Document ZB03ELVXDYQRkO7d0OzGVwnqZ

Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 6 Enforcement Division INSPECTION REPORT 05/08/2024 2:45 PM (CT) 05/08/2024 4:45 PM (CT) RCRA Focused Compliance Inspection (FCI) Announced: No (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 PBI International N/A 1220 Miller Cut Off Rd La Porte, TX 77571 Harris None N/A PBI International is a transporter that owns a large truck fleet including vacuum trucks. The company moves materials to and from its clients' facilities. 29.706134, -95.066529 Additional Persons Participating in Inspection: Name Title Organization Dedriel Gardner Inspector EPA REGION 6 John Penland Inspector EPA REGION 6 Anshul Paripati Contractor Eastern Research Group (ERG) Email Gardner.Dedriel@epa.gov Penland.John@epa.gov Anshul.Paripati@erg.com Phone (281) 983-2133 (214) 665-9717 (571) 535-1503 Lead Inspector: Cameron Tanaka Cameron Tanaka Date: 2024.07.25 23:39:27 -04'00' Digitally signed by Cameron Tanaka ERG Cameron.Tanaka@erg.com 07/25/2024 (703) 633-1632 ext. 11632 Page 1 of 6 PBI International Inspection Date(s): 05/08/2024 SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection Type of inspection: Focused Compliance Inspection (FCI) The Port of Houston and surrounding facilities were selected for inspection based on an Environmental Justice and 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 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 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 RCRA Inspector/ Contractor/ERG Inspector/Enforcement Officer/EPA Region 6 Inspector/Enforcement Officer/EPA Region 6 Name Phone Email Opening Closing Conf. Conf. Cameron Tanaka (703) 633-1632 Cameron.Tanaka@erg.com N/A N/A ext. 11632 Anshul Paripati (571) 535-1503 Anshul.Paripati@erg.com N/A N/A Dedriel Gardner (281) 983-2133 Gardner.Dedriel@epa.gov N/A N/A John Penland (214) 665-9717 Penland.John@epa.gov N/A N/A Page 2 of 6 PBI International Inspection Date(s): 05/08/2024 Facility General Description Tenant/Area PBI International Inspection Date 05/08/24 Process Description PBI International (PBI) is a transporter at their other locations, but they do not accept waste on their site. They have tanker trucks that only come back to the site completely cleaned out. PBI does not have a MARPOL COA. Area of Concern Yes Page 3 of 6 PBI International Inspection Date(s): 05/08/2024 SECTION II - OBSERVATIONS Tenant: PBI International Section: 2.1 Date: 05/08/24, 2:45 PM Contains AOC: Yes Contains CBI: No Lead Inspector: Cameron Tanaka Attendees: Jordy Dumas (Safety Director) PBI is a transporter that owns a large truck fleet including vacuum trucks. The company moves materials to and from its clients' facilities. At PBI's facility on the Houston Ship Channel, all vacuum trucks and containers brought on site or stored on site are empty and clean. Mr. Dumas indicated that the facility does not have any waste on site. After transportation jobs are completed, PBI's trucks are taken to a third-party tank washer for servicing. This includes heel stripping and cleaning. PBI does not have a MARPOL COA. During the inspection, the inspection team observed PBI's yard. Observations and Areas of Concern (AOCs) are organized below along with facility responses where relevant. The inspection team viewed many empty drums and other containers scattered throughout the site. In the far back of the facility's property, the inspection team observed three roll-off boxes, two of which had faded hazardous waste stickers, that contained what appeared to be sandblast media (see Appendix 1 - Photos 1, 2, 3, and 4). PBI stated that the containers were left at their site by the company that owned the property before them [AOC #1 - PBI International must make an accurate determination as to whether the sandblast media in the roll-offs is a hazardous waste to ensure wastes are properly managed according to applicable RCRA regulations - 40 CFR 262.11]. The inspection team also observed that approximately 5000 square feet of sandblast media was covering a part of the ground of the site (see Appendix 1 - Photo 5). This material also did not have a waste determination [AOC #2 - PBI International must make an accurate determination as to whether the sandblast media on the ground is a hazardous waste to ensure wastes are properly managed according to applicable RCRA regulations - 40 CFR 262.11]. The inspection team did not observe other AOCs at the time of the inspection. A closing conference was conducted at approximately 4:30 PM with Mr. Dumas. The AOCs were communicated during the closing. On 06/27/2024, Jason Mungia with PBI responded that the company had collected samples and would develop a disposal plan based on the results (see Appendix 2). Page 4 of 6 PBI International Inspection Date(s): 05/08/2024 SECTION III - RECORDS REVIEW No RCRA regulated records were reviewed during this focused onsite inspection. SECTION IV - APPARENT AREAS OF CONCERN The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation. Tenant: PBI International AOC #1 - PBI International must make an accurate determination as to whether the sandblast media in the roll-offs is a hazardous waste to ensure wastes are properly managed according to applicable RCRA regulations. Citation: 40 CFR 262.11 Section: 2.1 AOC #2 - PBI International must make an accurate Citation: 40 CFR 262.11 determination as to whether the sandblast media on the ground is a hazardous waste to ensure wastes are properly managed according to applicable RCRA regulations. Section: 2.1 SECTION V - FOLLOW UP Follow-Up Any facility follow-up items are as discussed in each facility's observations in Section II. Documents or files provided by the facilities were transmitted via email and included responses to AOCs or provision of documents requested. Communication Log During and after the inspection, additional information was emailed to EPA including: 1. 06/27/24 PBI International email - Jason Mungia sent an email describing corrective action performed for the lack of waste determinations at their site. Page 5 of 6 PBI International SECTION VI - LIST OF APPENDICES Appendix 1. Photograph Log Appendix 2. Follow-Up Email from PBI International Inspection Date(s): 05/08/2024 Page 6 of 6 APPENDIX 1. PHOTOGRAPH LOG UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: PBI International City: La Porte Photo No. 1 County/Parish: Harris State: Texas Photo Name: DSC04177 Date of Photo: 05.08.2024 Time of Photo: 15:40 hrs Photographer: Anshul Paripati Description: Overview of three roll off containers onsite dating back to 8.11.2023. The containers are believed to be from the previous owners. All three containers had what appeared to be sandblast media and two of them had faded hazardous waste labels. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: PBI International City: La Porte Photo No. 2 County/Parish: Harris State: Texas Photo Name: DSC04178 Date of Photo: 05.08.2024 Time of Photo: 15:40 hrs Photographer: Anshul Paripati Description: Close up of the label on the red roll off container shown in photo 41. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: PBI International City: La Porte Photo No. 3 County/Parish: Harris State: Texas Photo Name: DSC04179 Date of Photo: 05.08.2024 Time of Photo: 15:40 hrs Photographer: Anshul Paripati Description: Close up of the label on the furthest right brown roll off container shown in picture 41. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: PBI International City: La Porte Photo No. 4 County/Parish: Harris State: Texas Photo Name: DSC04182 Date of Photo: 05.08.2024 Time of Photo: 15:40 hrs Photographer: Anshul Paripati Description: Close up of the label on the middle brown roll off container shown in picture 41. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: PBI International City: La Porte Photo No. 5 County/Parish: Harris State: Texas Photo Name: DSC04183 Date of Photo: 05.08.2024 Time of Photo: 15:45 hrs Photographer: Anshul Paripati Description: Overview of the area covered with sandblast media. APPENDIX 2. FOLLOW-UP EMAIL FROM PBI INTERNATIONAL Appendix 2 Page 1 of 1