Document zeJRmRkOZdGmMmDR9yp2VBd6

Region 6 Enforcement and Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media: Regulatory Program(s) Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: 06/11/2019 FIFRA Section 12 ONG Consulting LLC (formerly known as SaniTec H20} 2513 Winners Circle Heath, TX 75126 519 E. Interstate 30, Ste. 154 Rockwall, TX 75058 Rockwall County Fredrick B. Ongeche I Chief Chemist/Owner FRS Number: N/A Identification/Permit Number: N/A Media Number: NAICS: SIC: Personnel participating in inspection: Fredrick B. Ongeche ONG Consulting, LLC Chief Chemist/Owner Lee McMillan Henry Krusekopf EPA Lead Inspector Signature/Date EPA Region 6 - Pesticide Environmental Engineer/ Enforcement Inspector Texas Department of Assistant Regional Director Agriculture - Pesticides ,., riYilt LeeV. IJ!cMlllan / r //~.."-'-.. I (316) 617-3921 (214) 665-6404 (214) 631-0265 8/5/2019 Date Supervisor Signature/Date hx~ / H. Troy St6dkey I \ L/ 8'-f-''i Date 6ENFORM-019-R7 (2/15/2017) 1 Section I - INTRODUCTION ONG Consulting, LLC Inspection Date: 06/11/2019 PURPOSE OF THE INSPECTION EPA Region 6 inspector, Lee McMillan and Texas Department of Agriculture inspector, Henry Krusekopf met for an announced joint inspection regarding ONG Consulting, LLC's production of an unregistered pesticide. On June 11, 2019, at approximately 1:15 PM, we arrived at the mailing address located at 519 E. Interstate 30, Ste. 154, Rockwall, TX 75058. We were able to confirm that the business does not have a physical location at this address and photos were taken. We then proceeded to the second location at 2513 Winners Circle Heath, TX 75126. I was able to confirm that the address was the home office of ONG Consulting, LLC (ONG). I presented my credentials to Mr. Fredrick Ongeche along with a Notice of Inspection and informed him that this was an EPA inspection to investigate a potential unregistered pesticide. The scope of the inspection is the evaluation of company's distribution and sale of copper-ion generators used to treat zebra mussels in the water treatment process with regard FIFRA regulation (Section 12(a)(1)(A) - Unregistered Pesticides). FACILITY DESCRIPTION ONG is a privately held limited liability company founded in 2005, in the State of Kansas and authorized to do business in Texas. The company's primary focus has been on the production of fouling controls for water distribution systems. The company has two patents filed and three in the pre-application process. The ONG's team includes, electrical engineers, chemists, microbiologist, fabricators, and sales. The company has a home office in Heath, TX. The electrical/electronic design takes place in Milwaukee, WI. The equipment is fabricated in Colorado Springs, CO, then assembled, tested, and sold from Wichita, KS. ONG is considered a Category III sized business under FIFRA Enforcement Response Policy. Section II - OBSERVATIONS At approximately 1:34 PM we arrived at the home office of ONG. No products were on hand or being produced at the address. Inspector, Henry Krusekopf and I hand a conversation with Mr. Ongeche and provided compliance assistance answering questions about the process of the investigation. I included the photos taken to document the locations in Appendix 1. Section III - AREAS OF CONCERN I observed the installation of two ONG Fortress MC system copper-ion generators for the control of zebra mussels at the Lewisville water production facility on April 16, 2019. Neither of the Fortress MC systems had pesticide registrations under the regulations of FIFRA. Inspector Henry Krusekopf and I made Mr. Ongeche aware of the status of the generators and presented the him with a copy of the Federal Register Notice [EPA- HQ--OPP- 2007--0949; FRL-8149-4]: Pesticide Registration; Clarification for Ion-Generating Equipment. Additional documentation was also requested at this time. Mr. Ongeche 2 ONG Consulting, LLC Inspection Date: 06/11/2019 stated that he would be taking measures to come into compliance by addressing the areas of concern and expected to have his product registered by July 2019. The inspection was concluded at approximately 2:40 PM and I exited the premises. Section IV - FOLLOW UP The following information was received by EPA after exiting the office on June 11, 2019: A Brief Company History Invoices and Contracts (CBI) Marketing Materials and EPA Registration Documents Section V - LIST OF APPENDICES Appendix 1 - Photo Log - 3 photos taken Appendix 2 - Notice of Inspection 3 ONG Consulting, LLC Inspection Date: 06/11/2019 Appendix 1 Photograph Log UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: ONG Consulting, LLC City: Rockwall Photo No. 1 County/Parish: Grayson State: Texas Photo File Name: H:\6PD\6MM-XP\Enforcement\ENFORCEMENT SENSITIVE\FY2019\2019-068 ONG Consulting (Citizen)\Photos\DSC_0001.JPG Date of Photo: June 11, 2019 Time of Photo: 01:16 PM Photographer: Lee McMillan Description: Official address of ONG Consulting, LLC located at 519 E. Interstate 30, Ste. 154, Rockwall, TX 75058 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: ONG Consulting, LLC City: Rockwall Photo No. 2 County/Parish: Grayson State: Texas Photo File Name: H:\6PD\6MM-XP\Enforcement\ENFORCEMENT SENSITIVE\FY2019\2019-068 ONG Consulting (Citizen)\Photos\DSC_0002.JPG Date of Photo: June 11, 2019 Time of Photo: 01:17 PM Photographer: Lee McMillan Description: Post office box for ONG Consulting UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: ONG Consulting, LLC City: Rockwall Photo No. 3 County/Parish: Grayson State: Texas Photo File Name: H:\6PD\6MM-XP\Enforcement\ENFORCEMENT SENSITIVE\FY2019\2019-068 ONG Consulting (Citizen)\Photos\DSC_0004.JPG Date of Photo: June 11, 2019 Time of Photo: 02:37 PM Photographer: Lee McMillan Description: Business office of ONG Consulting LLC Appendix 2 Notice of Inspection