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Click or tap here to enter text. Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection 08/19/2024 09:25 AM (CT) 08/20/2024 02:20 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 Matthew Environmental Texas Commission on Briseo - Investigator Environmental Quality (TCEQ), 8/19/24 only Region 15 - Harlingen Sebastian J. Intern Reyna - 8/19/24 only Texas Commission on Environmental Quality (TCEQ), Region 15 - Harlingen Email Phone Matthew.Briseno@tceq.texas.gov (956) 430-6037 Sebastian.Reyna@tceq.texas.gov (956) 430-6031 Lead Inspector: Dedriel Gardner EPA REGION 6 Gardner.Dedriel@epa.gov Supervisor Review: Debra Pandak DEBRA PANDAK Date: 2024.11.01 14:42:06 -05'00' Digitally signed by DEBRA PANDAK EPA REGION 6 Pandak.debra@epa.gov 1 of 8 Brownsville Gulfside Warehouse, Inc. Inspection Date(s): 8/19-20/2024 Click or tap here to enter text. SECTION I - INTRODUCTION Background / Purpose of the Inspection Type of inspection: Follow up Compliance Evaluation Inspection Background - On September 28, 2023, EPA conducted a focused RCRA inspection at the Port of Brownsville (POB) and its tenants. It included the tenant, Brownsville Gulfside Warehouse, Inc. (BGW), located at 400 RL Ostos Road. During the September 28, 2023, inspection, EPA observed numerous containers of apparent paint related materials being stored onsite in a waste like manner. BGW provided no documentation on whether the materials was a solid waste or hazardous waste. Therefore, EPA conducted a follow-up inspection on December 12, 2023, and many of the containers remained. EPA contacted BGW on June 24, 2024, by phone and BGW stated that all the materials had been removed and they would provide documentation, however EPA did not receive this information. At EPA's request, TCEQ conducted a follow-up inspection on August 7, 2024, and materials either remained onsite in the process of being removed or had been moved to a different warehouse located inside the POB (Warehouse #14). On August 13, 2024, EPA sent Mr. Elizondo, BGW, and POB an email requesting that no additional materials be removed from the BGW or POB until EPA is provided with clear, concise analytical data or process knowledge documentation that makes an accurate determination as to whether the material is solid waste or hazardous waste. Purpose - On August 19-20, 2024, I, Dedriel Gardner, conducted an unannounced inspection of the BGW facility for compliance with the Resource Conservation and Recovery Act (RCRA). Ramiro Yanez, Foreman, acted as the BGW facility representative. I informed him that the inspection would be conducted under the authority of 3007 RCRA and I would be evaluating the paint related materials EPA observed onsite during the previous two inspections. I discussed EPA Region 6's Confidentiality Notice (40 CFR Section 2.203) for any, potential Business Confidentiality Information claims by BGW and provided him with the confidential business information (CBI) form, CBI related Questions and Answers (Q&As), and Small Business Resources Information Sheet (SBRIS). BGW did not make any confidential business claims at the conclusion of the inspection. Also, Juis Luiz Elizondo, owner of Pintura Que Padre, Matamoros Tamaulipas Mxico, joined the inspection on August 20, 2024, as he is the owner of the materials in question being stored at BGW and Warehouse #14. He was also informed of the same 3007 inspection authority, confidentiality notice/forms, and SBRIS. He was interviewed at both BGW and Warehouse #14. Mr. Yanez was also present throughout this interview at BGW but did not go to Warehouse #14 with me and Mr. Elizondo. This report is based on information supplied by Mr. Yanez, Mr. Elizondo, 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. Also, 118 photographs were taken during the inspection to document onsite observations. A subset of the photographs is used that best present the observation. A map of all 118 Photograph locations and direction taken is included in Appendix 1. 2 of 8 Brownsville Gulfside Warehouse, Inc. Inspection Date(s): 8/19-20/2024 Click or tap here to enter text. 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 Matthew Briseo - 8/19/24 only Intern/Texas Commission on Environmental Quality (TCEQ), Region 15 Harlingen Sebastian J. Reyna - 8/19/24 only Foreman/BGW Ramiro Yanez Supervisor/BGW Belinda Vazquez- closing conference only Owner/ Pintura que padre, Matamoros Tamaulipas Mxico Jos Luis Elizondo - 8/20/24 only (913) 5517049 (956) 4306037 (956) 4306031 (956) 4668521 (956) 8314241 Email Gardner.Dedriel@epa.gov Opening Closing Conf. Conf. Yes Yes Matthew Briseo@tceq.texas.gov Yes No Sebastian.Reyna@tceq.texas.gov Yes No egutierrez@brownsvillegulfside.com Yes No bvazquez@brownsvillegulfside.com No Yes No personal email. No for BGW/ Yes for self No for BGW/ Yes for self SECTION II - OPENING CONFERENCE/OBSERVATIONS This inspection report describes the inspection conducted on August 19-20, 2024. This inspection concentrated on the status of the paint related materials (including latex and oil-based paints, epoxy parts, thinners, cleaners, paint samples, home repair materials such as wallpaper adhesives, caulking, putty, etc.) that EPA observed during previous inspections and where these materials were being shipped. The focus was mostly on the materials that appeared to contain hazardous constituents and/or properties. On August 19, 2024, I arrived at BGW at about 9:25 A.M. and was told that Belinda Vazquez, Supervisor, was busy, and Ramiro Yanez, Foreman, will be escorting me during the inspection. Matthew Briseo (TCEQ) and Sebastian J. Reyna (TCEQ), arrived soon after. Mr. Yanez arrived about 9:55 A.M. and acted as the facility representative. Mr. Yanez has worked for BGW over 35 years and POB over 50 years. Mr. Yanez spoke Spanish and Messrs. Briseo and Reyna acted as his interpreter on August 19, 2024 (Messrs. Briseo and Reyna did not attend on August 20, 2024). On August 20, 2024, Mr. Elizondo joined the inspection. I communicated with Mr. Yanez and Mr. Elizondo using EPA's Translation International services over the phone throughout the inspection. I conducted an interview with Mr. Elizondo both at BGW and Warehouse #14. 3 of 8 Brownsville Gulfside Warehouse, Inc. Inspection Date(s): 8/19-20/2024 Click or tap here to enter text. A summary of the inspection and interviews follows: (1). Mr. Yanez's statements regarding materials remaining onsite and other BGW operated warehouses - Mr. Yanez stated that BGW only has three warehouse facilities at the POB and none located offsite. The paint related materials that EPA observed stored in a waste like manner were located only at the main warehouse at 400 RL Ostos Road in Warehouses #1, #2, and #3. Mr. Yanez stated the following regarding the materials stored in Warehouses #1, #2, and #3. Please note that all accessible containers shown in photos were partially full to full. a. Warehouse #1 - During the September 28, 2023, inspection, the EPA observed approximately 164 pallets of various size containers of apparently waste-like materials being stored. During the December 12, 2023, inspection it appeared that about a third to a half of the materials had been removed. Currently, it appeared that about three-quarters of the materials have been removed. The containers I observed remaining included containers that were unlabeled, and others labeled as stated in the previous inspection reports and shown in Appendix 1, Photos 1 thru 44. See the Warehouse #1 facility layout with the current and past photo locations in Appendix 1. i. Also, I observed the same two full unlabeled approximately 5-gallon plastic jugs that had a solvent type of odor during the December 12, 2023, inspection (see Appendix 1, Photo 38). Mr. Yanez stated that they came over with the electrical box stored next to them and he did not know what they were. [AOC #1a-BGW: Failure to make a hazardous waste determination on the two unknown 5-gallon plastic jugs - 40 CFR 262.11.] However, after the inspection in a September 6, 2024, email, Ms. Vazquez stated that these containers belonged to Mr. Elizondo, and Mr. Elizondo had removed them (see (4) below for management of materials Mr. Elizondo removed). ii. During the December 12, 2023, inspection, I observed spilled paint pens on the ground on the south side of Warehouse #1. Mr. Yanez had stated then that a pallet was being loaded onto a truck for transport to Mexico and was damaged by the forklift causing the pens to spill onto the ground. He planned to pick them up, store them at BGW while he tries to sell them. As of August 2024, about 40 remained in a small box inside Warehouse #1 and some on the ground in an area of about 10 ft x 20 ft as shown in Appendix 1, Photos 40 - 44, 99 and 100. [AOC #1b-BGW: Failure to make a hazardous waste determination on the remaining paint pens and spill area - 40 CFR 262.11.] However, after the inspection in a September 6, 2024, email, Ms. Vazquez stated that the paint pens observed were removed by Mr. Elizondo, which were bagged and picked up by him (see (4) below for management of materials Mr. Elizondo removed). b. Warehouse #2 - During the previous September 28, 2023, inspection, the EPA observed over 220 containers of various sizes. During the December 12, 2023, inspection, it appeared that about half of the materials had been removed. As of August 2024, it appeared that about three-quarters of the materials have 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 Appendix 1, Photos 45 - 85 and 91 - 98. See the Warehouse #2 facility layout with the current and past photo locations in Appendix 1. c. Warehouse #3 - During the previous September 28, 2023, inspection, the EPA observed over 750 containers of waste-like materials being stored. During the December 12, 2023, inspection, none of the materials observed during the previous inspection had been removed. This was according to Mr. Yanez as I was not able to see completely into the warehouse as supersacks of cement were blocking the doors. As of August 2024, there remained limited access to this warehouse. Mr. Yanez stated all the materials had been removed. However, I observed most of the containers remained as shown in Appendix 1, 4 of 8 Brownsville Gulfside Warehouse, Inc. Inspection Date(s): 8/19-20/2024 Click or tap here to enter text. Photos 101 - 107. See the Warehouse #3 facility layout with the current and past photo locations in Appendix 1. (2). Mr. Yanez's statements regarding Mr. Elizondo operations - Mr. Yanez stated the following regarding Mr. Elizondo (the owner of the above material stored in Warehouses #1, #2, and #3) operations. a. Mr. Elizondo is having problems moving the material to Mexico because the tax rate to cross the border has recently increased. b. Mr. Elizondo has not paid rent in over a year. c. Mr. Elizondo is making arrangements to move the materials. d. BGW is not pushing Mr. Elizondo too hard as he is moving the materials himself. e. There is no third party doing the transportation due to Mr. Elizondo's financial problems. He is doing all the moving himself, although the trailer is currently broken down. Therefore, no materials are currently being moved. f. BGW's responsibility is to load/unload the materials, although Mr. Yanez feels that they are responsible for the storage of it while it is on their site. g. The materials removed from Warehouse #1 went directly from the warehouse to Mexico. h. The materials removed from Warehouses #2 and #3 went from the two warehouses to Warehouse #14 then to Mexico (see (4) below for discussion regarding Warehouse #14). i. The materials remaining onsite, as of August 2024, are what is left after they removed the "big stuff" (i.e., the totes). (3). Mr. Yanez's statements regarding materials removed offsite - Mr. Yanez provided three shipping related documents to me during the August 19-20th inspection, and one to the TCEQ inspector during the August 7, 2024, inspection. a. Mr. Yanez provided me three BGW Report of Freight: Loading/Unloading forms (see Appendix 2). One was dated August 12, 2024, and two dated August 13, 2024. He stated they were the latest. He stated that since the EPA's December 12, 2023, inspection, they only have these three shipping documents plus the one they provided the TCEQ inspector during the August 7, 2024, inspection. The shipping documents were for materials removed from Warehouse #2 and sent to Warehouse #14. However, two of the three documents stated that the materials came from Warehouse #5. Mr. Yanez stated that this was a mistake as none of the materials have ever been stored in Warehouse #5. See Appendix 1, Photos 109 - 111 for materials currently stored in Warehouse #5 which included no apparent paint related materials. b. The one shipping document he provided to the TCEQ inspector (Mr. Briseo) was dated August 5, 2024, and was for material removed from Warehouse #1 and shipped to Warehouse #14. (4). Mr. Elizondo's interview regarding the materials stored at BGW and shipped offsite - During the interview with Mr. Elizondo at both BGW and Warehouse #14, Mr. Elizondo stated the following: a. He purchased the materials from GDB International (GDB) to sell (see the previous December 12, 2023, inspection report for additional information regarding GDB. b. He knows they can use all the materials, including the unlabeled containers, because he knows they are paints/paint related. c. He has been taking some of the materials from the BGW and he believes only about 20 percent total remains onsite. d. Currently, the materials are taken to Warehouse #14 to be labeled and permitted for shipment to Mexico. Warehouse #14 is located near the intersection of E 14th Street and Industrial Drive, Brownsville, Texas (address 125 Industrial Drive, Brownsville, TX 78521) (see Appendix 3 for aerial map). 5 of 8 Brownsville Gulfside Warehouse, Inc. Inspection Date(s): 8/19-20/2024 Click or tap here to enter text. e. In Mexico, he sells the paint to people to paint, including homes and schools. f. He is owner of Pinturas Que Padre (PQP) located in Mexico. The "PQP" I observed painted on some of the shrink wrapped pallets is to note that it is for his company. g. He has a transporter shipping the materials to Mexico. His name is Francisco Martinez. h. None of the materials have been sent to any American company, including to his son's paint business located in Brownsville, Texas. It was all sent to Mexico for use. i. He does not have an inventory of the materials being stored at BGW or Warehouse #14. j. They do not have any paperwork at Warehouse #14. The transporter would have the shipping related paperwork. i. No documentation was available during the inspection or had been provided to show that the materials from BGW or Warehouse #14 were being shipped to Mexico for use. [AOC #1-Mr. Elizondo: No documentation as required to demonstrate that materials stored in Warehouses #1, #2, and #3 (see (1) above) are not a solid waste - 40 CFR 261.2(f).] However, after the inspection, Mr. Elizondo provided shipping documents showing paint related materials were being shipped to Mexico (see Section IV Follow Up). k. He said the best way to communicate with him is using hardcopy mail in Spanish or via telephone with an interpreter. EPA can call and leave a message for him to return, or the best time to reach him is after 7:30 P.M. i. He did not have an email address and did not receive an email from EPA. (However, after the inspection EPA learned that he is able to use someone else's email address to communicate). ii. He stated that Mr. Yanez is currently telling him that he must get all this material off their site. l. He will need time to get all the materials shipped to Mexico. At the time of the inspection, the trailer is broken down, therefore no materials are being removed from BGW. m. At Warehouse #14, I observed 14 pallets of paint related materials consisting of 12 totes, one pallet of 1-gallon cans, and one pallet of 1-pint cans as shown in Appendix 1, Photos 112 - 117. Mr. Elizondo stated the following regarding this material: i. The paint related materials are waiting to be shipped to Mexico. ii. These paint materials were moved from BGW about a couple of weeks ago. They consist of the items noted on the three loading/shipping related papers Mr. Yanez provided to me during this inspection (Appendix 2). iii. They clean up the container labels and sell the paints. iv. What he cannot sell, he discards. v. A total of 14 totes were waiting to be loaded onto a trailer and shipped to Mexico at the time of the inspection. They had no paperwork available for the paints on this shipment leaving. However, after the inspection, Mr. Elizondo provided shipping documents showing paint related materials were being shipped to Mexico (see Section IV Follow Up). vi. In Mexico, any latex paint that has hardened as seen in Appendix 1, Photos 116 and 117 is ground up and then he finds someone to properly dispose of it. vii. In Mexico, the oil-based paints usually do not harden. However, if they do, thinner and/or water is added, and he is able to sell the paint. n. Warehouse #14 is shared by other companies including Solar Supply (air conditioning contractor) and BYM Import (importer) (see Appendix 3 for aerial map). 6 of 8 Brownsville Gulfside Warehouse, Inc. Inspection Date(s): 8/19-20/2024 Click or tap here to enter text. SECTION III - CLOSING CONFERENCE AND FOLLOW UP Closing Conference On August 20, 2024, after completing the inspection at Warehouse #14, I closed out the interview with Mr. Elizondo. He lost his SBRIS document during the inspection and asked for another copy in Spanish. I told him I would send him another copy after the inspection in Spanish if we had it. I informed Mr. Elizondo that EPA will be sending him an email regarding not moving the materials until we get clear information on whether the material is a solid or hazardous waste, and a letter asking additional information regarding the materials. I left Warehouse #14 at approximately 1:55 P.M. and returned to BGW to conduct the BGW closing conference. On August 21, 2024, I verified with Mr. Elizondo that he was not making any CBI claims. At the BGW I closed out the BGW inspection with Belinda Vazquez as Mr. Yanez was not available at the time. I asked if they had received an email from EPA regarding not to remove the materials from the warehouse until EPA has clear information that the materials are not solid/hazardous waste. Ms. Vazquez stated that she got the email. I informed her that they would be getting a letter from EPA asking more questions regarding the materials. She made copies of the shipping related documents Mr. Yanez provided me during the inspection. I asked if any information I received was confidential business and she stated no. I left the facility at about 2:30 P.M. Follow Up During this inspection and the TCEQ August 2024 inspection, BGW provided EPA and TCEQ with a total of four shipping documents showing paint related materials being shipped from BGW to Warehouse #14 (see (3) above). Mr. Elizondo stated that all the paint related materials we observed were not waste and will be sent to Warehouse #14 prior to Mexico for use (see Appendix 4, for the August 30, 2024, translated email stating the materials will be sold). On August 27, 2024, Mr. Elizondo provided additional information including Safety Data Sheets (SDS) he obtained from the company he purchased the materials from (GBD International) and shipping documents from his Importer/transporter, Francisco Martinez (see Appendix 4) to show that the materials were being shipped to Mexico. Papers appeared to show that paint related materials were being shipped along with other materials to Mexico. In a September 6, 2024 email, BGW (Ms. Vazquez) informed EPA of the following: all the materials EPA observed onsite in Warehouses #1, #2, and #3 were removed on August 19, 2024, thru September 3, 2024; materials were hauled away by Mr. Jose Luis Elizondo; BGW cannot provide any shipping information because transportation was not handled by BGW; and they were taken to Warehouse #14 (see Appendix 5). In a September 25, 2024, phone call, Mr. Elizondo stated, through an interpreter, that all the materials were removed from BGW. However, he stated the following: BGW (Ramiro Yanez, the Foreman) "sponsored" Salinas Transportation, located in Brownsville, Texas, to move the materials from BGW to the Salinas Transportation yard; when Mr. Elizondo has space in Mexico to receive more materials, he will let Mr. Yanez know, who will then arrange for more to be shipped to Warehouse #14 for shipment to Mexico. Mr. Elizondo said he would provide the shipping papers he has, but Mr. Yanez would have to provide the documents as he arranged the shipment with Salinas Transportation. Mr. Elizondo stated that 7 of 8 Brownsville Gulfside Warehouse, Inc. Inspection Date(s): 8/19-20/2024 Click or tap here to enter text. as of September 25, 2024, the materials remaining in the U.S. are located partly at the Salinas Transportation facility and Warehouse #14 prior to being shipped to Mexico. On September 27, 2024, Mr. Elizondo provided additional shipping papers of materials that have been shipped to Mexico (see Appendix 4). The shipping documents were provided in Spanish and did not appear to list Mr. Elizondo's name or company address. However, Mr. Elizondo stated that the materials arrive in Mexico on a railcar/trailer (as translated) and are taken to the Importer's (Francisco Martinez) warehouse. He stated that the warehouse's address is Calle LaGuna Santa Maria, Calle 12, Colona Industrial, 87350 (Matamoros, MX). Mr. Elizondo stated that he picks up the materials from that warehouse in a trailer within two to three days of arrival and takes them to his store. SECTION IV - AREA OF CONCERNS As of this inspection and based on follow-up conversations and information provided, no AOCs were identified (see Section IV - Follow Up). SECTION V - LIST OF APPENDICES Appendix 1 Appendix 2 Appendix 3 Appendix 4 - Appendix 5 - Photo Log of Partial Set and Comparison Photo Layouts of Locations for the Current and Past Two Inspections Three Shipping Related Papers Provided by Mr. Yanez and the Shipping Document Provided to TCEQ BGW and Warehouse #14 Aerial Maps Documents Mr. Elizondo Provided After the Inspection including SDS and Shipping Documents - Includes: 8/27/24 Email of SDS; 8/30/24 Email of Responses to Questions and Shipping Documents; 8/30/24 Email of Shipping Documents; and 9/27/24 Email of Shipping Documents 9/6/24 BGW Email Response Regarding Materials All Removed 8 of 8 Brownsville Gulfside Warehouse, Brownsville, Texas Inspection Date 08/19-20/2024 Appendix 1 Photograph Log of Partial Set and Comparison Photo Layouts of Locations for the Current and Past Two Inspections UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010122 Date of Photo: 8/19/2024 Time of Photo: 10:30 Photographer: Dedriel Gardner Description: Warehouse #1 - Pallet of 1-pint unlabeled metal cans with no labels (it looked as the labels had been removed as shown in Photo 2). The pallet contained about 47 boxes of 5, 1-pint cans shrink wrapped. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010123 Date of Photo: 8/19/2024 Time of Photo: 10:31 Photographer: Dedriel Gardner Description: Warehouse #1 - Close-up of an unlabeled 1-pint can that was on the pallet shown in Photo 1. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010124 Date of Photo: 8/19/2024 Time of Photo: 10:31 Photographer: Dedriel Gardner Description: Warehouse #1 - 55-gallon blue drums that were labeled as putty. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010125 Date of Photo: 8/19/2024 Time of Photo: 10:31 Photographer: Dedriel Gardner Description: Warehouse #1 - On right side of photo is the pallet of 1-pint unlabeled full metal cans with no labels shown in Photo 1. The pallet contained about 47 boxes of 5, 1-pint cans shrink wrapped. On left side of photo are the 55-gallon drums of putty shown in Photo 3. The supersacks contain cement and do not belong to Mr. Elizondo. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010126 Date of Photo: 8/19/2024 Time of Photo: 10:32 Photographer: Dedriel Gardner Description: Warehouse #1 - Close-up of a label on an approximately 1-quart jug labeled Dulux TinterColorant Color Rendez Vous shown in Photo 6. The label was in a foreign language, but the word "water" was noted as the pen points out. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010127 Date of Photo: 8/19/2024 Time of Photo: 10:33 Photographer: Dedriel Gardner Description: Warehouse #1 - 4 pails containing approximately 13, 1-quart jugs labeled Dulux TinterColorant. The label was in a foreign language, but the word "water" was noted on the label as shown in Photos 5 and 7. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010128 Date of Photo: 8/19/2024 Time of Photo: 10:33 Photographer: Dedriel Gardner Description: Warehouse #1 - Close-up of a label on an approximately 1-quart jug labeled Dulux TinterColorant Color Rendez Vous shown in Photo 6. The label was in a foreign language, but the word "water" was noted. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010129 Date of Photo: 8/19/2024 Time of Photo: 10:34 Photographer: Dedriel Gardner Description: Warehouse #1 - Close-up of a label on one of the approximately 140, half gallon plastic jugs labeled Dulux Valentine Texture Unique & Cremeuse and 30 g/L VOCs shown in Photo 9. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010130 Date of Photo: 8/19/2024 Time of Photo: 10:34 Photographer: Dedriel Gardner Description: Warehouse #1 - Approximately 140, half gallon plastic jugs labeled Dulux Valentine Texture Unique & Cremeuse and 30 g/L VOCs. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 10 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010131 Date of Photo: 8/19/2024 Time of Photo: 10:35 Photographer: Dedriel Gardner Description: Warehouse #1 - Close-up of a label on one of the approximately 54, 5-gallon plastic pails labeled as different types of wallpaper adhesives that was labeled Premium Grade Heavy Duty Clear 234 Adhesive (Photo 11), 5.2 g/L VOCs, and ingredients included clay, sodium nitrate, starch, and water. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 11 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010132 Date of Photo: 8/19/2024 Time of Photo: 10:36 Photographer: Dedriel Gardner Description: Warehouse #1 - Close-up of a label on one of the approximately 54, 5-gallon plastic pails labeled as different types of wallpaper adhesives that was labeled Premium Grade Heavy Duty Clear 234 Adhesive, 5.2 g/L VOCs, and ingredients included clay, sodium nitrate, starch, and water as shown in Photo 10. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 12 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010133 Date of Photo: 8/19/2024 Time of Photo: 10:36 Photographer: Dedriel Gardner Description: Warehouse #1 - Approximately 54, 5-gallon plastic pails labeled as different types of wallpaper adhesives part of which are also shown in Photo 14 and are labeled Marketing Restricted/Must be Relabeled . Close-ups of some of the labels are shown in Photos 10, 11, 13, 15 and 16. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 13 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010134 Date of Photo: 8/19/2024 Time of Photo: 10:37 Photographer: Dedriel Gardner Description: Warehouse #1 - Close-up of a label on one of the approximately 54, 5-gallon plastic pails labeled as different types of wallpaper adhesives that was labeled Zinsser Sure Grip Heavy Duty Plus, VOC compliant, and ingredients included corn starch, Dextrin, sodium nitrate, starch, and water. Also, shown in Photo 16. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 14 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010135 Date of Photo: 8/19/2024 Time of Photo: 10:37 Photographer: Dedriel Gardner Description: Warehouse #1 - Approximately 54, 5-gallon plastic pails labeled as different types of wallpaper adhesives part of which are also shown in Photo 12 and labeled Marketing Restricted/Must be Relabeled. Close-ups of some of the labels are shown in Photos 10, 11, 13, 15 and 16. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 15 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010136 Date of Photo: 8/19/2024 Time of Photo: 10:39 Photographer: Dedriel Gardner Description: Warehouse #1 - Close-up of a label on one of the approximately 54, 5-gallon plastic pails labeled as different types of wallpaper adhesives that was labeled Zinsser Sure Grip Clay Strippable 134. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 16 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010137 Date of Photo: 8/19/2024 Time of Photo: 10:39 Photographer: Dedriel Gardner Description: Warehouse #1 - Close-up of a label on one of the approximately 54, 5-gallon plastic pails labeled as different types of wallpaper adhesives that was labeled Zinsser Sure Grip Heavy Duty Plus, VOC compliant, and ingredients included corn starch, Dextrin, sodium nitrate, starch, and water. Also, shown in Photo 13. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 17 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010138 Date of Photo: 8/19/2024 Time of Photo: 10:40 Photographer: Dedriel Gardner Description: Warehouse #1 - Approximately 90, 1-gallon black metal unlabeled individual cans on two pallets that were shrink wrapped and labeled as Valspar and asthma and allergy friendly. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 18 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010139 Date of Photo: 8/19/2024 Time of Photo: 10:45 Photographer: Dedriel Gardner Description: Warehouse #1 - Approximately 100 or more, 1-pint cans labeled Dulux Valentine and Marketing Restricted/Must be Relabeled. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 19 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010140 Date of Photo: 8/19/2024 Time of Photo: 10:45 Photographer: Dedriel Gardner Description: Warehouse #1 - Close-up of a label on one of the approximately 100 or more, 1-pint cans labeled Dulux Valentine and Marketing Restricted/Must be Relabeled. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 20 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010141 Date of Photo: 8/19/2024 Time of Photo: 10:46 Photographer: Dedriel Gardner Description: Warehouse #1 - Close up of one of the labels on the approximately 10 totes, three labeled some type of latex paint or coating and the others had no labels shown in Photo 21. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 21 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010142 Date of Photo: 8/19/2024 Time of Photo: 10:47 Photographer: Dedriel Gardner Description: Warehouse #1 - Approximately 10 totes, three labeled some type of latex paint or coating and the others had no labels. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 22 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010143 Date of Photo: 8/19/2024 Time of Photo: 10:49 Photographer: Dedriel Gardner Description: Warehouse #1 - Close-up of a label on an approximately 1-quart jug labeled Dulux TinterColorant Color Rendez Vous. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 23 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010144 Date of Photo: 8/19/2024 Time of Photo: 10:50 Photographer: Dedriel Gardner Description: Warehouse #1 - Bags of Shell GTL Sarawax SX105 that consisted of a white powder type materials that had spilled onto the floor. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 25 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010146 Date of Photo: 8/19/2024 Time of Photo: 10:52 Photographer: Dedriel Gardner Description: Warehouse #1 - Approximately 10 totes with no visible labels. Containers were full to partially full. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 26 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010147 Date of Photo: 8/19/2024 Time of Photo: 10:52 Photographer: Dedriel Gardner Description: Warehouse #1 - Close-up of a Steris Nonconformance Form on a tote of apparent paint related materials dated 7/12/23 and labeled as having "Contamination". UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 27 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010148 Date of Photo: 8/19/2024 Time of Photo: 10:53 Photographer: Dedriel Gardner Description: Warehouse #1 - Close-up of a Steris Nonconformance Form on a tote of apparent paint related materials dated 7/12/23 and labeled as having "Contamination" as shown in Photo 26. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 28 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010149 Date of Photo: 8/19/2024 Time of Photo: 10:54 Photographer: Dedriel Gardner Description: Warehouse #1 - Approximately 19 totes with some labeled as latex type paints, coatings, and others no visible labels. Containers were full to partially full. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 29 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010150 Date of Photo: 8/19/2024 Time of Photo: 11:00 Photographer: Dedriel Gardner Description: Warehouse #1 - Close-up of a label on one of the approximately 19 totes with some labeled as latex type paints, coatings, and others no visible labels as shown in Photo 32. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 30 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010151 Date of Photo: 8/19/2024 Time of Photo: 11:00 Photographer: Dedriel Gardner Description: Warehouse #1 - Close-up of a label on one of the approximately 19 totes with some labeled as latex type paints, coatings, and others no visible labels as shown in Photo 32. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 31 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010152 Date of Photo: 8/19/2024 Time of Photo: 11:00 Photographer: Dedriel Gardner Description: Warehouse #1 - Close-up of a label on one of the approximately 19 totes with some labeled as latex type paints, coatings, and others no visible labels as shown in Photo 32. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 32 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010153 Date of Photo: 8/19/2024 Time of Photo: 11:01 Photographer: Dedriel Gardner Description: Warehouse #1 - Approximately 19 totes with some labeled as latex type paints, coatings, and others no visible labels (same totes shown in Photo 28 except facing the opposite direction). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 33 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010154 Date of Photo: 8/19/2024 Time of Photo: 11:02 Photographer: Dedriel Gardner Description: Warehouse #1 - Approximately 31 black and white 5-gallon unlabeled pails with some containing a blue circle. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 34 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010155 Date of Photo: 8/19/2024 Time of Photo: 11:02 Photographer: Dedriel Gardner Description: Warehouse #1 - 3 totes, 2 no visible labels and one with label as shown in the photo. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 35 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010156 Date of Photo: 8/19/2024 Time of Photo: 11:02 Photographer: Dedriel Gardner Description: Warehouse #1 - Approximately 7 pallets containing a total of 135, 5-gallon pails of which some were labeled Purple 11/19/18, PQP, and some unlabeled containing a blue circle. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 36 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010157 Date of Photo: 8/19/2024 Time of Photo: 11:03 Photographer: Dedriel Gardner Description: Warehouse #1 - Close-up of a label on one of the approximately 7 pallets containing a total of 135, 5-gallon pails of which some were labeled Purple 11/19/18, PQP, and some unlabeled containing a blue circle. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 37 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010158 Date of Photo: 8/19/2024 Time of Photo: 11:04 Photographer: Dedriel Gardner Description: Warehouse #1 - Close-up of a label on one of the approximately 7 pallets containing a total of 135, 5-gallon pails of which some were labeled Purple 11/19/18, PQP, and some unlabeled containing a blue circle. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 38 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010159 Date of Photo: 8/19/2024 Time of Photo: 11:04 Photographer: Dedriel Gardner Description: Two unknown unlabeled 5-gallon plastic jugs that had a solvent type odor according to Mr. Yanez during the previous inspection. He stated that they came over with the electrical box located next to them. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 39 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010160 Date of Photo: 8/19/2024 Time of Photo: 11:05 Photographer: Dedriel Gardner Description: Warehouse #1 - 3 totes, 2 no visible labels and one with label as shown in the photo. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 40 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010161 Date of Photo: 8/19/2024 Time of Photo: 11:06 Photographer: Dedriel Gardner Description: Warehouse #1 - Close up of approximately 40 automobile paint pens that were labeled as "FLAMMABLE" in the previous inspection reports. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 41 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010162 Date of Photo: 8/19/2024 Time of Photo: 11:06 Photographer: Dedriel Gardner Description: Warehouse #1 - Close up of approximately 40 automobile paint pens that were labeled as "FLAMMABLE" in the previous inspection reports. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 42 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010163 Date of Photo: 8/19/2024 Time of Photo: 11:11 Photographer: Dedriel Gardner Description: Outside of Warehouse #1 - Leftover paint pens that spilled on the ground discussed during the previous 12/12/23 inspection report. . UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 43 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010164 Date of Photo: 8/19/2024 Time of Photo: 11:11 Photographer: Dedriel Gardner Description: Outside of Warehouse #1 - Leftover paint pens that spilled on the ground discussed during the previous 12/12/23 inspection report. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 45 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010166 Date of Photo: 8/19/2024 Time of Photo: 11:16 Photographer: Dedriel Gardner Description: Warehouse #2 - Old paint samples (about 100, 8-oz jars) and paint materials (including oil base paints) being stored. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 46 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010167 Date of Photo: 8/19/2024 Time of Photo: 11:16 Photographer: Dedriel Gardner Description: Warehouse #2 - Old paint materials being stored including a pallet with about 100, 1gallon metal cans of oil base paint; one pallet with about 54 boxes of 1-pint to 1-quart cans of paint materials and one box of 7 cans of solvent containing toluene; one pallet of unlabeled/unreadable labels of 1-gallon jugs; and one pallet of about 100, 1-gallon black 1-gallon unlabeled cans. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 47 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010168 Date of Photo: 8/19/2024 Time of Photo: 11:17 Photographer: Dedriel Gardner Description: Warehouse #2 - Close-up of old paint samples shown in Photo 45 dating back to 2011 and 2012. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 48 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010169 Date of Photo: 8/19/2024 Time of Photo: 11:17 Photographer: Dedriel Gardner Description: Warehouse #2 - Close-up of old paint label shown in Photo 46 showing that it is labeled as flammable and Marketing Restriction Must be Relabeled. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 49 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010170 Date of Photo: 8/19/2024 Time of Photo: 11:17 Photographer: Dedriel Gardner Description: Warehouse #2 - Close-up of old paint label shown in Photos 46 and 48 showing that it is labeled as flammable and Marketing Restriction Must be Relabeled. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 51 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010172 Date of Photo: 8/19/2024 Time of Photo: 11:18 Photographer: Dedriel Gardner Description: Warehouse #2 - Close-up of old paint label shown in Photos 46, 48 thru 50 showing that it is labeled as flammable. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 52 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010173 Date of Photo: 8/19/2024 Time of Photo: 11:18 Photographer: Dedriel Gardner Description: Warehouse #2 - Close-up of old paint label shown in Photos 46, 48 thru 50 showing that it is labeled as flammable. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 53 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010174 Date of Photo: 8/19/2024 Time of Photo: 11:19 Photographer: Dedriel Gardner Description: Warehouse #2 - Close-up of old paint label shown in Photos 46 and 52 showing that it is labeled as flammable and Marketing Restriction Must be Relabeled. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 54 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010175 Date of Photo: 8/19/2024 Time of Photo: 11:19 Photographer: Dedriel Gardner Description: Warehouse #2 - Close-up of old paint label shown in Photos 46 and 51 showing that it is labeled as flammable. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 55 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010176 Date of Photo: 8/19/2024 Time of Photo: 11:20 Photographer: Dedriel Gardner Description: Warehouse #2 - Close-up of old paint label shown in Photos 46 showing that it is labeled as oil based paint. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 56 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010177 Date of Photo: 8/19/2024 Time of Photo: 11:21 Photographer: Dedriel Gardner Description: Warehouse #2 - Close-up of old paint label shown in Photos 46, 57, 59, and 60 showing that it is labeled as flammable. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 57 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010178 Date of Photo: 8/19/2024 Time of Photo: 11:21 Photographer: Dedriel Gardner Description: Warehouse #2 - Close-up of old paint label shown in Photos 46, 56, 59, and 60 showing that it is labeled as flammable. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 58 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010179 Date of Photo: 8/19/2024 Time of Photo: 11:22 Photographer: Dedriel Gardner Description: Warehouse #2 - Close-up of old paint materials being stored including the pallet with about 54 boxes of 1-pint to 1-quart cans of paint materials dated 2009. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 59 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010180 Date of Photo: 8/19/2024 Time of Photo: 11:23 Photographer: Dedriel Gardner Description: Warehouse #2 - Close-up of old solvent flammable label shown in Photos 46, 56, 57, and 60 showing that it is labeled as flammable. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 60 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010181 Date of Photo: 8/19/2024 Time of Photo: 11:23 Photographer: Dedriel Gardner Description: Warehouse #2 - Close-up of old flammable solvent shown in Photos 46, 56, 57, and 59 showing that it is labeled as flammable. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 61 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010182 Date of Photo: 8/19/2024 Time of Photo: 11:23 Photographer: Dedriel Gardner Description: Warehouse #2 - Close-up of old paint materials being stored including the pallet with about 54 boxes of 1-pint to 1-quart cans of paint materials dated 2009 as shown in Photo 58. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 62 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010183 Date of Photo: 8/19/2024 Time of Photo: 11:24 Photographer: Dedriel Gardner Description: Warehouse #2 - Close-up of old paint label shown in Photos 46 and 63 showing that it is labeled as flammable. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 63 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010184 Date of Photo: 8/19/2024 Time of Photo: 11:25 Photographer: Dedriel Gardner Description: Warehouse #2 - Close-up of old paint label shown in Photos 46 and 62 showing that it is labeled as flammable. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 64 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010185 Date of Photo: 8/19/2024 Time of Photo: 11:25 Photographer: Dedriel Gardner Description: Warehouse #2 - Close-up of the one pallet of unlabeled/unreadable labels of 1-gallon jugs shown in Photos 46 and 65. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 65 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010186 Date of Photo: 8/19/2024 Time of Photo: 11:26 Photographer: Dedriel Gardner Description: Warehouse #2 - Close-up of the one pallet of unlabeled/unreadable labels of 1-gallon jugs shown in Photos 46 and 64. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 66 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010187 Date of Photo: 8/19/2024 Time of Photo: 11:26 Photographer: Dedriel Gardner Description: Warehouse #2 - Close-up of one pallet of about 100, 1-gallon black 1-gallon unlabeled cans shown in Photo 46 and 66. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 67 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010188 Date of Photo: 8/19/2024 Time of Photo: 11:26 Photographer: Dedriel Gardner Description: Warehouse #2 - Close-up of one pallet of about 100, 1-gallon black 1-gallon unlabeled cans shown in Photo 46 and 66. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 69 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010190 Date of Photo: 8/19/2024 Time of Photo: 11:28 Photographer: Dedriel Gardner Description: Warehouse #2 - Close-up of one pallet of 210, 1-gallon cans of possible oil base paints as shown in Photos 72. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 70 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010191 Date of Photo: 8/19/2024 Time of Photo: 11:28 Photographer: Dedriel Gardner Description: Warehouse #2 - Close-up of one pallet of 210, 1-gallon cans of possible oil base paints as shown in Photos 72. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 72 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010193 Date of Photo: 8/19/2024 Time of Photo: 11:29 Photographer: Dedriel Gardner Description: Warehouse #2 - One pallet of 210, 1-gallon cans of possible oil base paints dated 5/28/21 shown in Photo 75. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 73 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010194 Date of Photo: 8/19/2024 Time of Photo: 11:29 Photographer: Dedriel Gardner Description: Warehouse #2 - Close-up of Photo 75 of 4, 55-gallon drums labeled Witbreak DRM-9510. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 74 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010195 Date of Photo: 8/19/2024 Time of Photo: 11:30 Photographer: Dedriel Gardner Description: Warehouse #2 - Close-up of Photo 75 of a label on one of the 5 totes of paint related materials. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 75 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010196 Date of Photo: 8/19/2024 Time of Photo: 11:31 Photographer: Dedriel Gardner Description: Warehouse #2 - A pallet of 210, 1-gallon cans of old paints; 5 totes of paint related materials; and 4, 55-gallon drums labeled Witbreak DRM-9510. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 76 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010197 Date of Photo: 8/19/2024 Time of Photo: 11:33 Photographer: Dedriel Gardner Description: Warehouse #2 - Close-up of one of the pallets shown in Photo 77 of 1-gallon unlabeled black cans. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 77 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010198 Date of Photo: 8/19/2024 Time of Photo: 11:33 Photographer: Dedriel Gardner Description: Warehouse #2 - About 25 totes of paint related materials; 6 pallets of 1-gallon cans of oil based paints for a total of about 1260, 1-gallon cans; 1 pallet of unlabeled black 1-gallon cans; and 55gallon drums of caulking. One readable date on a pallet was 6/14/22. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 78 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010199 Date of Photo: 8/19/2024 Time of Photo: 11:34 Photographer: Dedriel Gardner Description: Warehouse #2 - Close-up of the 1 pallet of unlabeled black 1-gallon cans; shown in Photo 77. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 79 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010200 Date of Photo: 8/19/2024 Time of Photo: 11:35 Photographer: Dedriel Gardner Description: Warehouse #2 - Close-up of one of the labels on a 1-gallon can on one of the 6 pallets of 1gallon cans of oil based paints for a total of about 1260, 1-gallon cans shown in Photo 77. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 80 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010201 Date of Photo: 8/19/2024 Time of Photo: 11:35 Photographer: Dedriel Gardner Description: Warehouse #2 - Close-up of one of the labels on a 1-gallon can on one of the 6 pallets of 1gallon cans of oil based paints for a total of about 1260, 1-gallon cans shown in Photo 77. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 81 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010202 Date of Photo: 8/19/2024 Time of Photo: 11:36 Photographer: Dedriel Gardner Description: Warehouse #2 - Close-up of one of the labels on a 1-gallon can on one of the 6 pallets of 1gallon cans of oil based paints for a total of about 1260, 1-gallon cans shown in Photo 77. One readable date on a pallet was 6/14/22. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 82 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010203 Date of Photo: 8/19/2024 Time of Photo: 11:36 Photographer: Dedriel Gardner Description: Warehouse #2 - Close-up of one of the labels on a pallet of 21 boxes of 12, 1-quart cans labeled D-100 Solvent that contains toluene as shown in Photo 84. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 83 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010204 Date of Photo: 8/19/2024 Time of Photo: 11:37 Photographer: Dedriel Gardner Description: Warehouse #2 - Close-up of one of the labels on a pallet of 21 boxes of 12, 1-quart cans labeled D-100 Solvent that contains toluene as shown in Photo 84. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 84 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010205 Date of Photo: 8/19/2024 Time of Photo: 11:37 Photographer: Dedriel Gardner Description: Warehouse #2 - One pallet of 21 boxes of 12, 1-quart cans labeled D-100 Solvent that contains toluene as shown in Photo 84. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 85 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010206 Date of Photo: 8/19/2024 Time of Photo: 11:37 Photographer: Dedriel Gardner Description: Warehouse #2 - One pallet of 21 boxes of 12, 1-quart cans labeled D-100 Solvent that contains toluene as shown in Photo 84. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 91 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010212 Date of Photo: 8/20/2024 Time of Photo: 10:00 Photographer: Dedriel Gardner Description: Warehouse #2 - Overall view of materials remaining in warehouse that include supersacks of cement and paint related materials behind the supersacks of cements. The supersacks of cement do not belong to Mr. Elizondo. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 92 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010213 Date of Photo: 8/20/2024 Time of Photo: 10:00 Photographer: Dedriel Gardner Description: Warehouse #2 - Overall view of materials remaining in warehouse that include supersacks of cement and paint related materials behind the supersacks of cements. The supersacks of cement do not belong to Mr. Elizondo. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 94 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010215 Date of Photo: 8/20/2024 Time of Photo: 10:01 Photographer: Dedriel Gardner Description: Warehouse #2 - Overall view of materials remaining in warehouse that include supersacks of cement and paint related materials behind the supersacks of cements. The supersacks of cement do not belong to Mr. Elizondo. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 95 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010216 Date of Photo: 8/20/2024 Time of Photo: 10:02 Photographer: Dedriel Gardner Description: Warehouse #2 - Overall view of materials remaining in warehouse that include supersacks of cement and paint related materials behind the supersacks of cements. The supersacks of cement do not belong to Mr. Elizondo. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 97 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010218 Date of Photo: 8/20/2024 Time of Photo: 10:04 Photographer: Dedriel Gardner Description: Warehouse #2 - Paint related materials being stored. The supersacks of cement do not belong to Mr. Elizondo. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 98 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010219 Date of Photo: 8/20/2024 Time of Photo: 10:04 Photographer: Dedriel Gardner Description: Warehouse #2 - Paint related materials being stored. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 101 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010222 Date of Photo: 8/20/2024 Time of Photo: 10:12 Photographer: Dedriel Gardner Description: Warehouse #3 - Overall view of blue drums with "Use before" date 4/14/2019. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 102 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010223 Date of Photo: 8/20/2024 Time of Photo: 10:12 Photographer: Dedriel Gardner Description: Warehouse #3 - Overall view of blue drums with "Use before" date 4/14/2019 along with containers of paint related materials. The supersacks of cement do not belong to Mr. Elizondo. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 103 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010224 Date of Photo: 8/20/2024 Time of Photo: 10:13 Photographer: Dedriel Gardner Description: Warehouse #3 - Close-up of Photo 102 containers of paint related materials. The supersacks of cement do not belong to Mr. Elizondo. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 104 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010225 Date of Photo: 8/20/2024 Time of Photo: 10:13 Photographer: Dedriel Gardner Description: Warehouse #3 - Close-up of Photo 102 containers of paint related materials. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 106 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010227 Date of Photo: 8/20/2024 Time of Photo: 10:14 Photographer: Dedriel Gardner Description: Warehouse #3 - Close-up of a blue drum label on drums shown in Photo 101 stating "Use before" date 12/27/2018. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 107 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010228 Date of Photo: 8/20/2024 Time of Photo: 10:14 Photographer: Dedriel Gardner Description: Warehouse #3 - Close-up of a blue drum label on drums shown in Photo 101 stating "Use before" date 4/14/2019. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 111 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010232 Date of Photo: 8/20/2024 Time of Photo: 10:21 Photographer: Dedriel Gardner Description: Warehouse #5 - Overall view of supersacks of Oxido being stored in the warehouse. These materials do not belong to Mr. Elizondo. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 112 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010233 Date of Photo: 8/20/2024 Time of Photo: 12:45 Photographer: Dedriel Gardner Description: Warehouse #14 - Overall view of paint related material waiting to be shipped to Mexico. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 113 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010234 Date of Photo: 8/20/2024 Time of Photo: 12:45 Photographer: Dedriel Gardner Description: Warehouse #14 - Close-up of one of the labels on a 1-gallon can of paint on pallet shown in Photo 112. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 114 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010235 Date of Photo: 8/20/2024 Time of Photo: 12:46 Photographer: Dedriel Gardner Description: Warehouse #14 - Close-up of one of the labels on a 1-gallon can of paint on pallet shown in Photo 112 stating "Danger! Extremely Flammable. Vapors May Ignite Explosively. Harmful or Fatal if Swallowed.". Front of this can's label is shown in Photo 115. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 115 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010236 Date of Photo: 8/20/2024 Time of Photo: 12:47 Photographer: Dedriel Gardner Description: Warehouse #14 - Close-up of one of the labels on a 1-gallon can of paint on pallet shown in Photo 112 stating "Danger! Extremely Flammable. Vapors May Ignite Explosively. Harmful or Fatal if Swallowed.". Back of this can's label is shown in Photo 114. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 116 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010237 Date of Photo: 8/20/2024 Time of Photo: 12:48 Photographer: Dedriel Gardner Description: Warehouse #14 - Close-up of the approximately 1-pint cans of paint on pallet shown in Photo 112. Some of the cans were opened and the paint had dried which Mr. Elizondo stated was water base. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 117 Location: Brownsville Gulfside Warehouse City: Brownsville County/Parish: Cameron State: Texas Photo File Name: P1010238 Date of Photo: 8/20/2024 Time of Photo: 12:49 Photographer: Dedriel Gardner Description: Warehouse #14 - Close-up of one of the labels on an approximately 1-pint can of paint on pallet shown in Photo 112 (can removed for photo). The label is in a foreign language. Appendix 2 Three Shipping Related Papers Provided by Mr. Yanez and the Shipping Document Provided to TCEQ Appendix 3 BGW and Warehouse #14 Aerial Maps WHSE #1 WHSE #2 Port of Brownsville Brownsville Gulfside Warehouse, Imagery 2024 Airbus, Maxar Technologies, Map data 2024 200 ft WHSE #3 125 Industrial Dr Warehouse #14, Brownsville, TX Imagery 2024 Airbus, Maxar Technologies, Map data 2024 Google 50 ft