Document n38Ee6Ljz530ZJNgn4LYx0pX

Inspection Date(s): Time: Program: Regulatory Program(s): If Access is Denied: REGION 10 Enforcement Division INSPECTION REPORT 06/09/2022 - 06/09/2022 Announced: No Entry: 08:15 AM (AKT) Exit: 02:45 PM (AKT) RCRA Title 40 - ENVIRONMENTAL PROTECTION AGENCY Company Name: Facility or Site Name: Facility/Site Physical Address: (City, state, zip code) Type of Operation: Size of Facility: Length of Facility at Location: Geographic Coordinates: Mailing address: (Secondary Address) Schlumberger Schlumberger Technology Corporation East Facility Building 27 Spine Road Prudhoe Bay, AK 99734 Contractor to the oil service companies, providing fracking, downhole tools, coil tubing services, and well cementing. 12 acres Since the early 1990s 70.22867, -148.382421 Ms. Kelly Sperbeck, Alaska HSE Manager 600 East 57th Place, Suite A Anchorage, AK 99518 ksperbeck@slb.com (City, state, zip code) County: Anchorage, AK 99518 Facility/Site Identifier: Media Number: NAICS: AKD000814012 N/A 213112 - Support Activities for Oil and Gas Operations Lead Inspector: Jon Jones Jones, Jon REGION 10 Digitally signed by Jones, Jon Date: 2022.08.05 10:17:17 -08'00' Jones.Jon@epa.gov (907) 271-6329 Additional Persons Participating in Inspection: Supervisor Review: Jen Sullivan Jennifer A Sullivan REGION 10 Digitally signed by Jennifer A Sullivan Date: 2022.08.08 08:21:21 -07'00' Sullivan.Jennifer.A@epa.gov (206) 553-6978 1 of 23 SCHLUMBERGER TECHNOLOGY CORPORATION EAST FACILITY Inspection Date(s): 06/09/2022 - 06/09/2022 SECTION I - INTRODUCTION Purpose of the Inspection/Objective Type of inspection: CEI - Compliance Evaluation Inspection This was a Resource Conservation and Recovery Act (RCRA) inspection. The facility was inspected to ensure compliance with standards for hazardous waste generators and universal waste management (40 C.F.R. Part 262 through 273) and used oil management (40 C.F.R. Part 279). The inspection was conducted as part of a Core Program requirement for FY 2022. Attendees Title Name Lead Inspector Jon Jones Phone 9072716329 Email Jones.Jon@epa.gov Present in Present in Opening Conf. Closing Conf. Yes Yes Alaska HSE Kelly Sperbeck (907) 273-1711 ksperbeck@slb.com Yes Yes Manager Facility Sam Muir (907) 268-7534 smuir2@slb.com Yes Yes Maintenance Field Specialist 2 Mike Hyatt (907) 227-9897 mhyatt@exchange.slb.com Yes No WS PSD Arnoldo Perez (907) 943-5045 aperez96@slb.com Yes No Manager Alaska General Nathan Rose (907) 273-1767 NRose1@slb.com No Yes Manager North America Alex Roberts (832) 328-3146 ACarey@slb.com No Yes Offshore HSE Manager Environmental Judy Carley (713) 724-1752 JCarley@slb.com No Yes and Regulatory Affairs Manager Opening Conference EPA Lead Inspector Jon Jones arrived at the Schlumberger Technology Corporation East Facility at 08:15 AM (AKT) on 06/09/2022 for an inspection. I presented my credentials to Arnoldo Perez and informed him that this was an EPA RCRA inspection. The table above presents all the inspection opening and closing conference participants. I was accompanied by Mr. Muir during the inspection of the facility. During the inspection I looked at the facility's processes, in addition to hazardous waste management practices, generation points, and accumulation areas. I looked for wastes that facility representatives had not yet identified or designated as hazardous. I also observed the facility's universal waste and used oil management. Specifically, I inspected the following areas of the facility listed below. Only those areas in which I observed areas of concern or noted other pertinent issues are discussed in this inspection report. 2 of 23 SCHLUMBERGER TECHNOLOGY CORPORATION EAST FACILITY Inspection Date(s): 06/09/2022 - 06/09/2022 Facility/Site Description Schlumberger Technology Corporation East Facility is a contractor to the oil service companies, providing fracking, downhole tools, coil tubing services, and well cementing. The facility is in Deadhorse, AK. Additional information can be found at slb.com. Facility Info Weather Conditions Cold and clear Safety Training No Provided to Inspector(s)? What type of SQG generator facility notified? What type of generator facility verified as? SQG initially verified by Kelly Sperbeck during the opening conference; however, at the end of the inspection the facility was determined to be a Very Small Quantity Generator (VSQG) Operating Hours 24/7, 365 with 12-hour shifts Number of employees 160 to 180 Process Description According to Mr. Muir the following waste streams are generated at the facility: Waste silver nitrate is generated in the QA/QC Lab and managed as hazardous waste. Waste fluorescent lamps are managed as universal waste. Waste batteries - lead acid, NiCad, lithium ion, all managed as universal waste. Waste aerosols - punctured, and residue is managed as hazardous waste. Aerosol cans are disposed with scrap metal. Used oil recycled through US Ecology (formerly NRC). Used antifreeze recycled through US Ecology (formerly NRC). Building(s) Building/Area/Sub-area Back shop Process Description Bulk plant where they store and load trucks with cement dry goods Area of Concern Yes Coil shop where they maintain coil equipment in a truck shop Acid Bay where they store and load acid for downhole well work. Generator room/electrical house. 3 of 23 SCHLUMBERGER TECHNOLOGY CORPORATION EAST FACILITY Inspection Date(s): 06/09/2022 - 06/09/2022 Coil shop Yes Cold storage storage of dry goods No Drilling and Measurement (D&M) Downhole tools Yes shop Clean, repair, test and send back to work. Can Popper area Aerosol residue SAA No Tool Rebuild shop Yes Utility Room Yes End of life battery Conex No Front shop Test Bay, wash Bay, and front offices. Yes Parts cage Pit bay/oil storage Gun shop QA/QC Lab Checking pressure and flow on equipment, Washing equipment. waste lamp and battery storage area Yes SAA for aerosol can residue. Yes Yes SAA for silver nitrate waste. No Cabinet adjacent to sink Very Special Building (VSB) Used for testing chloride content in water for cement fracking. SAA No Storage of engines, pump parts, and other misc No parts. SECTION II - OBSERVATIONS AND RECORDS REVIEW Observations Building: Back shop/Coil shop Observation #: JJ1-OB-006 Contains CBI: No Date: 06/09/2022 At the time of the inspection, I saw a 55-gallon container, marked with the word "BAD", that was approximately 1/3 full of an unknown liquid. Brian Goza, Bulk Plant, jostled the container and said it was about a third full. Neither Mr. Giza nor Mr. Muir knew what the container held. Photo(s) 1. IMG-202206091129552955984934.jpg 2. IMG-20220609113003303954204.jpg 3. IMG-2022060911301730171071868.jpg Building: Drilling and Measurement (D&M) shop/Tool Rebuild shop Observation #: JJ1-OB-005 Contains CBI: No Date: 06/09/2022 While inspecting the tool rebuild shop, within the D&M shop, I saw a 5-gallon bucket that held six punctured aerosol cans. At the time of the inspection, these aerosol cans did not look as though they had been punctured 4 of 23 SCHLUMBERGER TECHNOLOGY CORPORATION EAST FACILITY Inspection Date(s): 06/09/2022 - 06/09/2022 using the drum top can popper. They appeared as though they had been punctured using another type of tool. It was unknown as to where these aerosol cans were punctured, or how the contents of the cans was managed. Photo(s) 1. IMG-20220609110941941975446.jpg 2. IMG-20220609110948948900639.jpg 3. IMG-202206091109569561050568.jpg 4. IMG-202206091110231023978954.jpg Building: Drilling and Measurement (D&M) shop/Utility Room Contains CBI: No Observation #: JJ1-OB-004 Date: 06/09/2022 At the time of the inspection, I saw a 55-gallon container with attached aerosol can popper that was not closed, labeled with the words "Hazardous Waste," or marked with a hazard indicator. There was also an aerosol can on top of the container that had not yet been punctured. The aerosol can was not labeled with the words hazardous waste or marked with a hazard indicator. At the end of the inspection, it was determined that the facility was a Very Small Quantity Generator (VSQG) and the labeling and marking requirements for the containers of hazardous waste were not applicable. The facility provided documentation, following the inspection that the container had now been closed, labeled with the words "Hazardous Waste," and marked with a hazard indicator. I also saw a 55-gallon poly container that was being used to accumulate used oil. At the time of the inspection, the container was not labeled with the words "Used Oil." The container held approximately 10-gallons of used oil, based on jostling the container. The facility provided documentation (see Document Log) following the inspection that the container had been labeled with the words "Used Oil." Brad Shumate, Maintenance Supervisor, was the person in charge of this area. Photo(s) 1. IMG-202206091035383538661751.jpg 2. IMG-202206091035573557743270.jpg 3. IMG-202206091036133613823957.jpg 4. IMG-202206091037323732847446.jpg 5. IMG-202206091037423742894576.jpg 6. IMG-202206091037573757935076.jpg 7. IMG-202206091042454245733889.jpg 8. IMG-202206091042544254693513.jpg Building: Front shop/Parts cage Observation #: JJ1-OB-001 Contains CBI: No Date: 06/09/2022 At the time of the inspection, I saw an open cardboard box that according to Mr. Muir, contained waste fluorescent lamps. The container held eight loose lamps and a box that contained additional lamps. The box held 22 lamps. The container was labeled with the words "Universal Waste -lamps", but it was not closed. 5 of 23 SCHLUMBERGER TECHNOLOGY CORPORATION EAST FACILITY Inspection Date(s): 06/09/2022 - 06/09/2022 I also saw nine boxes that held lead acid batteries and they were packaged and labeled "Used batteries." I also saw a small cardboard box, that held between 25 and 30 Ni-Cad batteries, that was on top of a larger wooden box that also held an additional six Ni-Cad batteries and ten small lead acid batteries. Neither of the two boxes were labeled with the words Universal Waste-batteries, Waste-batteries, or Used-batteries. The facility provided documentation (see Document Log) following the inspection that the boxes had been labeled with the words "Universal Waste - Batteries." Photo(s) 1. IMG-202206090933183318997117.jpg 2. IMG-2022060909332733271058791.jpg 3. IMG-2022060909333733371055595.jpg 4. IMG-202206090934123412881032.jpg 5. IMG-202206090934193419823949.jpg Building: Front shop/Pit Bay/oil storage Observation #: JJ1-OB-002 Contains CBI: No Date: 06/09/2022 At the time of the inspection, I saw a 55-gallon container with an attached aerosol can popper. According to Mr. Muir, the container was a SAA container for aerosol can residue. I saw that the container was labeled with the words "Satellite Containment." The container was not labeled with the words "Hazardous Waste," or marked with a hazard indicator. The facility manages the punctured aerosol cans as scrap metal, and they accumulate the cans in a metal trash can prior to recycling. At the end of the inspection, it was determined that the facility was a VSQG and the labeling and marking requirements for the containers of hazardous waste were not applicable. The facility provided documentation, following the inspection (see Document Log) that the container had been closed, labeled with the words "Hazardous Waste," and marked with a hazard indicator. The facility had an oil filter crusher and I saw an open 5-gallon bucket that was being used to accumulate the used oil from the filter crusher. At the time of the inspection, the 5-gallon bucket was not labeled with the words "Used Oil." The container was approximately 1/3 full of used oil. The facility provided documentation (see Document Log), following the inspection that the container had been labeled with the words "Used Oil." Photo(s) 1. IMG-202206090947354735918850.jpg 2. IMG-202206090947444744916667.jpg 3. IMG-20220609094805485996350.jpg 4. IMG-202206090951005101061318.jpg 5. IMG-20220609095106516988036.jpg 6. IMG-2022060909551155111013425.jpg 7. IMG-2022060909551855181076229.jpg 8. IMG-202206090955245524933878.jpg Building: Gun shop Contains CBI: No 6 of 23 SCHLUMBERGER TECHNOLOGY CORPORATION EAST FACILITY Inspection Date(s): 06/09/2022 - 06/09/2022 Observation #: JJ1-OB-007 Date: 06/09/2022 While in the Gun shop, I saw a small box of waste batteries. While inspecting the contents of the box, I saw three Ni-Cad batteries that were not labeled as "Universal Waste-battery," "Waste-Battery," or "Used-Battery." While at the Gun shop, I was told by Robert Gumminger, Schlumberger TCP General Field Specialist, that waste explosives are generated periodically in amounts that push the facility's generator status up to that of a Large Quantity Generator. When this occurs, the facility uses the option of episodic generation to manage the waste explosives. Mr. Gumminger provided copies of the paperwork associated with their last episodic generation event which is listed in the document log of this report. Photo(s) 1. IMG-202206091345324532518311.jpg 2. IMG-202206091345394539620333.jpg Building: QA/QC Lab/Cabinet adjacent to sink Contains CBI: No Observation #: JJ1-OB-003 Date: 06/09/2022 Roarke Burnett, Lab Technician, was the person in charge of this area. At the time of the inspection, Mr. Burnett pulled a waste silver nitrate container from out of a cabinet. The container was a 5-gallon bucket that held a 1-gallon cube-tainer. The container was not labeled with the words "Hazardous Waste," or marked with a hazard indicator. Mr. Burnett labeled the cube-trainer during the inspection. At the end of the inspection, it was determined that the facility was a VSQG and the labeling and marking requirements for the containers of hazardous waste were not applicable. Photo(s) 1. IMG-202206091020272027817392.jpg 2. IMG-202206091020332033684936.jpg 3. IMG-202206091020482048443875.jpg 4. IMG-202206091023342334592400.jpg 5. IMG-202206091023392339360947.jpg Records Review At the time of the inspection the facility was determined to be a VSQG, and no paperwork was reviewed. However, paperwork regarding episodic generation was obtained from the facility and is listed in the document log. SECTION III - AREAS OF CONCERN The presentation of areas of concern does not constitute a formal compliance determination or violation. Building: Back shop JJ1-OB-006 Area: Coil shop Sub-area: A 55-gallon container was approximately 1/3 full of an Citations: 7 of 23 Sections: SCHLUMBERGER TECHNOLOGY CORPORATION EAST FACILITY Inspection Date(s): unknown liquid. Neither Mr. Giza nor SM knew what the container held. Building: Drilling and Measurement (D&M) shop JJ1-OB-005 262.11 Area: Tool Rebuild shop A 5-gallon bucket held six punctured aerosol cans. The aerosol cans did not look as though they had been punctured using the drum top can popper. They appeared as though they had been punctured using another type of tool. It was unknown as to where these aerosol cans were punctured or how the contents of the cans were managed. Citations: Under review Building: Drilling and Measurement (D&M) shop JJ1-OB-004 Area: Utility Room A 55-gallon poly container was being used to accumulate used oil. ATI, the container had approximately 10 gallons of used oil in it and was not labeled with the words "Used Oil." Citations: 279.22(c)(1) Building: Front shop JJ1-OB-002 Area: Pit Bay/oil storage An open 5-gallon bucket was being used to accumulate the used oil from the filter crusher. The 5-gallon bucket was not labeled with the words "Used Oil." The container was approximately 1/3 full of used oil. Citations: 279.22(c)(1) Building: Front shop JJ1-OB-001 Area: Parts cage 8 of 23 06/09/2022 - 06/09/2022 Sub-area: Sections: Sub-area: Sections: Sub-area: Sections: Sub-area: SCHLUMBERGER TECHNOLOGY CORPORATION EAST FACILITY Inspection Date(s): There was an open cardboard box that contained 22 waste fluorescent lamps. The container was not closed. Citations: 273.13(d)(1) A small cardboard box that held between 25 and 30 NiCad batteries was on top of a larger wooden box that also held an additional six Ni-Cad batteries and 10 small lead acid batteries. Neither of the two boxes were labeled with the words "Universal Wastebatteries," "Waste-Batteries," or "Used-Batteries." Citations: 273.14(a) Building: Gun shop JJ1-OB-007 Area: A box containing three waste Ni-Cad batteries was not labeled as "Universal Wastebatteries," "Waste-Batteries," or "Used-Batteries." Citations: 273.14(a) SECTION IV - FOLLOW UP N/A 06/09/2022 - 06/09/2022 Sections: Sections: Sub-area: Sections: Closing Conference SECTION V - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS - No sampling was conducted. 9 of 23 SCHLUMBERGER TECHNOLOGY CORPORATION EAST FACILITY Inspection Date(s): SECTION VI - LIST OF APPENDICES Photo Log [Title] IMG-2022060909392539251100599.jpg 06/09/2022 09:39 AM (AKT) Jon Jones Front shop/Parts cage No CBI No PII View of signage on the cage, as well as the open box of waste lamps. [Title] IMG-202206091039543954843627.jpg 06/09/2022 10:39 AM (AKT) Jon Jones Drilling and Measurement (D&M) shop/Utility Room No CBI No PII View of the open bung on the container and the open puncturing device. 06/09/2022 - 06/09/2022 10 of 23 SCHLUMBERGER TECHNOLOGY CORPORATION EAST FACILITY Inspection Date(s): [Title] IMG-202206091039593959610271.jpg 06/09/2022 10:39 AM (AKT) Jon Jones Drilling and Measurement (D&M) shop/Utility Room No CBI No PII Another view of the open bung on the container. [Title] IMG-202206091129552955984934.jpg 06/09/2022 11:29 AM (AKT) Jon Jones Back shop/Coil shop No CBI No PII View of 55-gallon container, seen here marked with the word "BAD," that was approximately 1/3 full of an unknown liquid. [Title] IMG-20220609113003303954204.jpg 06/09/2022 11:30 AM (AKT) Jon Jones Back shop/Coil shop No CBI No PII Another view of 55-gallon container, seen here marked with the word "BAD," that was approximately 1/3 full of an unknown liquid. 06/09/2022 - 06/09/2022 11 of 23 SCHLUMBERGER TECHNOLOGY CORPORATION EAST FACILITY Inspection Date(s): [Title] IMG-2022060911301730171071868.jpg 06/09/2022 11:30 AM (AKT) Jon Jones Back shop/Coil shop No CBI No PII Close-up view of 55-gallon container, seen here marked with the word "BAD," that was approximately 1/3 full of an unknown liquid. [Title] IMG-20220609110941941975446.jpg 06/09/2022 11:09 AM (AKT) Jon Jones Drilling and Measurement (D&M) shop/Tool Rebuild shop No CBI No PII View of 5-gallon bucket that held six punctured aerosol cans. [Title] IMG-20220609110948948900639.jpg 06/09/2022 11:09 AM (AKT) Jon Jones Drilling and Measurement (D&M) shop/Tool Rebuild shop No CBI No PII Another view of 5-gallon bucket that held six punctured aerosol cans. 06/09/2022 - 06/09/2022 12 of 23 SCHLUMBERGER TECHNOLOGY CORPORATION EAST FACILITY Inspection Date(s): [Title] IMG-202206091109569561050568.jpg 06/09/2022 11:09 AM (AKT) Jon Jones Drilling and Measurement (D&M) shop/Tool Rebuild shop No CBI No PII Close-up view of the punctured aerosol cans, showing the large puncture holes. [Title] IMG-202206091110231023978954.jpg 06/09/2022 11:10 AM (AKT) Jon Jones Drilling and Measurement (D&M) shop/Tool Rebuild shop No CBI No PII Another close-up view of the punctured aerosol cans, showing the large puncture holes. [Title] IMG-202206091035383538661751.jpg 06/09/2022 10:35 AM (AKT) Jon Jones Drilling and Measurement (D&M) shop/Utility Room No CBI No PII View of 55-gallon container with attached can popper that is open. 13 of 23 06/09/2022 - 06/09/2022 SCHLUMBERGER TECHNOLOGY CORPORATION EAST FACILITY Inspection Date(s): [Title] IMG-202206091035573557743270.jpg 06/09/2022 10:35 AM (AKT) Jon Jones Drilling and Measurement (D&M) shop/Utility Room No CBI No PII Another view of 55-gallon container with attached can popper that is open. [Title] IMG-202206091036133613823957.jpg 06/09/2022 10:36 AM (AKT) Jon Jones Drilling and Measurement (D&M) shop/Utility Room No CBI No PII Close-up view of 55-gallon container with attached can popper that is open. [Title] IMG-202206091037323732847446.jpg 06/09/2022 10:37 AM (AKT) Jon Jones Drilling and Measurement (D&M) shop/Utility Room No CBI No PII Another view of 55-gallon container with attached can popper that is open. 14 of 23 06/09/2022 - 06/09/2022 SCHLUMBERGER TECHNOLOGY CORPORATION EAST FACILITY Inspection Date(s): [Title] IMG-202206091037423742894576.jpg 06/09/2022 10:37 AM (AKT) Jon Jones Drilling and Measurement (D&M) shop/Utility Room No CBI No PII Another view of 55-gallon container with attached can popper that is open. [Title] IMG-202206091037573757935076.jpg 06/09/2022 10:37 AM (AKT) Jon Jones Drilling and Measurement (D&M) shop/Utility Room No CBI No PII Another view of 55-gallon container with attached can popper that is open. [Title] IMG-202206091042454245733889.jpg 06/09/2022 10:42 AM (AKT) Jon Jones Drilling and Measurement (D&M) shop/Utility Room No CBI No PII View of 55-gallon poly container that was being used to accumulate used oil. The container is seen here not labeled with the words "Used Oil." 15 of 23 06/09/2022 - 06/09/2022 SCHLUMBERGER TECHNOLOGY CORPORATION EAST FACILITY Inspection Date(s): [Title] IMG-202206091042544254693513.jpg 06/09/2022 10:42 AM (AKT) Jon Jones Drilling and Measurement (D&M) shop/Utility Room No CBI No PII Another view of 55-gallon poly container that was being used to accumulate used oil. The container is seen here not labeled with the words "Used Oil." [Title] IMG-202206090933183318997117.jpg 06/09/2022 09:33 AM (AKT) Jon Jones Front shop/Parts cage No CBI No PII View of cardboard box that contains waste fluorescent lamps and is not closed. [Title] IMG-2022060909332733271058791.jpg 06/09/2022 09:33 AM (AKT) Jon Jones Front shop/Parts cage No CBI No PII Another view of cardboard box that contains waste fluorescent lamps and is not closed. 06/09/2022 - 06/09/2022 16 of 23 SCHLUMBERGER TECHNOLOGY CORPORATION EAST FACILITY Inspection Date(s): [Title] IMG-2022060909333733371055595.jpg 06/09/2022 09:33 AM (AKT) Jon Jones Front shop/Parts cage No CBI No PII Another view of cardboard box that contains waste fluorescent lamps and is not closed. [Title] IMG-202206090934123412881032.jpg 06/09/2022 09:34 AM (AKT) Jon Jones Front shop/Parts cage No CBI No PII View of two boxes of waste batteries, seen here on the left. Neither of the two boxes were labeled. [Title] IMG-202206090934193419823949.jpg 06/09/2022 09:34 AM (AKT) Jon Jones Front shop/Parts cage No CBI No PII Another view of the two boxes of waste batteries. Neither of the two boxes were labeled. 06/09/2022 - 06/09/2022 17 of 23 SCHLUMBERGER TECHNOLOGY CORPORATION EAST FACILITY Inspection Date(s): [Title] IMG-202206090947354735918850.jpg 06/09/2022 09:47 AM (AKT) Jon Jones Front shop/Pit Bay/oil storage No CBI No PII View of 55-gallon container with an attached can popper. [Title] IMG-202206090947444744916667.jpg 06/09/2022 09:47 AM (AKT) Jon Jones Front shop/Pit Bay/oil storage No CBI No PII Another view of 55-gallon container with an attached can popper. [Title] IMG-20220609094805485996350.jpg 06/09/2022 09:48 AM (AKT) Jon Jones Front shop/Pit Bay/oil storage No CBI No PII Another view of 55-gallon container with an attached can popper. 06/09/2022 - 06/09/2022 18 of 23 SCHLUMBERGER TECHNOLOGY CORPORATION EAST FACILITY Inspection Date(s): [Title] IMG-202206090951005101061318.jpg 06/09/2022 09:51 AM (AKT) Jon Jones Front shop/Pit Bay/oil storage No CBI No PII View of punctured aerosol cans in trash can, adjacent to the oil filter crusher which is between the trash can and the container with attached can popper. [Title] IMG-20220609095106516988036.jpg 06/09/2022 09:51 AM (AKT) Jon Jones Front shop/Pit Bay/oil storage No CBI No PII Another view of the punctured aerosol cans. [Title] IMG-2022060909551155111013425.jpg 06/09/2022 09:55 AM (AKT) Jon Jones Front shop/Pit Bay/oil storage No CBI No PII View of 5-gallon bucket that was being used to accumulate the used oil from the filter crusher. The 5-gallon bucket was not labeled with the words "Used Oil." The container was approximately 1/3 full of used oil. 19 of 23 06/09/2022 - 06/09/2022 SCHLUMBERGER TECHNOLOGY CORPORATION EAST FACILITY Inspection Date(s): [Title] IMG-2022060909551855181076229.jpg 06/09/2022 09:55 AM (AKT) Jon Jones Front shop/Pit Bay/oil storage No CBI No PII Another view of the 5-gallon bucket that was being used to accumulate the used oil from the filter crusher and seen here, not labeled with the words "Used Oil." [Title] IMG-202206090955245524933878.jpg 06/09/2022 09:55 AM (AKT) Jon Jones Front shop/Pit Bay/oil storage No CBI No PII Close-up view of the 5-gallon bucket that was being used to accumulate the used oil from the filter crusher and seen here, not labeled with the words "Used Oil." [Title] IMG-202206091345324532518311.jpg 06/09/2022 01:45 PM (AKT) Jon Jones Gun shop No CBI No PII View of box containing waste batteries that is not labeled with the words, "Universal WasteBatteries," "Waste-Batteries," or "UsedBatteries." 20 of 23 06/09/2022 - 06/09/2022 SCHLUMBERGER TECHNOLOGY CORPORATION EAST FACILITY Inspection Date(s): [Title] IMG-202206091345394539620333.jpg 06/09/2022 01:45 PM (AKT) Jon Jones Gun shop No CBI No PII Another view of box containing waste batteries that is not labeled with the words, "Universal Waste-Batteries," "Waste-Batteries," or "UsedBatteries." [Title] IMG-202206091020272027817392.jpg 06/09/2022 10:20 AM (AKT) Jon Jones QA/QC Lab/Cabinet adjacent to sink No CBI No PII View of silver nitrate waste container from the cabinet. [Title] IMG-202206091020332033684936.jpg 06/09/2022 10:20 AM (AKT) Jon Jones QA/QC Lab/Cabinet adjacent to sink No CBI No PII View of the container that held a 1-gallon cubetainer of the waste silver nitrate. 06/09/2022 - 06/09/2022 21 of 23 SCHLUMBERGER TECHNOLOGY CORPORATION EAST FACILITY Inspection Date(s): [Title] IMG-202206091020482048443875.jpg 06/09/2022 10:20 AM (AKT) Jon Jones QA/QC Lab/Cabinet adjacent to sink No CBI No PII View of the cube-tainer of waste silver nitrate. 06/09/2022 - 06/09/2022 [Title] IMG-202206091023342334592400.jpg 06/09/2022 10:23 AM (AKT) Jon Jones QA/QC Lab/Cabinet adjacent to sink No CBI No PII View of the cube-tainer after being labeled. [Title] IMG-202206091023392339360947.jpg 06/09/2022 10:23 AM (AKT) Jon Jones QA/QC Lab/Cabinet adjacent to sink No CBI No PII Close-up view of the cube-tainer after being labeled. Document Log Document Type Facility Map Document Name Facility Map.pdf Contains Contains Uploaded By CBI PII No No Jon Jones 22 of 23 Date Received 07/21/2022 SCHLUMBERGER TECHNOLOGY CORPORATION EAST FACILITY Inspection Date(s): 06/09/2022 - 06/09/2022 Other - SDS - Wireline SDS for unknown fluid.pdf Lubricant No No Jon Jones Manifests October 2020 Waste Manifests.pdf No No Jon Jones Other - Episodic generation paperwork 8700-12 for episodic gen.pdf No No Jon Jones Manifests Non-haz manifest 168920A.pdf No No Jon Jones Manifests Non-haz manifest 178659A.pdf No No Jon Jones Communications EPA Follow Up.docx No No Jon Jones Communications FW_ [Ext] Oil .pdf No No Jon Jones Communications FW_ [Ext] Paint .pdf No No Jon Jones Communications RE_ [Ext] RE_ SLB Requested information.pdf No No Jon Jones Communications Schlumberger Follow up EPA ID_ No No Jon Jones AKD000814012 .pdf 07/21/2022 07/21/2022 07/21/2022 07/21/2022 07/21/2022 07/21/2022 07/21/2022 07/21/2022 07/21/2022 07/21/2022 23 of 23