Document r88x5Z3k51z5m5YgM5xG0MM0

Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 6 Enforcement Division INSPECTION REPORT 6/6/2024 9:00 AM (CT) 6/6/2024 11:00 AM (CT) RCRA Focused Compliance Inspection (FCI) Announced: No Access: Granted Facility or Site Name Facility/Site Identifier Facility/Site Physical Address City, State, Zip Code County/Borough Generator Status NAICS Type of Operation Geographic Coordinates Environmental Safety & Health Consulting Services, Inc. LAR000037069 1730 Coteau Rd Houma, LA 70364 Terrebonne Parish Non-generator 488510 Environmental Safety & Health Consulting Services, Inc. provides spill response, vessel and tank cleaning, and waste transportation services. 29.626515, -90.695907 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 Neil Rapp Contractor Eastern Research Neil.Rapp@erg.com Group (ERG) (480) 450-6517 Lead Inspector: Vince Damiano Vincent Damiano ERG Digitally signed by Vincent Damiano Date: 2024.09.09 17:49:44 -04'00' Vince.Damiano@erg.com (703) 835-6281 1 of 6 Environmental Safety & Health Consulting Services, Inc. Inspection Date: 06/06/2024 SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection Type of inspection: Focused Compliance Inspection (FCI) 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 maintaining 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 verbal or written statements made during or after the on-site 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. Attendees Title/Organization Name Lead Inspector/ Contactor/ERG RCRA Inspector/ Contractor/ERG Inspector/Enforcement Officer/EPA Region 6 Inspector/Enforcement Officer/EPA Region 6 Vince Damiano Neil Rapp Joyce Johnson Dedriel Gardner Phone Email (703) 835-6281 Vince.Damiano@erg.com Opening Conf. Yes Closing Conf. Yes (480) 450-6517 Neil.Rapp@erg.com Yes Yes (214) 665-8548 Johnson.Joyce-r6@epa.gov Yes Yes (281) 983-2133 Gardner.Dedriel@epa.gov Yes Yes 2 of 6 Environmental Safety & Health Consulting Services, Inc. Inspection Date: 06/06/2024 Facility General Description Tenant/Area Environmental Safety & Health Consulting Services, Inc. Inspection Date 06/06/24 Process Description Areas of Concern Environmental Safety & Health Consulting Services, Inc. Yes (ES&H) provides spill response, vessel and tank cleaning, and waste transportation services. ES&H's waste transportation services are managed by its Houma, Louisiana facility. The company serves as a hazardous and non-hazardous waste transporter. Waste generated by ES&H during spill response and cleaning activities remains at its clients' sites until it has been characterized and profiled for disposal. After the waste is profiled, ES&H transports it to the proper disposal facility. ES&H's Houma location does not operate a 10-day hazardous waste transfer facility and no hazardous waste remains onsite for longer than 24 hours. Facility personnel stated that ES&H is a non-generator of hazardous waste. ES&H does not maintain a MARPOL COA. 3 of 6 Environmental Safety & Health Consulting Services, Inc. Inspection Date: 06/06/2024 SECTION II - OBSERVATIONS Tenant: Environmental Safety & Health Consulting Services, Inc. Section: 2.1 Date: 6/6/2024, 9:00 A.M. Contains AOC: Yes Contains CBI: No Lead Inspector: Vince Damiano Attendees: Jake Pellegrin (HSE), Kyle Frazier (HSE), Sara Carlson (HSE) ES&H provides spill response, vessel and tank cleaning, and waste transportation services. ES&H's waste transportation services are managed by its Houma, Louisiana facility. Waste generated from spill response activities or during vessel and tank cleaning is managed at its customers' sites. ES&H owns frac tanks and roll-offs which it deploys to customers' sites for managing liquid and solid waste, respectively. After the waste has been profiled, it is transported by ES&H to the selected disposal facility. ES&H's customers are considered to be the generators of the waste and, if required, are responsible for signing hazardous waste manifests as the generator. The company's truck fleet includes tanker trucks and vac trucks for transporting liquid waste (i.e., wash water from tank cleanings) as well as roll-off trucks for transporting solid waste (i.e., oily absorbent, contaminated soil from spill response activities). ES&H is registered as a hazardous waste and used oil transporter (LAR000037069); however, facility personnel stated that ES&H does not transport used oil. Facility personnel said that hazardous waste is transported directly from clients' sites to the selected disposal facilities. They added that the only time hazardous waste is onsite at ES&H's Houma facility is when it is too late in the day to transport it to the selected disposal facility, or the driver is out of hours. Facility personnel stated that hazardous waste is never kept onsite for longer than 24 hours. ES&H is certified by USCG to perform over the water transfers from vessels to trucks, but the company does not have its own dock operations and does not maintain a MARPOL COA. ES&H personnel stated that the Houma facility is a non-generator of hazardous waste. The facility does generate used oil from maintenance on its truck fleet, as well as used batteries which it manages as universal waste. ES&H also has a parts washer in its maintenance shop with the facility managing the disposal of the used solvent. After the opening conference, the inspection team conducted a visual inspection of the facility. Observations and areas of concern (AOCs) are listed below. Storage Yard: The inspection team observed a gray frac tank (FT-7033) in the yard labeled with a blank hazardous waste label. The inspection team opened the hatch on top of the frac tank and observed it contained approximately 750 gallons of liquid with a strong petroleum odor (see Appendix 1 - Photos 1 through 4). The inspection team opened a second frac tank (FT-6333) and observed it contained approximately one foot of liquid and sludge with a strong petroleum odor; neither frac tank was stored in secondary containment (see Appendix 1 - Photos 5 and 6. At the time of the inspection, ES&H personnel stated that they could not identify the material inside the two frac tanks. [AOC #1: ES&H did not make a hazardous waste determination for the material in two nonempty frac tanks being stored at its facility - 40 CFR 262.11]. Truck Maintenance Shop: The inspection team observed six unlabeled partially full drums of used oil inside the facility's truck maintenance shop (see Appendix 1 - Photos 7, 8, 9, and 11). [AOC #2 - ES&H did not clearly label containers used to store used oil with the words "Used Oil" - 40 CFR 279.22(c)(1)]. The inspection team also observed one full and one partially full drum of hot drained used oil filters (see Appendix 1 - Photo 10). Although the used oil filters were hot drained, they were not hot drained using one of the methods required by 40 CFR 261.4(b)(13) to claim the hazardous waste exemption for non-terne plated oil filters. The drums should therefore have been labeled with the words "Used Oil" [See AOC #2] During the visual inspection, the inspection team asked facility personnel how used aerosol cans were managed at the facility. They responded that used aerosol cans were currently being 4 of 6 Environmental Safety & Health Consulting Services, Inc. Inspection Date: 06/06/2024 disposed of as municipal waste and that ES&H had not completed a hazardous waste determination for its used aerosol cans (see AOC# 1 above). After the visual inspection, the inspection team requested the following information from ES&H: The last ten hazardous waste manifest for waste transported by ES&H in 2024 (see Appendix 2). The inspection team reviewed the manifests provided by ES&H. The inspection team observed that hazardous waste shipped on Manifest #017987483FLE had been received at ES&H and held onsite for longer than 10 days before being shipped offsite for disposal (see Appendix 2) [AOC #3: ES&H stored hazardous waste for longer than 10 days while operating as a hazardous waste transfer facility- 40 CFR 263.12(a)]. Shipping documentation for the last load held in frac tanks FT-7033 and 6333 (see Appendix 3). Information on the contents remaining in frac tanks FT-7033 and 6333 (not provided). Information (i.e., SOP) on how ES&H cleans the frac tanks at its site (see Appendix 4). The shipping documentation for the last ten loads of cleaning waste from cleaning frac tanks and any related analytical (not provided). Shipping documentation for the disposal of used parts washer solvent and a waste determination for the material (not provided) Any responses to the AOCs identified during the visual inspection (see Appendix 5). The inspection team did not observe any other apparent 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 10:55 AM with ES&H personnel. The AOCs were communicated to ES&H during the closing conference. SECTION III - RECORDS REVIEW No RCRA regulated records were reviewed during this focused onsite inspection besides those mentioned in Section II. SECTION IV - AREA OF CONCERN The presentation of AOCs does not constitute a formal compliance determination or violation. Tenant: Environmental Safety & Health Consulting Services, Inc. AOC #1 - ES&H did not make a Citation: 40 CFR 262.11 hazardous waste determination for the material in two frac tanks at its yard or for the used aerosol cans being generated at its facility. AOC #2 - ES&H did not clearly Citation: 40 CFR 279.22(c)(1) label containers used to store used oil with the words "Used Oil". AOC #3 - ES&H stored hazardous Citation: 40 CFR 263.12(a) waste for longer than 10 days while operating as a hazardous waste transfer facility. SECTION V -FOLLOW UP Section: 2.1 Section: 2.1 Section: 2.1 5 of 6 Environmental Safety & Health Consulting Services, Inc. Inspection Date: 06/06/2024 Documents or files provided by the facility were transmitted via a file transfer protocol (FTP) link provided by ERG following the inspection. 6 of 6 Environmental Safety & Health Consulting Services, Inc. Inspection Date: 06/06/2024 Communication Log After the inspection, additional information was provided to EPA including: 1. 7/3/2024 - ES&H uploaded its last ten hazardous waste manifests, manifests for the last loads held in frac tanks FT-7033 and FT-6333, frac tank cleaning SOP, and follow-up to the AOCs identified during the inspection to the FTP site. SECTION VI - LIST OF APPENDICES Appendix 1 - Photograph Log Appendix 2 ES&H Hazardous Waste Manifests Appendix 3 Manifests for Last Load in Frac Tanks FT-7033 and FT-6333 Appendix 4 ES&H Frac Tank Cleaning SOP Appendix 5 ES&H Response to AOCs 7 of 6 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Appendix 1 Photograph Log UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: Environmental Safety & Health Consulting Services, Inc. City: Houma County/Parish: Terrebonne State: Louisiana Photo File Name: DSCN7320 Date of Photo: 6/06/2024 Time of Photo: 09:50 CST Photographer: Vince Damiano Description: Close up of hazardous waste label on frac tanks FT-7033. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: Environmental Safety & Health Consulting Services, Inc. City: Houma County/Parish: Terrebonne State: Louisiana Photo File Name: DSCN7321 Date of Photo: 6/06/2024 Time of Photo: 09:50 CST Photographer: Vince Damiano Description: Inside of frac tank FT-7033 containing approximately 750 gallons of unidentified liquid. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: Environmental Safety & Health Consulting Services, Inc. City: Houma County/Parish: Terrebonne State: Louisiana Photo File Name: DSCN7322 Date of Photo: 6/06/2024 Time of Photo: 09:50 CST Photographer: Vince Damiano Description: Inside of frac tank FT-7033 containing approximately 750 gallons of unidentified liquid. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: Environmental Safety & Health Consulting Services, Inc. City: Houma County/Parish: Terrebonne State: Louisiana Photo File Name: DSCN7323 Date of Photo: 6/06/2024 Time of Photo: 09:51 CST Photographer: Vince Damiano Description: Overview of frac tank FT-7033. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: Environmental Safety & Health Consulting Services, Inc. City: Houma County/Parish: Terrebonne State: Louisiana Photo File Name: DSCN7324 Date of Photo: 6/06/2024 Time of Photo: 10:02 CST Photographer: Vince Damiano Description: Inside of frac tank FT-6333 containing approximately one foot of unidentified liquid and sludge. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: Environmental Safety & Health Consulting Services, Inc. City: Houma County/Parish: Terrebonne State: Louisiana Photo File Name: DSCN7325 Date of Photo: 6/06/2024 Time of Photo: 10:03 CST Photographer: Vince Damiano Description: Overview of frac tank FT-6333. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: Environmental Safety & Health Consulting Services, Inc. City: Houma County/Parish: Terrebonne State: Louisiana Photo File Name: DSCN7326 Date of Photo: 6/06/2024 Time of Photo: 10:20 CST Photographer: Vince Damiano Description: Six partially full drums of used oil in the truck maintenance shop. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: Environmental Safety & Health Consulting Services, Inc. City: Houma County/Parish: Terrebonne State: Louisiana Photo File Name: DSCN7327 Date of Photo: 6/06/2024 Time of Photo: 10:20 CST Photographer: Vince Damiano Description: Close up of unlabeled, partially full drum of used oil in the truck maintenance shop. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 Location: Environmental Safety & Health Consulting Services, Inc. City: Houma County/Parish: Terrebonne State: Louisiana Photo File Name: DSCN7328 Date of Photo: 6/06/2024 Time of Photo: 10:20 CST Photographer: Vince Damiano Description: Close up of unlabeled, partially full drum of used oil in the truck maintenance shop. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 10 Location: Environmental Safety & Health Consulting Services, Inc. City: Houma County/Parish: Terrebonne State: Louisiana Photo File Name: DSCN7329 Date of Photo: 6/06/2024 Time of Photo: 10:20 CST Photographer: Vince Damiano Description: Close up of partially full drum of hot drained used oil filters in the truck maintenance shop. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 11 Location: Environmental Safety & Health Consulting Services, Inc. City: Houma County/Parish: Terrebonne State: Louisiana Photo File Name: DSCN7328 Date of Photo: 6/06/2024 Time of Photo: 10:20 CST Photographer: Vince Damiano Description: Six partially full drums of used oil in the truck maintenance shop. Appendix 2 ES&H Hazardous Waste Manifests Appendix 2 Page 1 of 9 Appendix 2 Page 2 of 9 Appendix 2 Page 3 of 9 Appendix 2 Page 4 of 9 Appendix 2 Page 5 of 9 Appendix 2 Page 6 of 9 Appendix 2 Page 7 of 9 Appendix 2 Page 8 of 9 Appendix 2 Page 9 of 9 Appendix 3 Manifests for Last Load in Frac Tanks FT-7033 and FT-6333 Appendix 3 Page 1 of 12 Appendix 3 Page 2 of 12 Appendix 3 Page 3 of 12 Appendix 3 Page 4 of 12 Appendix 3 Page 5 of 12 Appendix 3 Page 6 of 12 Appendix 3 Page 7 of 12 Appendix 3 Page 8 of 12 Appendix 3 Page 9 of 12 Appendix 3 Page 10 of 12 Appendix 3 Page 11 of 12 Appendix 3 Page 12 of 12 Appendix 4 ES&H Frac Tank Cleaning SOP March 4, 2008 HOUMA, LA MORGAN CITY, LA BELLE CHASSE, LA FOURCHON, LA GOLDEN MEADOW, LA LAPLACE, LA VENICE, LA LAKE CHARLES, LA FRAC TANK CLEANING PROCEDURE 1. Remove all free liquids from frac using vacuum truck suction. Liquids to be removed from top hatch or lower tank valves. 2. Open all hatches to start the ventilating process. Install forced air ventilation to tank. 3. Using 5 gas air monitor readings are taken of tanks air quality to assure safe for entry. 4. Make entry into tank wearing appropriate PPE. Entry requires (4) man crew to meet confined space entry requirements. 5. Soap is applied to all impacted areas by use of Hudson sprayer. 6. A vacuum truck suction hose is then placed inside of the frac tank prior to washing. 7. Frac tank is then pressure washed using minimum 3,000 PSI pressure washer. 8. Once the tank is washed all liquids removed by vacuum truck. 9. Tank is then inspected by ES&H supervisor to pass cleanliness. 10. Upon completion of tank cleaning tank is then inspected by ES&H mechanic approving all valves and fittings. Appendix 4 Page 1 of 1 Appendix 5 ES&H Response to AOCs