Document dQvrer85qOYgjg3zLmEQeENZR

Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 6 Enforcement Division INSPECTION REPORT 07/18/2024 10:20 AM (CT) Announced: No 07/18/2024 11:32 AM (CT) Access: Granted RCRA Focused Compliance Inspection (FCI) 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 United States Environmental Services LLC LAR000103013 4515 Paris Rd. Chalmette, LA 70043 Saint Bernard County N/A 562910 United States Environmental Services LLC operates as an environmental remediation facility. 29.9582, -89.9557 Additional Persons Participating in Inspection: Name Title Organization Dedriel Gardner Inspector EPA REGION 6 Joe Watson Contractor Eastern Research Group (ERG) Email Gardner.Dedriel@epa.gov Joe.Watson@erg.com Phone (281) 983-2133 (215) 891-6615 Lead Inspector: Vince Damiano Vincent Damiano ERG Digitally signed by Vincent Damiano Date: 2024.10.03 10:41:17 -04'00' Vince.Damiano@erg.com (703) 835-6281 Page 1 of 4 United States Environmental Services LLC Inspection Date: 07/18/2024 SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection The Port of New Orleans 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, 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 Name Vince Damiano Phone Email (703) 835-6281 Vince.Damiano@erg.com Opening Conf. Yes Closing Conf. Yes Joe Watson (215) 891-6615 Joe.Watson@erg.com Yes Yes Dedriel Gardner (281) 983-2133 Gardner.Dedriel@epa.gov Yes Yes Facility General Description Tenant/Area United States Environmental Services LLC Inspection Date 07/18/24 Process Description United States Environmental Services LLC (USES) operates as an environmental remediation facility. USES conducts chemical clean-ups, hydro blasting, degassing, hydro excavation, over the water clean-ups, and emergency remediations. USES does not maintain a MARPOL COA. Area of Concern Yes Page 2 of 4 United States Environmental Services LLC SECTION II - OBSERVATIONS Inspection Date: 07/18/2024 Tenant: United States Environmental Services LLC (USES) Section: 2.1 Date: 07/18/24, 10:20 AM Contains AOC: Yes Contains CBI: No Lead Inspector: Vince Damiano Attendees: David Blackwell (EHS Director), Dianna Barbe (Admin) USES is located in Chalmette, LA and operates as an environmental remediation facility. USES conducts chemical clean-ups, hydro blasting, degassing, hydro excavation, over the water clean-ups, and emergency remediations. USES will haul waste from clean-up jobs to a disposal facility or back to the customer; they are registered with the EPA as a hazardous waste transporter of hazardous waste (LAR000103013). Mr. Blackwell explained USES also supports the U.S. Coast Guard in inspections of boats or equipment and assists in over the water clean-ups of releases. Mr. Blackwell stated this USES facility does not generate RCRA-regulated waste and does not maintain a MARPOL COA as it is not on the water. Following the opening conference, the inspection team conducted a visual inspection of USES's maintenance and storage areas. The inspection team first observed eight 55-gallon drums and five 5-gallon containers in the back corner of the storage garage all ranging from full to about half-full of contents (see Appendix 1 - Photos 1 and 2). The inspection team asked Mr. Blackwell if these were waste or products as they did not contain any labels. Mr. Blackwell said he was unsure and would have to follow up. The inspection team requested waste determinations on the 55-gallon drums and 5-gallon containers [AOC #1 - USES did not make a hazardous waste determination. - 40 CFR 262.11]. Next, the inspection team observed three 55-gallon drums used for storing used oil (see Appendix 1 - Photo 3). One of the drums was empty but the other two were approximately half-full of used oil. The drums did not contain a label or indication they were storing used oil [AOC #2 - USES did not clearly label containers used to store used oil with the words "Used Oil" - 40 CFR 279.22(c)(1)]. The inspection team then observed USES's yard space where trailers, CONEX boxes, and equipment are stored. The inspection team observed a metal storage container approximately 200 gallons in volume. The box was mostly empty with residual rainwater and the facility said they no longer use the box and are getting rid of it. Next, the inspection team observed a 55-gallon drum about full of material (see Appendix 1 - Photo 4). The drum did not contain a label and the facility were unsure of the contents but thought it is most likely rainwater. The inspection team requested a waste determination (See AOC #1). The inspection team also observed three lead-acid batteries on the floor of the storage garage, but following the inspection Mr. Blackwell stated these were not waste and have been charged (see Appendix 1 - Photo 5). The inspection team did not observe other areas of concern 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 11:30 AM with USES. The AOCs were communicated during the closing. Following the inspection, Mr. Blackwell followed up with the inspection team with an email stating: 1. Photographs of the used oil drums labeled as emptied before being crushed and disposed of. 2. Photographs of undetermined 55-gallon drums and 5-gallons containers (Appendix 1 - Photos 1 and 2) removed off site. A hazardous waste determination was not included in the follow-up containers in Photos 1 and 2. Page 3 of 4 United States Environmental Services LLC Inspection Date: 07/18/2024 3. The batteries observed during the inspection were charged and put back into their boat. 4. Oil drums (Appendix 1 - Photo 3) that were not labeled were vacuumed out and removed off site. 5. The metal storage box with rainwater was vacuumed and removed off site. 6. Documentation from Crystal Clean showing oil drums (discussed in #4 above) were determined to be non-regulated used oil. 7. Shipping manifests where USES acted as a transporter from the last year from emergency responses; all manifests showed shipments of non-regulated or non-hazardous materials. See Appendix 2. 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. Tenant: USES AOC #1 - USES did not make a hazardous waste determination. Citation: 40 CFR 262.11 Section: 2.1 AOC #2 - USES did not clearly label containers used to Citation: 40 CFR 279.22(c)(1) store used oil with the words "Used Oil" Section: 2.1 SECTION V - FOLLOW UP 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. Communication Log During and after the inspection, additional information was emailed to EPA including: 1. 08/19/24 USES email - David Blackwell sent a follow-up email responding to AOCs, transporter manifests, photos of labeled used oil, and used oil disposal receipts. SECTION VI - LIST OF APPENDICES Appendix 1. Photograph Log Appendix 2. USES 08/19/24 Response Page 4 of 4 APPENDIX 1. PHOTOGRAPH LOG UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: USES City: Chalmette Photo No. 1 County/Parish: Saint Bernard State: Louisiana Photo File Name: DSCN6724 Date of Photo: 07/18/2024 Time of Photo: 11:07 hrs. Photographer: Vince Damiano Description: View of several drums and containers inside storage garage for which a waste determination was requested. Location: USES City: Chalmette UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 County/Parish: Saint Bernard State: Louisiana Photo File Name: DSCN6725 Date of Photo: 07/18/2024 Time of Photo: 11:07 hrs. Photographer: Vince Damiano Description: View of several drums and containers inside storage garage for which a waste determination was requested. Location: USES City: Chalmette UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 County/Parish: Saint Bernard State: Louisiana Photo File Name: DSCN6726 Date of Photo: 07/18/2024 Time of Photo: 11:08 hrs. Photographer: Vince Damiano Description: View of two unlabeled used oil drums inside storage garage approximately half-full; one of the drums was empty. Location: USES City: Chalmette UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 County/Parish: Saint Bernard State: Louisiana Photo File Name: DSCN6727 Date of Photo: 07/18/2024 Time of Photo: 11:13 hrs. Photographer: Vince Damiano Description: View of 55-gallon drum in the yard space with unknown contents at the time of the inspection. Location: USES City: Chalmette UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 County/Parish: Saint Bernard State: Louisiana Photo File Name: DSCN6728 Date of Photo: 07/18/2024 Time of Photo: 11:16 hrs. Photographer: Vince Damiano Description: View of three lead-acid batteries inside storage garage which were determined to be useful. APPENDIX 2. USES 08/19/24 RESPONSE Appendix 2 Page 1 of 15 Appendix 2 Page 2 of 15 Appendix 2 Page 3 of 15 Appendix 2 Page 4 of 15 Appendix 2 Page 5 of 15 Appendix 2 Page 6 of 15 Appendix 2 Page 7 of 15 Appendix 2 Page 8 of 15 Appendix 2 Page 9 of 15 Appendix 2 Page 10 of 15 Appendix 2 Page 11 of 15 Appendix 2 Page 12 of 15 Appendix 2 Page 13 of 15 Appendix 2 Page 14 of 15 Appendix 2 Page 15 of 15