Document zQGGvaDGqzk7BYw6ERgY6EVDa
f t E A ~ United States
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Environmental Protection
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Agency
EPA REGION 6 Enforcement Division
INSPECTION REPORT
Inspection Entry
6/24/2025 9:30 AM (CT)
Date/Time
Inspection Exit Date/Time 6/24/2025 10:10 AM (CT)
Regulatory Program Type of Inspection
RCRA Focused Compliance Inspection (FCI)
Announced: Yes 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
Chemical Response and Remediation Contractors, Inc. TXR000040014 18635 Primera Rd. Unit #1
Harlingen, TX 78552 Cameron N/A 48411, 56291 Chemical Response and Remediation Contractors, Inc. (CRRC) performs environmental remediation and transportation of non-hazardous waste. 26.226111, -97.727579
Additional Persons Participating in Inspection:
Name
Title
Organization
Cameron Tanaka
Contractor Eastern Research Group (ERG)
Email Cameron.Tanaka@erg.com
Lead Inspector: Vince Damiano
ERG
Vincent Damiano
Digitally signed by Vincent Damiano Date: 2025.08.06 12:57:35 -04'00'
IVince.Damiano@erg.com
Page 1 of 4
Chemical Response and Remediation Contractors, Inc.
Inspection Date: 6/24/2025
SECTION I - INTRODUCTION
Site Entry and Purpose of the Inspection
The Port Harlingen and surrounding facilities were selected for inspection based on a 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, portrelated facilities, and records, including photographs taken, 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 RCRA Inspector/ Contractor/ERG President/CRRC
Name Vince Damiano Cameron Tanaka David Hanawa
Opening Conf. Closing Conf.
Yes
Yes
Yes
Yes
Yes
Yes
Page 2 of 4
Chemical Response and Remediation Contractors, Inc. Facility General Description
Inspection Date: 6/24/2025
Tenant/Area Chemical Response and Remediation Contractors, Inc.
Inspection
Date
Process Description
6/24/25 CRRC performs environmental remediation and
transportation of non-hazardous waste. The facility does
not maintain a MARPOL COA.
Area of Concern
Yes
SECTION II - OBSERVATIONS
Facility: Chemical Response and Remediation Contractors, Inc.
Section: 2.1
Date: 6/24/25, 9:30 AM
Contains AOC: Yes Contains CBI: No
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Lead Inspector: Vince Damiano Attendees: David Hanawa (President)
CRRC, located in Harlingen, TX, performs environmental remediation and transportation of non-hazardous waste. As an environmental remediation contractor, CRRC cleans or removes asbestos, mold, trash, spills on land and in water, soil, and caustic materials and acts as the transporters for these cleanup activities. CRRC only transports non-hazardous and DOT Class I hazardous materials (not hazardous waste), which are occasionally brought onto the CRRC site and stored in roll-offs while waste profiles are rendered. Although CRRC is registered with the EPA as a hazardous waste transporter (EPA ID TXR000040014), CRRC does not typically transport hazardous waste or RCRA-regulated waste, and DOT hazardous materials generated at a remediation site are transported by a third-party transporter. CRRC transports and stores materials and waste from multiple remediation sites at once in three-quarter-ton trucks, trailers, roll-off trucks, and roll-off containers. CRRC transports these materials and wastes to US Ecology in Robstown, TX, or the LaGloria landfill in Edinburg, TX. The facility does not have any dock space. The facility generates used oil from onsite maintenance activities and sends it to a recycler approximately once a month. Facility personnel indicated that they generate approximately 50 gallons of used oil per month. CRRC has a third-party transporter that takes its used oil off-site to the recycler. The facility also generates used batteries that are recycled at the original battery supplier's facility, transported there also by the supplier. CRRC also collects waste from local schools and educational chemistry laboratories to be lap packed and sent for disposal. At most, CRRC will do this 1-2 times a year, but will sometimes not conduct a lab pack collection over the course of a calendar year. The schools are considered the generators of waste on manifests; however, Mr. Hanawa explained that approximately 80% of the waste picked up from this activity is non-hazardous, 15% of the waste is DOT hazardous, and only 5% of the waste is RCRA-regulated hazardous waste, such as paint, corrosives, or acids. All waste collected and handled by CRRC from the schools is typically one pint to one quart in size. Mr. Hanawa stated that any hazardous waste would not be handled by CRRC, and a third-party transporter is contracted to move that waste; an example manifest of this situation is provided in Appendix 2. Mr. Hanawa stated that the waste is segregated in the field for incompatibles and profiled once brought back to the facility. It takes about 30 days to have the lab packs completely profiled and shipped to the disposal facility.
After the opening conference, the inspection team observed CRRC's operations, including the yard area and the garage. In the yard area, close to the garage, the inspection team observed one 300-gallon tank storing used oil that CRRC generated, but the tank was not labeled as "Used Oil" (see Appendix 1 - Photo 1) [AOC #1 - CRRC did not clearly label a container used to store used oil with the words "Used Oil" - 40 CFR 279.22(c)(1)]. CRRC personnel immediately labeled the containers as used oil using spray paint (see Appendix 1 - Photo 3). In the garage area, the inspection team observed approximately 25 universal waste batteries that were not
Page 3 of 4
Chemical Response and Remediation Contractors, Inc.
Inspection Date: 6/24/2025
labelled or dated (see Appendix 1 - Photo 2) [AOC #2 - CRRC did not label batteries being managed as
universal waste properly or store the batteries in a properly labeled container - 40 CFR 273.14(a)] & [AOC #3 -
CRRC did not demonstrate the accumulation start date for universal waste- 40 CFR 273.15(c)].
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 10:10 AM with CRRC personnel. The AOCs identified at the time of the inspection were communicated during the closing. Following the inspection on 8/4/2025, Mr. Hanawa provided pictures of the used oil tank labeled and the battery storage area labeled (see Appendix 3).
SECTION III - RECORDS REVIEW No RCRA-regulated records were reviewed during this focused on-site inspection.
SECTION IV - AREAS OF CONCERN
The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation. Facility: Chemical Response and Remediation Contractors, Inc.
AOC #1 - CRRC did not clearly label a container used Citation: 40 CFR 279.22(c)(1) to store used oil with the words "Used Oil."
Section: 2.1
AOC #2 - CRRC did not label batteries being managed Citation: 40 CFR 273.14(a) as universal waste properly or store the batteries in a properly labeled container.
AOC #3 - CRRC did not demonstrate the accumulation Citation: 40 CFR 273.15(c) start date for universal waste.
Section: 2.1 Section: 2.1
SECTION V - FOLLOW UP Not Applicable Communication Log 24 hours prior to the on-site inspection, Erin Young-Dahl from EPA notified the facility that ERG would be performing a FCI at the facility. SECTION VI - LIST OF APPENDICES Appendix 1. Photograph Log Appendix 2. Example Manifest of Hazardous Waste Pick Up Appendix 3. CRRC Follow-Up Photos
Page 4 of 4
APPENDIX 1. PHOTOGRAPH LOG
Location: Chemical Response and Remediation Contractors, Inc.
City: Harlingen
County/Parish: Cameron
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State: Texas
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Photo No. 1
Photo File Name: DSCN8780 Date of Photo: 6/24/2025 Time of Photo: 0957 hrs. Photographer: Vince Damiano Description: View of a 300-gallon tank storing used oil in the facility's yard area that was not labeled.
Location: Chemical Response and Remediation Contractors, Inc.
City: Harlingen
County/Parish: Cameron
State: Texas
Photo No. 2
Photo File Name: DSCN8781 Date of Photo: 6/24/2025 Time of Photo: 1001 hrs. Photographer: Vince Damiano Description: View of about 25 unlabeled universal waste batteries in the facility's garage area.
Location: Chemical Response and Remediation Contractors, Inc.
City: Harlingen
County/Parish: Cameron
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State: Texas
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Photo No. 3
Photo File Name: DSCN8782 Date of Photo: 6/24/2025 Time of Photo: 1003 hrs. Photographer: Vince Damiano Description: View of a 300-gallon tank storing used oil in the facility's yard area that CRRC personnel spray painted a "Used Oil" label after the inspection team observed that there was no label.
APPENDIX 2. EXAMPLE MANIFEST OF HAZARDOUS WASTE PICK UP
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UNIFORM HAZARDOUS , 1. Generator ID Number
WASTE MANIFEST 1" X C E S O G
5. Generator's Name and Mailing Address
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WESLACOISD
PO 80.K 5::uwr. ftAffi.!Nf':iE.N, TX 76553
Generator's Phone: >l!ie-4-~ll/''iJO
6. Transporter 1Company Name ENVIROM.'\10
Form Approved 0MB No 2050-0039
2. Page 1Of 13. Emergency Response Phone
.(l4. Man.ifest Tracking Number.
1 4 i:100 535 505'3 INf~OTHA(', 00693700 9 .. GBF
, Generator's SiteAddress (ifdrfferent than mailing address)
:no WEST FOURTH STREET
WESLACO, TX 78596
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U.S. EPA ID Number
lNDUSTR:iAL SYSTEMS/SERVICES I TXR000080274
7. Transporter 2 Company Name
GRUENE TRANSPORIATiON. LLC
8. Designated Facility Name and Site Address
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51't 1 ETHRfDGE, HOUSTON. TX T1001
Facility's Phone:
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9a. 9b. U.S. DOT Description ~ncluding Proper Shipping Name, Hazard Class, ID Number, HM and Packing Group (ifany))
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U.S. EPA ID Number
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15. GENERATOR'S/OFFEROR'S CERTIFICATION: I hereby declare that the contents ofthis consignment are fully and accurately described above by the proper shipping name, an:l are classified, packaged,
marked and labeled/placarded, and are in all respects in proper condition for transportaccording to applicable international and,!!~lional governmental regulations. If export shipment and I am the Primary
Exporter, I certify that the contents ofthis consignment conform to the terms ofthe attached EPAAcknowledgment of Consimt: ~
I certify that the waste minimization statement identiffed in40 CFR 262.27(a) (if I am alarge quantity generator) or (b) (iqim asrnpll quantity generator) is true.
Generato(s/Offerors Printed/Typed Name
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l ~ , ~ 17. TransporterAcknowledgment of Receipt of Materials
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l 18. Discrepancy 18a. Discrepancy Indication Space
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C, 00 19. Hazardous WasteReport Management Method Codes (i.e., codes for hazardous wastetreatment, disposal, and recyclingsystems)
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U.S. EPA ID Number
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l 20. Designated Facility Owner or Operator: Certification of receipt of hazardousmaterials covered by the manifest except as ncted in Item 18a
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EPA Form 8700-22 (Rev. 12-17) Previous editions are obsolete.
Month Day Year
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GENERATOR'S INITIAL COPY
APPENDIX 3. CRRC FOLLOW-UP PHOTOS
Designated Used Battery Storage Area
Batteries with Removed Dates
UNIVERSAL WASTE
USED OIL