Document Z88pOER0ELenaX50wkx4RQq7V

VIA Electronic Mail: c.henry@stolt.com January 23, 2024 Corrie Henry EHS Supervisor Stolt-Nielsen, Inc. 16300 De Zavalla Road, Building 7 Channelview, TX 77530 Re: Stolt Barging Services Resource Conservation and Recovery Act Notice of Potential Violation and Opportunity to Confer Dear Mr. Henry: Hazardous waste that is improperly managed poses a serious threat to human health and the environment. Through implementation of the authorities in the Resource Conservation and Recovery Act (RCRA), 42 U.S.C. 6901 - 6992k, the United States Environmental Protection Agency regulates the control of hazardous waste from the "cradle-to-grave." This includes the generation, transportation, treatment, storage and disposal of hazardous waste. On August 24, 2023, the EPA, Region 6 conducted an inspection at Stolt-Nielsen, Inc.'s Stolt Barging Services facility in Channelview, Texas. The purpose of the inspection/investigation was to determine compliance with the requirements of RCRA and the implementing regulations. Information currently available to the EPA suggests potential violations of RCRA. By this letter, the EPA is extending an opportunity to advise the Agency via a conference call, or in writing, of any further information the EPA should consider with respect to the following potential violations of the RCRA and the implementing regulations: Central Accumulation Area - Failure to properly close the containers holding hazardous waste during accumulation pursuant to 40 CFR 262.17(a)(1)(iv)(A). Labelling and Marking of Containers - Failure to label containers with words "Hazardous Waste", indication of the hazards of the contents, and start date of accumulation, pursuant to 40 CFR 262.17(a)(5)(i). Weekly Inspection - Failure to provide inspection records of Central Accumulation Area pursuant of 40 CFR 262.17(a)(1)(v). 1 of 3 If you are interested in participating in an opportunity to confer with the Agency with respect to the above listed potential violations, please contact Nathan Taylor, with the Office of Regional Counsel, within seven calendar days of receipt of this letter at taylor.nathan@epa.gov or 214-665-3128. Thank you for your attention to this matter. If you have any questions, please contact Nathan Taylor (taylor.nathan@epa.gov; 214-665-3128) or Sandesh Thapa (thapa.sandesh@epa.gov; 214-665-2265). Sincerely, Digitally signed by Yurk, Jeff Date: 2024.01.23 Yurk, Jeff 07:29:34 -06'00' Jeff Yurk, Manager Waste Enforcement Branch Enclosure: Additional Sources of Information cc: madelyn.flannagan@tceq.texas.gov john.shelton@tceq.texas.gov 2 of 3 ADDITIONAL SOURCES OF INFORMATION Information on RCRA and hazardous waste regulations https://www.epa.gov/rcra/resource-conservation-and-recovery-act-rcra-regulations RCRA Civil Penalty Policy https://www.epa.gov/enforcement/resource-conservation-and-recovery-act-rcra-civil-penaltypolicy Consolidated Rules of Practice Governing the Administrative Assessment of Civil Penalties, 40 C.F.R. Part 22 https://www.epa.gov/sites/production/files/2013-10/documents/final-crop-fr_1.pdf Small Business Fact Sheet www.epa.gov/compliance/small-business-resources-information-sheet 3 of 3