Document mby1j9QD29bk0BN826b7dVyJd

Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 6 Enforcement Division INSPECTION REPORT 11/7/2024 11:40 (CT) Announced: No 11/7/2024 12:45 (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 Action Oil Services, Inc. TXR000085911 650 Canary St. Vidor, TX 77662 Orange County Non-generator 562211 Action Oil Services, Inc.is a used oil transporter and transfer facility that picks up used oil waste from other facilities. 30.10595, -94.0518 Additional Persons Participating in Inspection: Name Title Organization Angela Hays Inspector EPA REGION 6 Sandesh Thapa Inspector EPA REGION 6 Jon Herbay Contractor Eastern Research Group (ERG) Email Hays.Angela@epa.gov Thapa.Sandesh@epa.gov Jon.Herbay@erg.com Phone (214) 665-2285 (214) 665-2265 (412) 780-9931 Lead Inspector: Vince Damiano Chemical Engineer ERG Vincent Damiano Digitally signed by Vincent Damiano Date: 2025.02.06 10:09:05 -05'00' Vince.Damiano@erg.com 02/06/2025 (703) 633-1732 Page 1 of 5 Action Oil Services SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection Inspection Date: 11/07/2024 The Port of Beaumont 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 Environmental Protection Agency (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 Inspector/Enforcement Officer/EPA Region 6 Inspector/Enforcement Officer/EPA Region 6 RCRA Inspector/ Contractor/ERG Action Oil Services Action Oil Services Name Vince Damiano Phone Email (703) 633-1732 Vince.Damiano@erg.com Opening Conf. Yes Closing Conf. Yes Angela Hays (214) 665-2285 Hays.Angela@epa.gov Yes Yes Sandesh Thapa (214) 665-2265 Thapa.Sandesh@epa.gov Yes Yes Jon Herbay (412) 780-9931 Jon.Herbay@erg.com Yes Yes Landon Tannehill (409) 781-3743 actionoilsvc@yahoo.com Yes Yes Luther E Tannehill (409) 781-3711 actionoilsvc@yahoo.com Yes Yes Page 2 of 5 Action Oil Services Facility General Description Inspection Date: 11/07/2024 Tenant/Area Action Oil Services Inspection Date 11/07/24 Process Description Action Oil Services, Inc. (Action Oil) is a used oil transporter and transfer facility that collects used oil waste from customers. Action Oil Services is land-based and does not operate under a MARPOL COA. Area of Concern Yes SECTION II - OBSERVATIONS Tenant: Action Oil Services Section: 2.1 Date: 11/07/24, 11:40 AM Contains AOC: Yes Contains CBI: No Lead Inspector: Vince Damiano Attendees: Landon Tannehill (Manager) and Luther E. Tannehill (Manager / Owner) Action Oil is located in Vidor, TX, and operates as a used oil transporter and transfer facility. It picks up used oil from local customers, consolidates it, and ships it out to be recycled. Action Oil services customers by picking up used oil, used oily fuels, and oil-contaminated debris and absorbents using a flatbed truck or a vacuum truck. Action Oil has two 70-barrel and two 50-barrel vacuum trucks for servicing customers and two 190-barrel vacuum trucks for transporting collected used oil to Blue Tide Environmental (TXR000084220) to be recycled. Most of Action Oil's customers are facilities that conduct oil changes on vehicles, but a small part is picked up from used oil generators along the port and vessels docked at the port. Action Oil is certified to do over-the-water transfers of used oil and oily water. Action Oil processes solids containing used oil and oil filters through a filter press; collecting the used oil drained from the solids and recycling the empty oil filters. Used Oil that is collected in containers is transferred into a used oil tank before being shipped to Blue Tide Environmental. Action Oil has been at this location for approximately one year after relocating. At the time of the inspection, Action Oil had a total of twenty storage tanks, with only eleven in use. Action Oil had installed ten new used oil tanks that were storing used oil. However, ten older used oil tanks were in the process of being decommissioned with only one of the older tanks being used as an oil/water separator. Following the opening conference, the inspection team conducted a visual inspection of the used oil process area and tank farm. Upon entering the process pad in the process area, the inspection team observed approximately thirty 55-gallon drums and several 5-gallon containers of used oil waiting to be consolidated into the hopper and filter. Throughout the process pad, the inspection team observed five 55-gallon drums and three 5-gallon containers storing used oil, all approximately one-quarter full to full, that were not marked or labeled as "Used Oil" (see Appendix 1 - Photos 1-7 and 10) [AOC#1 - Action Oil did not clearly label containers used to store used oil with the words "Used Oil" - 40 CFR 279.45(g)(1)]. Next to the hopper, the inspection team observed two spills of used oil onto the concrete pad that were not properly cleaned up (see Appendix 1 - Photos 8 and 9) [AOC#2 - Action Oil did not clean up and properly manage the released used oil and other materials - 40 CFR 279.45(h)]. The process pad was made of concrete and drained to two closed sumps found in the middle of the building stretching from the north wall to the south wall; the pad also had a slight berm built along the perimeter of approximately two inches (see Appendix 1 - Photos 18 to 20). Next, the inspection team observed the container storage building, where empty drums and totes were stored for exchange by Action Oil during its used oil collection process. The inspection team continued the inspection at the tank farm area. Mr. Luther Tannehill stated only one of the older original tanks out of ten is Page 3 of 5 Action Oil Services Inspection Date: 11/07/2024 currently storing used oil and it is used as an oil/water separator (see Appendix 1 - Photo 12). The tank was not labeled as used oil at the time of the inspection (see AOC#1). The inspection team noted the concrete pad where the oil/water separator was sitting did not have a secondary containment system (see Appendix 1 - Photo 11) [AOC#3 - Action Oil did have a secondary containment system for an aboveground tank used to store oil at a transfer facility - 40 CFR 279.45(f)]. Mr. Tannehill informed the inspection team that the water from the bottom of the oil/water separator is discharged into the county drainage canal located at the back of the property behind the tank farm (see Appendix 1 - Photos 13 to 15). Mr. Tannehill said they do not have an NPDES permit and they occasionally sample the water in the oil/water separator. Adjacent to the older ten tanks was a set of ten new used oil tanks that were actively storing used oil at the time of the inspection. However, the tanks did not contain a label or marking indicating they were storing used oil (see Appendix 1 - Photos 16 and 17, AOC#1). The inspection team did not observe other areas of concern (AOCs) 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 1:00 PM with Action Oil personnel. The AOCs were communicated during the closing. Following the inspection on 11/18/2024, Mr. Landon Tannehill sent a follow-up email in response to the AOCs observed during the inspection including: Photos of labels placed on non-hazardous drums in the process pad and the spills next to the hopper cleaned up (Appendix 2). Statement that labels have been ordered for the used oil tanks. Sample test results for the water discharge from the oil/water separator were analyzed on 11/18/2024 (Appendix 3). An example of a used oil shipment ticket to Blue Tide with pre-shipment test results (Appendix 4). The cover page of their current SPCC plan which was last revised in 2005 (Appendix 5). Drawing of the facility and containment area (Appendix 5). Pictures of a secondary containment system installed on the concrete pad for the older ten tanks; sent on 11/25/2024 (Appendix 6). See the full response in Appendix 7. 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: Action Oil Services AOC #1 - Action Oil did not clearly label containers used to store used oil with the words "Used Oil." Citation: 40 CFR 279.45(g)(1) Section: 2.1 AOC #2 - Action Oil did not clean up and manage properly the released used oil and other materials. Citation: 40 CFR 279.45(h) Section: 2.1 Page 4 of 5 Action Oil Services Inspection Date: 11/07/2024 AOC #3 - Action Oil did have a secondary containment Citation: 40 CFR 279.45(f) Section: 2.1 system for an aboveground storage tank used to store used oil at a transfer facility. 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. 11/18/24 Action Oil email - Landon Tannehill provided the inspection team with photos of attempted corrections made towards AOCs observed and requested documentation from the inspection team. 2. 11/25/24 Action Oil email - Landon Tannehill provided the inspection team with photos of the secondary containment system installed on the tank farm. SECTION VI - LIST OF APPENDICES Appendix 1. Photograph Log Appendix 2. Photos from 11/18 Response Appendix 3. Discharge Water Sample Results Appendix 4. Blue Tide Used Oil Ticket and Sample Results Appendix 5. SPCC Cover Sheet and Facility Drawing Appendix 6. Secondary Containment System Installed on Tanks Appendix 7. Action Oil Email Response from 11/18 Page 5 of 5 APPENDIX 1. PHOTOGRAPH LOG UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Action Oil Services, Inc. City: Vidor County/Parish: Orange State: Texas Photo No. 1 Photo File Name: DSCN7678 Date of Photo: 11/07/2024 Time of Photo: 12:15 hrs. Photographer: Vince Damiano Description: View of a half-full 5-gallon container storing used oil that was unlabeled observed on the process pad. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Action Oil Services, Inc. City: Vidor County/Parish: Orange State: Texas Photo No. 2 Photo File Name: DSCN7679 Date of Photo: 11/07/2024 Time of Photo: 12:16 hrs. Photographer: Vince Damiano Description: View of a quarter-full 55-gallon container storing used oil that was unlabeled observed on the process pad. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Action Oil Services, Inc. City: Vidor County/Parish: Orange State: Texas Photo No. 3 Photo File Name: DSCN7680 Date of Photo: 11/07/2024 Time of Photo: 12:16 hrs. Photographer: Vince Damiano Description: View of a full 55-gallon container storing used oil that was unlabeled observed on the process pad. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Action Oil Services, Inc. City: Vidor County/Parish: Orange State: Texas Photo No. 4 Photo File Name: DSCN7681 Date of Photo: 11/07/2024 Time of Photo: 12:17 hrs. Photographer: Vince Damiano Description: View of a half-full 55-gallon container storing used oil that was unlabeled observed on the process pad. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Action Oil Services, Inc. City: Vidor County/Parish: Orange State: Texas Photo No. 5 Photo File Name: DSCN7682 Date of Photo: 11/07/2024 Time of Photo: 12:17 hrs. Photographer: Vince Damiano Description: View of a quarter-full 5-gallon container storing used oil that was unlabeled observed on the process pad. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Action Oil Services, Inc. City: Vidor County/Parish: Orange State: Texas Photo No. 6 Photo File Name: DSCN7683 Date of Photo: 11/07/2024 Time of Photo: 12:17 hrs. Photographer: Vince Damiano Description: View of a full 55-gallon container storing used oil that was unlabeled observed on the process pad. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Action Oil Services, Inc. City: Vidor County/Parish: Orange State: Texas Photo No. 7 Photo File Name: DSCN7684 Date of Photo: 11/07/2024 Time of Photo: 12:17 hrs. Photographer: Vince Damiano Description: View of a quarter-full 55-gallon container storing used oil that was unlabeled observed on the process pad. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Action Oil Services, Inc. City: Vidor County/Parish: Orange State: Texas Photo No. 8 Photo File Name: DSCN7685 Date of Photo: 11/07/2024 Time of Photo: 12:18 hrs. Photographer: Vince Damiano Description: A view of spilled oil that was not cleaned up was found on the concrete pad in the processing area next to the hopper. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Action Oil Services, Inc. City: Vidor County/Parish: Orange State: Texas Photo No. 9 Photo File Name: DSCN7686 Date of Photo: 11/07/2024 Time of Photo: 12:29 hrs. Photographer: Vince Damiano Description: A view of another spill of oil that was not cleaned up was found on the concrete pad in the processing area next to the hopper. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Action Oil Services, Inc. City: Vidor County/Parish: Orange State: Texas Photo No. 10 Photo File Name: DSCN7687 Date of Photo: 11/07/2024 Time of Photo: 12:20 hrs. Photographer: Vince Damiano Description: View of a full 5-gallon container storing used oil that was unlabeled observed on the process pad. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Action Oil Services, Inc. City: Vidor County/Parish: Orange State: Texas Photo No. 11 Photo File Name: DSCN7688 Date of Photo: 11/07/2024 Time of Photo: 12:29 hrs. Photographer: Vince Damiano Description: Overview of the older tank farm found in the back of the facility in which there was no secondary containment system. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Action Oil Services, Inc. City: Vidor County/Parish: Orange State: Texas Photo No. 12 Photo File Name: DSCN7689 Date of Photo: 11/07/2024 Time of Photo: 12:29 hrs. Photographer: Vince Damiano Description: View of the tank used as an oil/water separator which was storing used oil and was not labeled "Used Oil." UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Action Oil Services, Inc. City: Vidor County/Parish: Orange State: Texas Photo No. 13 Photo File Name: DSCN7690 Date of Photo: 11/07/2024 Time of Photo: 12:31 hrs. Photographer: Vince Damiano Description: View of the drain in which water from the oil/water separator is discharged behind the facility. Note the two totes seen to the left were empty. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Action Oil Services, Inc. City: Vidor County/Parish: Orange State: Texas Photo No. 14 Photo File Name: DSCN7691 Date of Photo: 11/07/2024 Time of Photo: 12:31 hrs. Photographer: Vince Damiano Description: View of the drain in which water from the oil/water separator is discharged behind the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Action Oil Services, Inc. City: Vidor County/Parish: Orange State: Texas Photo No. 15 Photo File Name: DSCN7692 Date of Photo: 11/07/2024 Time of Photo: 12:31 hrs. Photographer: Vince Damiano Description: View of the drain in which water from the oil/water separator is discharged behind the facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Action Oil Services, Inc. City: Vidor County/Parish: Orange State: Texas Photo No. 16 Photo File Name: DSCN7693 Date of Photo: 11/07/2024 Time of Photo: 12:33 hrs. Photographer: Vince Damiano Description: Overview of the newly built tank farm containing ten used oil tanks that were actively storing used oil. None of the tanks were labeled "Used Oil." UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Action Oil Services, Inc. City: Vidor County/Parish: Orange State: Texas Photo No. 17 Photo File Name: DSCN7694 Date of Photo: 11/07/2024 Time of Photo: 12:33 hrs. Photographer: Vince Damiano Description: Overview of the newly built tank farm containing ten used oil tanks that were actively storing used oil; none of the tanks were labeled. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Action Oil Services, Inc. City: Vidor County/Parish: Orange State: Texas Photo No. 18 Photo File Name: DSCN7695 Date of Photo: 11/07/2024 Time of Photo: 12:33 hrs. Photographer: Vince Damiano Description: Overview of the process pad. A mixture of empty and non-empty 55-gallon drums with the filter press and hopper is seen in the top right corner. The blind sump runs horizontal across the middle of the process pad. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Action Oil Services, Inc. City: Vidor County/Parish: Orange State: Texas Photo No. 19 Photo File Name: DSCN7696 Date of Photo: 11/07/2024 Time of Photo: 12:33 hrs. Photographer: Vince Damiano Description: Overview of the process pad, the roll-off boxes are used to store non-hazardous debris. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Action Oil Services, Inc. City: Vidor County/Parish: Orange State: Texas Photo No. 20 Photo File Name: DSCN7697 Date of Photo: 11/07/2024 Time of Photo: 12:34 hrs. Photographer: Vince Damiano Description: View of the concrete berm surrounding the perimeter of the process pad. APPENDIX 2. PHOTOS FROM 11/18 RESPONSE Photograph provided by Action Oil on 11/18/2024 in response to AOCs Appendix 2 Page 1 of 4 Photograph provided by Action Oil on 11/18/2024 in response to AOCs Appendix 2 Page 2 of 4 Photograph provided by Action Oil on 11/18/2024 in response to AOCs Appendix 2 Page 3 of 4 Photograph of oil spills cleaned up provided by Action Oil on 11/18/2024 in response to AOCs Appendix 2 Page 4 of 4 APPENDIX 3. DISCHARGE WATER SAMPLE RESULTS APPENDIX 4. BLUE TIDE USED OIL TICKET AND SAMPLE RESULTS BTE INTERNAL REPORT PRODUCT NAME UMO: Pre-shipment Sample ID Customer Company Name Sample Information Sample Receiving Date B022409017 Action Oil Service, Lnc S9 09-09-2024 Report Date 9-9-2024 Test Test Method Min Max Results Density at 60F , lb/gal Density at 60F, g/mL Flash Point, PMCC PCBs Water Analysis Aluminum Arsenic Cadmium Calcium Chlorine Chromium Iron Lead Magnesium Nickel Phosphorus Silicon Sodium Sulfur Titanium Vanadium Zinc D4052 D4052 D93 Internal Internal D5185 D5185 D5185 D5185 D5185 D5185 D5185 D5185 D5185 D5185 D5185 D5185 D5185 D5185 D5185 D5185 D5185 Report Report 140 -- -- 2 Report Report -- 5 -- 2 Report -- 1000 -- 10 Report -- 100 Report Report -- 1500 -- 100 Report -- 5500 Report Report Report 7.253 0.8691 >140 ND 4.19 8.96 0.251 ND 996.0 38.7 0.807 54.1 3.71 281.0 0.722 593.0 31.7 61.1 2653.0 ND ND 655.0 Note: Data result - ND : below limit of detection or non detected Unit lb/gal g/ml F ppmw wt% ppmw ppmw ppmw ppmw ppmw ppmw ppmw ppmw ppmw ppmw ppmw ppmw ppmw ppmw ppmw ppmw ppmw Report reviewed by : Jody Cammack Comment : All results are within specification Comment ----------------------- APPENDIX 5. SPCC COVER SHEET AND FACILITY DRAWING APPENDIX 6. SECONDARY CONTAINMENT SYSTEM INSTALLED ON TANKS APPENDIX 7. ACTION OIL EMAIL RESPONSE FROM 11/18