Document pGVQQ18VNaqeBwyr8xjKKj8E

Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 6 Enforcement Division INSPECTION REPORT 4/18/2024 02:45 PM (CT) 4/18/2024 03:50 PM (CT) Closing Conference RCRA Focused Compliance Inspection (FCI) Announced: No Access: Granted Facility or Site Name Facility/Site Identifier Facility/Site Physical Address City, State, Zip Code County/Borough Generator Status NAICS +Type of Operation Geographic Coordinates Mailing Address/Secondary Address City, State, Zip Code ES&H LAR000037069 21148 LA Route 1 Golden Meadow, LA 70357 Lafourche Parish Transporter 488510 Freight Transportation Arrangement 29.34477, -90.24761 1730 Coteau Rd (main offices) Houma, LA 70364 Permit Number (If Applicable) Not Applicable Additional Persons Participating in Inspection: Name Title Organization Email Phone Joyce Johnson Inspector EPA Region 6 Johnson.Joyce-r6@epa.gov (214) 665-8548 Dedriel Gardner Inspector EPA Region 6 Gardner.Dedriel@epa.gov (281) 983-2133 George Wieber Contractor Eastern Research George.Wieber@erg.com 443-883-5253 Group (ERG) Lead Inspector: Brook McKeown ERG Brook.McKeown@erg.com 9/11/2024 (410) 459-5811 Page 1 of 6 ES&H SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection Inspection Date: 04/18/2024 The Port Fourchon 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 Error! Reference source not found.), verbal or written statements made during or after the on-site inspection, and/or materials shown, demonstrated, or submitted to the EPA during or after the on-site inspection. In addition, information gathered prior to or after the inspection from a review of EPA, State, and public records may be included in this report. Attendees Title/Organization Name Lead Inspector/ Contactor/ERG Brook McKeown RCRA Inspector/ Contractor/ERG George Wieber Inspector/Enforcement Joyce Officer/EPA Region 6 Johnson Inspector/Enforcement Dedriel Officer/EPA Region 6 Gardner Phone Email (410) 459-5811 Brook.McKeown@erg.com Opening Conf. Yes Closing Conf. Yes 443-883-5253 George.Wieber@erg.com Yes Yes (214) 665-8548 Johnson.Joyce-r6@epa.gov Yes Yes (281) 983-2133 Gardner.Dedriel@epa.gov Yes Yes Page 2 of 6 ES&H Inspection Date: 04/18/2024 Facility General Description Tenant/Area ES&H Inspection Process Description Date 4/18/24 ES&H provides emergency response, tank cleaning, spill cleanup, and equipment maintenance services for port operations. ES&H puts used cleanup supplies and wastes into containers at the client site and transports them offsite to a destination facility for disposal. Occasionally, ES&H will bring the wastes back to its site temporarily as a transfer area. ES&H serves as a hazardous waste transporter, with its EPA ID associated with its Houma, LA location. The facility visited during this inspection is located in Golden Meadow, LA and does not maintain a MARPOL COA. Area of Concern No Page 3 of 6 ES&H Inspection Date: 04/18/2024 SECTION II - OBSERVATIONS Tenant: ES&H Section: 2 Date: 4/18/2024, 2:45 P.M. Contains AOC: No Contains CBI: No Lead Inspector: Brook McKeown Attendees: Lewis Walker (Supervisor/Technician) Mr. Walker, a Supervisor for ES&H, provided the inspection team with a brief overview of company operations as well as site-specific operations at the Golden Meadow, LA location. ES&H provides a variety of services to clients at Port Fourchon, including tank cleaning, spill response and cleanup, equipment maintenance, and stand-by support. Mr. Walker stated that any hazardous waste generated during cleanup or spill response activities is accumulated at the customer site, and ES&H will transport the waste off the customer site to a designated facility, with the customer listed as the generator on the manifest. Mr. Walker stated that ES&H will sometimes bring containers of waste back from the customer site to the ES&H site in Golden Meadow, LA for transfer, and the containers would remain on site no longer than a week. The ES&H site also uses frac tanks to temporarily store raw material, fuel, or bilge water for customers. Mr. Walker stated that the Golden Meadow, LA site may temporarily stage these frac tanks before returning to customers. ES&H will use third parties to clean out and take any washwater when the frac tanks are cleaned if the customer does not want to keep the washwater for recovering materials. ES&H is registered as a transporter for hazardous waste with an EPA ID LAR000037069. After the opening meeting with Mr. Walker, the inspection team conducted a visual inspection of the site at approximately 3:30 PM. The Golden Meadow, LA site does not have a dock or direct waterfront access from the property. The inspection team observed the supply and storage warehouse and an outdoor area, and no containers of hazardous waste were observed on site at the time of the inspection. There were four frac tanks present on site which were either empty or contained customer product or fuel for temporary storage. The inspection team did not observe any apparent AOCs at the time of the inspection; however, further EPA review may add to the facility's potential AOCs. The inspection team did not request further documentation and departed the facility at approximately 3:50 PM. Mr. Walker provided contact information for corporate personnel at the ES&H Houma, LA location for any additional questions. Inspector McKeown called the contact number provided following the inspection but did not get a response. 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. The inspection team did not identify apparent areas of concern while on site at ES&H in Golden Meadow, LA. Page 4 of 6 ES&H Inspection Date: 04/18/2024 SECTION V - FOLLOW UP EPA did not request additional documentation from ES&H and did not identify apparent areas of concern during the inspection. ES&H did not send any follow-up email or correspondence related to this inspection. Page 5 of 6 ES&H SECTION VI - LIST OF APPENDICES None. Inspection Date: 04/18/2024 Page 6 of 6