDE LRD." 11 of 49 Brownsville Gulfside Warehouse Inc., Brownsville, TX - TXR000076653 Inspection Date(s): 12/12/2023 PHOTO 23 BGW Warehouse #1 P1010023.JPG 12/12/2023 02:42 PM No CBI No PII Photographer: Dedriel Gardner Miscellaneous rolls and super sacks of cement in area where paint related materials were being stored during the previous 9/28/23 inspection. PHOTO 24 BGW Warehouse #1 P1010024.JPG 12/12/2023 02:43 PM No CBI No PII Photographer: Dedriel Gardner Miscellaneous items and super sacks of cement in area where paint related materials were being stored during the previous 9/28/23 inspection. 12 of 49 Brownsville Gulfside Warehouse Inc., Brownsville, TX - TXR000076653 Inspection Date(s): 12/12/2023 PHOTO 25 BGW Warehouse #1 P1010025.JPG 12/12/2023 02:43 PM No CBI No PII Photographer: Dedriel Gardner Miscellaneous items and super sacks of cement in area where paint related materials were being stored during the previous 9/28/23 inspection. PHOTO 26 BGW Warehouse #1 P1010026.JPG 12/12/2023 02:44 PM No CBI No PII Photographer: Dedriel Gardner Miscellaneous items and super sacks of cement in area where paint related materials were being stored during the previous 9/28/23 inspection. 13 of 49 Brownsville Gulfside Warehouse Inc., Brownsville, TX - TXR000076653 Inspection Date(s): 12/12/2023 PHOTO 27 BGW Warehouse #1 P1010027.JPG 12/12/2023 02:45 PM No CBI No PII Photographer: Dedriel Gardner Super sacks of cement in area near where paint related materials were being stored during the previous 9/28/23 inspection. PHOTO 28 BGW Warehouse #1 P1010028.JPG 12/12/2023 02:45 PM No CBI No PII Photographer: Dedriel Gardner Super sacks of cement in area where paint related materials were being stored during the previous 9/28/23 inspection. 14 of 49 Brownsville Gulfside Warehouse Inc., Brownsville, TX - TXR000076653 Inspection Date(s): 12/12/2023 PHOTO 29 BGW Warehouse #1 P1010029.JPG 12/12/2023 02:46 PM No CBI No PII Photographer: Dedriel Gardner Totes of paint related materials and super sacks of cement. PHOTO 30 BGW Warehouse #1 P1010030.JPG 12/12/2023 02:47 PM No CBI No PII Photographer: Dedriel Gardner Miscellaneous items and super sacks of cement and containers of paint related materials. 15 of 49 Brownsville Gulfside Warehouse Inc., Brownsville, TX - TXR000076653 Inspection Date(s): 12/12/2023 PHOTO 31 BGW Warehouse #1 P1010031.JPG 12/12/2023 02:49 PM No CBI No PII Photographer: Dedriel Gardner Paint pens that spilled on the ground about a month ago when a pallet of paint pens was being loaded onto a truck and was damaged by the forklift. Tire tracks were on the spilled paint pens. PHOTO 32 BGW Warehouse #1 P1010032.JPG.JPG 12/12/2023 02:49 PM No CBI No PII Photographer: Dedriel Gardner Close-up of spilled paint pens on the ground shown in photo 31. 16 of 49 Brownsville Gulfside Warehouse Inc., Brownsville, TX - TXR000076653 Inspection Date(s): 12/12/2023 PHOTO 33 BGW Warehouse #1 P1010033.JPG 12/12/2023 02:49 PM No CBI No PII Photographer: Dedriel Gardner Close-up of spilled paint pens on the ground shown in photo 31. PHOTO 34 BGW Warehouse #1 P1010034.JPG 12/12/2023 02:50 PM No CBI No PII Photographer: Dedriel Gardner Close-up of spilled paint pens on the ground shown in photo 31. 17 of 49 Brownsville Gulfside Warehouse Inc., Brownsville, TX - TXR000076653 Inspection Date(s): 12/12/2023 PHOTO 35 BGW Warehouse #1 P1010035.JPG 12/12/2023 02:50 PM No CBI No PII Photographer: Dedriel Gardner Close-up of spilled paint pens on the ground shown in photo 31. PHOTO 36 BGW Warehouse #1 P1010036.JPG 12/12/2023 02:50 PM No CBI No PII Photographer: Dedriel Gardner Close-up of spilled paint pens on the ground shown in photo 31. 18 of 49 Brownsville Gulfside Warehouse Inc., Brownsville, TX - TXR000076653 Inspection Date(s): 12/12/2023 PHOTO 37 BGW Warehouse #1 P1010037.JPG 12/12/2023 02:51 PM No CBI No PII Photographer: Dedriel Gardner Close-up of spilled paint pens on the ground shown in photo 31. PHOTO 38 BGW Warehouse #1 P1010038.JPG 12/12/2023 02:52 PM No CBI No PII Photographer: Dedriel Gardner Close-up of spilled paint pens on the ground shown in photo 31. 19 of 49 Brownsville Gulfside Warehouse Inc., Brownsville, TX - TXR000076653 Inspection Date(s): 12/12/2023 PHOTO 39 BGW Warehouse #1 P1010039.JPG 12/12/2023 02:55 PM No CBI No PII Photographer: Dedriel Gardner Miscellaneous items and super sacks of cement and containers of apparent paint related materials. PHOTO 40 BGW Warehouse #1 P1010040.JPG 12/12/2023 02:56 PM No CBI No PII Photographer: Dedriel Gardner Wrapped pallets labeled "Purple" with a date of 11/16/2018. 20 of 49 Brownsville Gulfside Warehouse Inc., Brownsville, TX - TXR000076653 Inspection Date(s): 12/12/2023 PHOTO 41 BGW Warehouse #1 12/12/2023 02:56 PM No CBI Black buckets of unknown material. No PII P1010041.JPG Photographer: Dedriel Gardner PHOTO 42 BGW Warehouse #1 P1010042.JPG 12/12/2023 02:57 PM No CBI No PII Photographer: Dedriel Gardner Black buckets of unknown material. Wrapped pallets labeled "Purple" with a date of 11/16/2018. 21 of 49 Brownsville Gulfside Warehouse Inc., Brownsville, TX - TXR000076653 Inspection Date(s): 12/12/2023 PHOTO 43 BGW Warehouse #1 12/12/2023 02:58 PM No CBI No PII Containers of apparent paint related materials. P1010043.JPG Photographer: Dedriel Gardner PHOTO 44 BGW Warehouse #1 P1010044.JPG 12/12/2023 02:59 PM No CBI No PII Photographer: Dedriel Gardner Apparent paint related material being stored and super sacks of cement. 22 of 49 Brownsville Gulfside Warehouse Inc., Brownsville, TX - TXR000076653 Inspection Date(s): 12/12/2023 PHOTO 45 BGW Warehouse #1 12/12/2023 03:00 PM No CBI Totes of off-spec paints/coatings. No PII P1010045.JPG Photographer: Dedriel Gardner PHOTO 46 BGW Warehouse #1 12/12/2023 03:00 PM No CBI No PII Close-up of label on tote shown in photo 45. P1010046.JPG Photographer: Dedriel Gardner 23 of 49 Brownsville Gulfside Warehouse Inc., Brownsville, TX - TXR000076653 Inspection Date(s): 12/12/2023 PHOTO 47 BGW Warehouse #1 P1010047.JPG 12/12/2023 03:00 PM No CBI No PII Photographer: Dedriel Gardner Close-up of a Steris Nonconformance Form on a tote of apparent paint related materials dated 7/12/23 and labeled as having "Contamination". PHOTO 48 BGW Warehouse #1 P1010048.JPG 12/12/2023 03:00 PM No CBI No PII Photographer: Dedriel Gardner Close-up of a Steris Nonconformance Form on a tote of apparent paint related materials dated 7/12/23 and labeled as having "Cos having "Contamination". 24 of 49 Brownsville Gulfside Warehouse Inc., Brownsville, TX - TXR000076653 Inspection Date(s): 12/12/2023 PHOTO 49 BGW Warehouse #1 P1010049.JPG 12/12/2023 03:01 PM No CBI No PII Photographer: Dedriel Gardner Tote of apparent paint related materials with a Steris Nonconformance Form dated 7/12/23 and labeled as having "Contamination". PHOTO 50 BGW Warehouse #1 P1010050.JPG 12/12/2023 03:03 PM No CBI No PII Photographer: Dedriel Gardner Two unknown unlabeled 5-gallon plastic jugs that had a solvent type odor. Came over with the electrical box located next to them. 25 of 49 Brownsville Gulfside Warehouse Inc., Brownsville, TX - TXR000076653 Inspection Date(s): 12/12/2023 PHOTO 51 BGW Warehouse #1 P1010051.JPG 12/12/2023 03:03 PM No CBI No PII Photographer: Dedriel Gardner Two unknown unlabeled 5-gallon plastic jugs that had a solvent type odor. Came over with the electrical box located next to them. PHOTO 52 BGW Warehouse #2 P1010052.JPG 12/12/2023 03:05 PM No CBI No PII Photographer: Dedriel Gardner Pallets of apparent paint related material being stored and super sacks of cement in area where paint related materials were being stored during the previous 9/28/23 inspection. 26 of 49 Brownsville Gulfside Warehouse Inc., Brownsville, TX - TXR000076653 Inspection Date(s): 12/12/2023 PHOTO 53 BGW Warehouse #2 12/12/2023 03:05 PM No CBI Super sacks of cement in area. No PII P1010053.JPG Photographer: Dedriel Gardner PHOTO 54 BGW Warehouse #2 P1010054.JPG 12/12/2023 03:05 PM No CBI No PII Photographer: Dedriel Gardner Super sacks of cement in area where paint related materials were being stored during the previous 9/28/23 inspection. 27 of 49 Brownsville Gulfside Warehouse Inc., Brownsville, TX - TXR000076653 Inspection Date(s): 12/12/2023 PHOTO 55 BGW Warehouse #2 P1010055.JPG 12/12/2023 03:06 PM No CBI No PII Photographer: Dedriel Gardner Pallets of apparent paint related material being stored and super sacks of cement in area where paint related materials were being stored during the previous 9/28/23 inspection. PHOTO 56 BGW Warehouse #2 P1010056.JPG 12/12/2023 03:06 PM No CBI No PII Photographer: Dedriel Gardner Close up of can labels on pallet of apparent paint related material shown on photo 57. 28 of 49 Brownsville Gulfside Warehouse Inc., Brownsville, TX - TXR000076653 Inspection Date(s): 12/12/2023 PHOTO 57 BGW Warehouse #2 12/12/2023 03:07 PM No CBI No PII Pallet of apparent paint related material being stored. P1010057.JPG Photographer: Dedriel Gardner PHOTO 58 BGW Warehouse #2 P1010058.JPG 12/12/2023 03:07 PM No CBI No PII Photographer: Dedriel Gardner A pile of apparent paint related material being stored including some containers of hardened material. 29 of 49 Brownsville Gulfside Warehouse Inc., Brownsville, TX - TXR000076653 Inspection Date(s): 12/12/2023 PHOTO 59 BGW Warehouse #2 P1010059.JPG 12/12/2023 03:07 PM No CBI No PII Photographer: Dedriel Gardner A close-up of a container of hardened material in the pile of apparent paint related material shown in photo 58. PHOTO 60 BGW Warehouse #2 P1010060.JPG 12/12/2023 03:08 PM No CBI No PII Photographer: Dedriel Gardner A close-up of a container of hardened material in the pile of apparent paint related material shown in photo 58. 30 of 49 Brownsville Gulfside Warehouse Inc., Brownsville, TX - TXR000076653 Inspection Date(s): 12/12/2023 PHOTO 61 BGW Warehouse #2 P1010061.JPG 12/12/2023 03:08 PM No CBI No PII Photographer: Dedriel Gardner Close up of unlabeled approximately 1-gallon containers shown in photo 63. PHOTO 62 BGW Warehouse #2 P1010062.JPG 12/12/2023 03:08 PM No CBI No PII Photographer: Dedriel Gardner Close up of unlabeled approximately 1-gallon containers shown in photo 63. 31 of 49 Brownsville Gulfside Warehouse Inc., Brownsville, TX - TXR000076653 Inspection Date(s): 12/12/2023 PHOTO 63 BGW Warehouse #2 12/12/2023 03:09 PM No CBI No PII Apparent paint related material being stored. P1010063.JPG Photographer: Dedriel Gardner PHOTO 64 BGW Warehouse #2 12/12/2023 03:10 PM No CBI No PII Apparent paint related material being stored. P1010064.JPG Photographer: Dedriel Gardner 32 of 49 Brownsville Gulfside Warehouse Inc., Brownsville, TX - TXR000076653 Inspection Date(s): 12/12/2023 PHOTO 65 BGW Warehouse #2 P1010065.JPG 12/12/2023 03:10 PM No CBI No PII Photographer: Dedriel Gardner Apparent paint related material being stored including some 8-ounce glass jars that spilled from boxes. PHOTO 66 BGW Warehouse #2 P1010066.JPG 12/12/2023 03:11 PM No CBI No PII Photographer: Dedriel Gardner Close up of apparent paint related material being stored including some 8-ounce glass jars that spilled from boxes shown in photo 65. 33 of 49 Brownsville Gulfside Warehouse Inc., Brownsville, TX - TXR000076653 Inspection Date(s): 12/12/2023 PHOTO 67 BGW Warehouse #2 P1010067.JPG 12/12/2023 03:11 PM No CBI No PII Photographer: Dedriel Gardner Close up of apparent paint related material in 8-ounce glass jars that spilled from boxes shown in photo 65. PHOTO 68 BGW Warehouse #2 P1010068.JPG 12/12/2023 03:11 PM No CBI No PII Photographer: Dedriel Gardner Close up of apparent paint related material in 8-ounce glass jars that spilled from boxes shown in photo 65. 34 of 49 Brownsville Gulfside Warehouse Inc., Brownsville, TX - TXR000076653 Inspection Date(s): 12/12/2023 PHOTO 69 BGW Warehouse #2 P1010069.JPG 12/12/2023 03:11 PM No CBI No PII Photographer: Dedriel Gardner Close up of apparent paint related material in 8-ounce glass jars that spilled from boxes shown in photo 65. PHOTO 70 BGW Warehouse #2 P1010070.JPG 12/12/2023 03:12 PM No CBI No PII Photographer: Dedriel Gardner Apparent paint related material being stored including some 8-ounce glass jars that spilled from boxes. 35 of 49 Brownsville Gulfside Warehouse Inc., Brownsville, TX - TXR000076653 Inspection Date(s): 12/12/2023 PHOTO 71 BGW Warehouse #2 P1010071.JPG 12/12/2023 03:12 PM No CBI No PII Photographer: Dedriel Gardner Apparent paint related material in 8-ounce glass jars in a bucket. PHOTO 72 BGW Warehouse #2 P1010072.JPG 12/12/2023 03:13 PM No CBI No PII Photographer: Dedriel Gardner Apparent paint related material being stored including some that had hardened and some 8-ounce glass jars that spilled from boxes. 36 of 49 Brownsville Gulfside Warehouse Inc., Brownsville, TX - TXR000076653 Inspection Date(s): 12/12/2023 PHOTO 73 BGW Warehouse #2 12/12/2023 03:14 PM No CBI No PII Apparent paint related material being stored. P1010073.JPG Photographer: Dedriel Gardner PHOTO 74 BGW Warehouse #2 12/12/2023 03:15 PM No CBI No PII Apparent paint related material being stored. P1010074.JPG Photographer: Dedriel Gardner 37 of 49 Brownsville Gulfside Warehouse Inc., Brownsville, TX - TXR000076653 Inspection Date(s): 12/12/2023 PHOTO 75 BGW Warehouse #2 P1010075.JPG 12/12/2023 03:15 PM No CBI No PII Photographer: Dedriel Gardner View of a label of a can of "production sample" from Sherwin-Williams. Date is 4/8/2009. PHOTO 76 BGW Warehouse #2 P1010076.JPG 12/12/2023 03:15 PM No CBI No PII Photographer: Dedriel Gardner Close up of label on apparent paint related material shown in photo 74. 38 of 49 Brownsville Gulfside Warehouse Inc., Brownsville, TX - TXR000076653 Inspection Date(s): 12/12/2023 PHOTO 77 BGW Warehouse #2 P1010077.JPG 12/12/2023 03:16 PM No CBI No PII Photographer: Dedriel Gardner Close up of label on apparent paint related material shown in photo 74. PHOTO 78 BGW Warehouse #2 P1010078.JPG 12/12/2023 03:17 PM No CBI No PII Photographer: Dedriel Gardner Pallet of off-spec paints/coatings. Orange labels say "Marking Restriction. Must be Relabeled." 39 of 49 Brownsville Gulfside Warehouse Inc., Brownsville, TX - TXR000076653 Inspection Date(s): 12/12/2023 PHOTO 79 BGW Warehouse #2 P1010079.JPG 12/12/2023 03:17 PM No CBI No PII Photographer: Dedriel Gardner Close up of labels on cans of paint materials shown in photo 78. PHOTO 80 BGW Warehouse #2 P1010080.JPG 12/12/2023 03:17 PM No CBI No PII Photographer: Dedriel Gardner Close up of labels on cans of paint materials shown in photo 78. 40 of 49 Brownsville Gulfside Warehouse Inc., Brownsville, TX - TXR000076653 Inspection Date(s): 12/12/2023 PHOTO 81 BGW Warehouse #2 P1010081.JPG 12/12/2023 03:18 PM No CBI No PII Photographer: Dedriel Gardner Close up of labels on cans of paint materials shown in photo 78. The Pecan color paint can had been opened. PHOTO 82 BGW Warehouse #2 P1010082.JPG 12/12/2023 03:19 PM No CBI No PII Photographer: Dedriel Gardner Close up of open can of paint materials that hardened shown in photo 83. 41 of 49 Brownsville Gulfside Warehouse Inc., Brownsville, TX - TXR000076653 Inspection Date(s): 12/12/2023 PHOTO 83 BGW Warehouse #2 P1010083.JPG 12/12/2023 03:20 PM No CBI No PII Photographer: Dedriel Gardner Open can of paint materials that hardened. Labeled as water base. PHOTO 84 BGW Warehouse #2 P1010084.JPG 12/12/2023 03:21 PM No CBI No PII Photographer: Dedriel Gardner Close up of open can of paint materials that hardened shown in photo 83. 42 of 49 Brownsville Gulfside Warehouse Inc., Brownsville, TX - TXR000076653 Inspection Date(s): 12/12/2023 PHOTO 85 BGW Warehouse #2 P1010085.JPG 12/12/2023 03:22 PM No CBI No PII Photographer: Dedriel Gardner Apparent paint related materials including approximately 1-cubic yard boxes labeled "FLAMMABLE." Boxes held "pens" of automobile paint. PHOTO 86 BGW Warehouse #2 P1010086.JPG 12/12/2023 03:23 PM No CBI No PII Photographer: Dedriel Gardner Apparent paint related material being stored. Orange labels say "Marking Restriction. Must be Relabeled." 43 of 49 Brownsville Gulfside Warehouse Inc., Brownsville, TX - TXR000076653 Inspection Date(s): 12/12/2023 PHOTO 87 BGW Warehouse #2 P1010087.JPG 12/12/2023 03:24 PM No CBI No PII Photographer: Dedriel Gardner Close up of the approximately 1-cubic yard boxes labeled "FLAMMABLE" shown in photo 85. Boxes held "pens" of automobile paint. PHOTO 88 BGW Warehouse #2 P1010088.JPG 12/12/2023 03:24 PM No CBI No PII Photographer: Dedriel Gardner Close up of the approximately 1-cubic yard boxes labeled "FLAMMABLE" shown in photo 85. Boxes held "pens" of automobile paint. 44 of 49 Brownsville Gulfside Warehouse Inc., Brownsville, TX - TXR000076653 Inspection Date(s): 12/12/2023 PHOTO 89 BGW Warehouse #2 P1010089.JPG 12/12/2023 03:24 PM No CBI No PII Photographer: Dedriel Gardner Close up of the approximately 1-cubic yard boxes labeled "FLAMMABLE" shown in photo 90. Boxes held "pens" of automobile paint. PHOTO 90 BGW Warehouse #2 P1010090.JPG 12/12/2023 03:24 PM No CBI No PII Photographer: Dedriel Gardner Approximately 1-cubic yard boxes labeled "FLAMMABLE" shown in photo 85. Boxes held "pens" of automobile paint. 45 of 49 Brownsville Gulfside Warehouse Inc., Brownsville, TX - TXR000076653 Inspection Date(s): 12/12/2023 PHOTO 91 BGW Warehouse #2 P1010091.JPG 12/12/2023 03:25 PM No CBI No PII Photographer: Dedriel Gardner Close up of the approximately 1-cubic yard boxes labeled "FLAMMABLE" shown in photo 92. Boxes held "pens" of automobile paint. PHOTO 92 BGW Warehouse #2 P1010092.JPG 12/12/2023 03:25 PM No CBI No PII Photographer: Dedriel Gardner Approximately 1-cubic yard boxes labeled "FLAMMABLE". Boxes held "pens" of automobile paint. 46 of 49 Brownsville Gulfside Warehouse Inc., Brownsville, TX - TXR000076653 Inspection Date(s): 12/12/2023 PHOTO 93 BGW Warehouse #2 P1010093.JPG 12/12/2023 03:25 PM No CBI No PII Photographer: Dedriel Gardner Close up of the approximately 1-cubic yard boxes labeled "FLAMMABLE" shown in photo 92. Boxes held "pens" of automobile paint. PHOTO 94 BGW Warehouse #2 P1010094.JPG 12/12/2023 03:26 PM No CBI No PII Photographer: Dedriel Gardner Apparent paint related material including approximately 1-cubic yard boxes of automobile paint "pens". 47 of 49 Brownsville Gulfside Warehouse Inc., Brownsville, TX - TXR000076653 Inspection Date(s): 12/12/2023 PHOTO 95 BGW Warehouse #2 P1010095.JPG 12/12/2023 03:26 PM No CBI No PII Photographer: Dedriel Gardner Apparent paint related material including approximately 1-cubic yard boxes labeled "FLAMMABLE." Boxes held "pens" of automobile paint. PHOTO 96 BGW Warehouse #2 P1010096.JPG 12/12/2023 03:26 PM No CBI No PII Photographer: Dedriel Gardner 1-cubic yard box with handwritten "DON'T DOUBLE STACK" sitting on floor. 48 of 49 Brownsville Gulfside Warehouse Inc., Brownsville, TX - TXR000076653 Inspection Date(s): 12/12/2023 PHOTO 97 BGW Warehouse #3 P1010097.JPG 12/12/2023 03:35 PM No CBI No PII Photographer: Dedriel Gardner Overall view of blue drums in south part of warehouse 3 with "Use before" date 4/14/2019. PHOTO 98 BGW Warehouse #3 12/12/2023 03:35 PM No CBI No PII Super sacks of cement in front of warehouse 3 north door. P1010098.JPG Photographer: Dedriel Gardner 49 of 49 12-12-23 Inspection Report APPENDIX 2 - 12/13/2023 BGW Email with Contact Names for GBD and Company in Mexico From: To: Subject: Date: Attachments: Raquel Sarquis Gardner, Dedriel Contact info. Wednesday, December 13, 2023 8:52:00 AM image001.png Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open attachments or click on provided links. Good morning Dedriel, Please find below contact information for the paint are storing. Contact: Mike CBD-International Inc. New Braunswick NJ 08901 Sr. Paco Martinez Calle 12 #900A Laguna Santa Maria Esquina Colonia Ind H. Matamoros Tamaulipas Thank you, Rachel Sarquis Logistics Coordinator BROWNSVILLE GULFSIDE WAREHOUSE 400 R.L. OSTOS RD Brownsville Tx 78521 Telephone - 956 831-4241 www.brownsvillegulfside.com