Document dYkJE0D6y1v4re71dBk0ReJRe

Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 6 Enforcement Division INSPECTION REPORT 04/18/2024 1:00 (CT) 04/18/2024 2:30 (CT) RCRA Focused Compliance Inspection (FCI) Announced: No 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 VLS Environmental Solutions LAR000088872 7951 Dock Board Rd Sulphur, LA 70665 Calcasieu Parish Large Quantity Generator (LQG) None VLS Environmental Solutions 30.061693, -93.355957 Additional Persons Participating in Inspection: Name Title Organization Elizabeth Pham Inspector EPA REGION 6 Sandesh Thapa Inspector EPA REGION 6 Anshul Paripati Contractor Eastern Research Group (ERG) Email Pham.elizabeth@epa.gov Thapa.sandesh@epa.gov Anshul.Paripati@erg.com Phone (214) 665-8354 (214) 665-2265 (571) 535-1503 Lead Inspector: Cameron Tanaka Cameron Tanaka Date: 2024.07.24 22:49:28 -04'00' Digitally signed by Cameron Tanaka ERG Cameron.Tanaka@erg.com 07/24/2024 (703) 633-1632 ext. 11632 Page 1 of 6 VLS Environmental Solutions Inspection Date(s): 04/18/2024 SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection Type of inspection: Focused Compliance Inspection (FCI) The Port of Lake Charles 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 Yes No ext. 11632 Anshul Paripati (571) 535-1503 Anshul.Paripati@erg.com Yes Yes Elizabeth Pham (214) 665-8354 Pham.elizabeth@epa.gov Yes Yes Sandesh Thapa (214) 665-2265 Thapa.sandesh@epa.gov Yes Yes Page 2 of 6 VLS Environmental Solutions Inspection Date(s): 04/18/2024 Facility General Description Tenant/Area VLS Environmental Solutions Inspection Date 04/18/24 Process Description VLS Environmental Solutions (VLS) provides barge cleaning, maintenance, and valve replacements, repairs, and greasing. Most of their hazardous and non-hazardous waste is generated from wash water from the barge tank cleaning. Most of their cleaning, however, is for petroleum product tanks and the wash waster from that is sent for reclamation and sold. They do not have a MARPOL certificate for this location. Area of Concern No Page 3 of 6 VLS Environmental Solutions Inspection Date(s): 04/18/2024 SECTION II - OBSERVATIONS - In order of inspection time. Tenant: VLS Environmental Solutions Section: 2.1 Date: 04/18/24, 1:00 PM Contains AOC: No Contains CBI: No Lead Inspector: Cameron Tanaka Attendees: Randy Brook (no role listed) and Kenny Trahan (Environmental Manager) VLS Environmental Solutions (VLS) performs barge cleaning, maintenance, valve replacements, small repairs, and greasing for vessels. VLS is a large quantity generator of hazardous waste with EPA ID LAR000088872. According to a hazardous waste manifest, RCRA regulated wastes that they generate includes D001, D002, and D018 waste. The inspection team did not note any issues with this manifest. Most of their hazardous and non-hazardous waste is generated from wash water from the barge tank cleaning. Most of their cleaning, however, is for petroleum product tanks. The wash water for those operations is sent for reclamation and sold. For hazardous wastes generated, these generally include wash water from barges containing materials such as styrene monomers or chlorinated solvents. For barge cleaning, they strip and remove heels and residuals from the barges then clean the tanks with water. Their vacuum trucks remove this wash water and pump it into totes or frac tanks in their logistics area. For every barge that they are requested to clean, they verify all the SDS's for the materials on the barge and take samples before they perform any stripping or heel removal. Generally, VLS can resell the heels that they strip off barges but if the sampling results indicate that they cannot, those heels will be handled as hazardous waste. VLS generates non-hazardous waste including rust scale, oily trash, and greasing wastes. The inspection team viewed a non-hazardous waste manifest and found no issues. Their hazardous and non-hazardous wash water wastes are sent to injection wells. Hazardous wash water waste is sent to Circon and Texas Molecular and non-hazardous wash water waste is sent to US Ecology in Pasadena, TX. Other hazardous wastes, such as material that cannot be resold and hazardous sludge, is sent to third-party locations including Circon, Clean Harbors, Veolia, Tradebe, and US Ecology. They do not transport these wastes themselves. VLS does not generate or transfer used oil on site. VLS does not remove any garbage, e-waste, or other wastes from the vessels they clean, and they do not have universal waste generated or stored on site. They do not have a MARPOL COA for this location. Logistics Area The inspection team then performed a walk-through of VLS's logistics area where waste is stored. A tote that was about a quarter full of oil to be reclaimed and resold was observed (see Appendix 1 - Photos 1). The team also observed three hazardous waste ethanol wash water totes dated 3/26/24 that were closed, properly labeled, and in good condition (see Appendix 1 - Photos 2 and 3). Two of the totes were full and one of them was about half full. No apparent AOCs were observed by the inspection team the time of the inspection. A closing conference was conducted at approximately 2:20 PM with VLS personnel. Page 4 of 6 VLS Environmental Solutions SECTION III - RECORDS REVIEW Inspection Date(s): 04/18/2024 No RCRA regulated records 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. VLS did not have any Areas of Concern. 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 areas of concern or provision of documents requested. Communication Log During and after the inspection, additional information from VLS was not requested. Page 5 of 6 VLS Environmental Solutions SECTION VI - LIST OF APPENDICES Appendix 1. Photograph Log Inspection Date(s): 04/18/2024 Page 6 of 6 APPENDIX 1. PHOTOGRAPH LOG UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: VLS Environmental Solutions City: Sulphur County/Parish: Calcasieu State: Louisiana Photo File Name: DSCN7200 Date of Photo: 04/18/2024 Time of Photo: 13:07 hrs. Photographer: Anshul Paripati Description: View of a tote containing oil to be reclaimed and resold in VLS' logistics area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: VLS Environmental Solutions City: Sulphur County/Parish: Calcasieu State: Louisiana Photo File Name: DSCN7201 Date of Photo: 04/18/2024 Time of Photo: 13:09 hrs. Photographer: Anshul Paripati Description: View of three hazardous waste ethanol wash water totes dated 3/26/24 in VLS' logistics area. Photo No. 3 Location: VLS Environmental Solutions City: Sulphur County/Parish: Calcasieu State: Louisiana Photo File Name: DSCN7202 Date of Photo: 04/18/2024 Time of Photo: 13:09 hrs. Photographer: Anshul Paripati Description: Closeup view of a label on one of the three hazardous waste ethanol wash water totes dated 3/26/24 in VLS' logistics area.