Document zo4Jd0NmRjQMOMkYxV0e3YaDB

Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 6 Enforcement Division INSPECTION REPORT 03/12/2024 11:23 (CT) Announced: No 03/12/2024 16:10 (CT) Access: Granted RCRA Focused Compliance Inspection (FCI) 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 Kiewit Offshore Services LTD TXR000042648 2440 Kiewit Road Ingleside, TX 78662 San Patricio County Small Quantity Generator (SQG) 336611 Kiewit Offshore Services LTD (Kiewit) is a construction facility specializing in the fabrication of offshore platforms. 27.85073, -97.22813 Additional Persons Participating in Inspection: Name Title Organization Joyce Johnson Inspector EPA REGION 6 Erin Young-Dahl Inspector EPA REGION 6 Andrew Gates Contractor Eastern Research Group (ERG) Email Johnson.Joyce@epa.gov YoungDahl.Erin@epa.gov Andrew.Gates@erg.com Lead Inspector: Vince Damiano ERG Vincent Damiano Digitally signed by Vincent Damiano Date: 2024.07.11 18:34:25 -04'00' Vince.Damiano@erg.com Phone (214) 665-8548 (214) 665-3166 (657) 206-7829 07/11/2024 (703) 633-1732 Page 1 of 9 Kiewit Offshore Services LTD SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection Inspection Date: 03/12/2024 The Port of Corpus Christi 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 Appendix 1), 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 Lead Inspector/ Contractor/ERG RCRA Inspector/ Contractor/ERG Inspector/Enforcement Officer/EPA Region 6 Inspector/Enforcement Officer/EPA Region 6 Name Vince Damiano Phone Email (703) 633-1732 Vince.Damiano@erg.com Opening Conf. Yes Closing Conf. Yes Andrew Gates (657) 206-7829 Andrew.Gates@erg.com Yes Yes Joyce Johnson (214) 665-8548 Johnson.Joyce@epa.gov Yes Yes Erin Young-Dahl (214) 665-3166 YoungDahl.Erin@epa.gov Yes Yes Page 2 of 9 Kiewit Offshore Services LTD Inspection Date: 03/12/2024 Facility General Description Tenant/Area Kiewit Offshore Services LTD Inspection Date 03/12/24 Process Description Kiewit Offshore Services LTD (Kiewit) is a construction facility specializing in the fabrication of offshore modules. The facility does not regularly receive or ship petroleum or chemical products at this location. The facility maintains a MARPOL COA for Annex I and V but does not receive waste from vessels. Area of Concern Yes Page 3 of 9 Kiewit Offshore Services LTD Inspection Date: 03/12/2024 SECTION II - OBSERVATIONS Tenant: Kiewit Offshore Services LTD Section: 2.1 Date: 03/12/24, 11:23 AM Contains AOC: Yes Contains CBI: No Lead Inspector: Vince Damiano Attendees: Bo Johnson (Ops Manager), Hannah Johnson (Environmental Coordinator), Diana Villenas (Environmental Manager) Kiewit is located in Ingleside, Texas to the east of the Port of Corpus Christi and within Corpus Christi Bay. Kiewit operates as a construction facility specializing in the development and fabrication of offshore modules, with a focus on oil drilling rigs. Kiewit is not affiliated with the Port of Corpus Christi and operates one large bulkhead with almost 3,000 feet of shoreline. During refurbishment operations, rigs may arrive with waste onboard in need of disposal. When this happens, the rig owner is responsible for all waste generated and disposal; Kiewit is not responsible for or considered the generator of the wastes. Kiewit maintains a MARPOL COA for Annex I and V and is registered with EPA as a SQG of hazardous waste (EPA ID TXR000042648). Ms. Johnson and Ms. Villenas summarized the waste streams generated at the facility as consisting of bleach, fuels, chemical water with low pH, aerosol cans, paint waste, and used oil. During the inspection the inspection team toured the facility and the bulkhead, including the paint CAA inside the paint building (Appendix 1 - Photos 1 to 7), the can crushing area in the paint building (Appendix 1 - Photos 8 to 17), the satellite accumulation area (SAA) on the west side of the paint building (Appendix 1 - Photos 18 to 20), and the waste CAA (Appendix 1 - Photos 21 to 42). Observations and AOCs are organized by section below along with facility responses where relevant. Paint CAA Inside Paint Building (aka Back Booth Waste Area): During the inspection, the inspection team observed two mostly full 55-gallon drums and two non-empty 5gallon buckets of paint waste in the paint CAA that did not have the proper label wording (see Appendix 1 - Photos 1 to 7). The labels were not clearly visible due to a plastic liner over the bag, however they did contain an accumulation start date upon further inspection.[AOC #1 - Kiewit did not clearly label containers used to store waste paint with the words "Universal Waste: Paint and Paint Related Waste" - 30 TAC 335.262(c)(2)(F)] Additionally, the two 5-gallon containers did not have lids and had not been completely emptied of paint. [AOC #2 - Kiewit was storing waste paint in open containers - 30 TAC 335.262(c)(2)(A)] Following the inspection, Ms. Johnson sent photos (see Appendix 2) of the two 55-gallon drums labeled "Universal Waste: Paint and Paint Related Waste". Can Crushing Area Inside Paint Building: In the can crushing area, the inspection team observed two 5-gallon containers that were half full of dried paint and two 1-gallon containers half full of liquid paint (see Appendix 1 - Photos 8, 9, 12, and 13). [AOC #3 - Kiewit was allowing waste paint to dry as a form of treatment - 30 TAC 335.261(b)(21)] The two 5-gallon and two 1-gallon containers were stored without lids (see AOC #2 above) and did not have a visible label (see AOC #1 above). Following the inspection, Ms. Villenas sent photos (see Appendix 3) demonstrating that all containers in the can crushing area were empty and that most of the containers had been processed. Paint SAA West Side of Paint Building: In the paint SAA on the west side of the paint building, the inspection team observed one unlabeled 55-gallon drum containing unpunctured waste aerosol cans (see Appendix 1 - Photos 18 to 20). [AOC #4 - Kiewit was storing non-punctured waste aerosol cans in an unlabeled drum - 40 CFR 273.14(f)] Following the inspection, Page 4 of 9 Kiewit Offshore Services LTD Inspection Date: 03/12/2024 Ms. Villenas sent a photo (see Appendix 3) demonstrating that the 55-gallon drum had been labeled. Waste CAA and Drum Storage Area (DSA): The following observations were made in the waste CAA and DSA: One full 55-gallon container labeled "Oily Water" and one full 55-gallon container labeled "Hose Oil" (see Appendix 1 - Photos 27 and 28). [AOC #5 - Kiewit did not clearly label containers used to store used oil with the words "Used Oil" - 40 CFR 279.22(c)(1)] Several 55-gallon drums with incomplete universal waste labels (see Appendix 1 - Photo 30) (see AOC #1 above). Two unlabeled 55-gallon drums of unknown waste. Following the inspection, they were determined to be non-hazardous waste containing AFFF/water/dirt. (See Appendix 1 - Photos 32 and 33). Inadequate aisle space in DSA (see Appendix 1 - Photo 29). [AOC #6 - Kiewit did not provide proper aisle space between rows of drums - 40 CFR 262.16(b)(8)(v)] Two full 55-gallon drums of hazardous waste, containing Biocide PC-56 and contaminated gas respectively, with incomplete hazardous waste labels that did not have an indication of the hazards (see Appendix 1 - Photos 23 to 26) [AOC #7 - Kiewit did not clearly mark an indication of hazards on a hazardous waste label - 40 CFR 262.16(b)(6)(i)]. Several full 55-gallon drums of paint related waste in the DSA and three partially full 55-gallon drums of unidentified waste next to the DSA in poor condition (see Appendix 1 - Photo 31, 39-41). [AOC #8 - Kiewit did not immediately transfer hazardous waste from damaged containers to containers that were in good condition - 40 CFR 262.16(b)(2)(i)] Unlabeled spent lead acid batteries stored as universal waste in the CAA. [AOC #9 - Kiewit did not label batteries being managed as universal waste properly or store the batteries in a properly labeled container - 40 CFR 273.14(a)] Three partially full, unlabeled 55-gallon drums and seven full, unlabeled 20-liter containers of unknown waste pending analysis. [AOC #10 - Kiewit did not clearly label its containers as "Hazardous Waste" as the waste analysis was pending - 40 CFR 262.16(b)(6)(i)] Following the inspection, Ms. Villenas sent photos (see Appendix 3 and 4) addressing each of the AOCs identified in the waste CAA and DSA. After the visual inspection, the inspection team requested the following information from Kiewit: A waste determination on three unidentified 55-gallon drums showing signs of container damage in the waste CAA and drum storage area (see Appendix 2). A waste determination for the Biocide PC-56 and contaminated gas (see Appendix 1 - Photo 23) (see Appendix 3). SDS for the antifoamer and scale inhibitor (see Appendix 1 - Photo 21 and 22) (see Appendix 3). MARPOL COA from the U.S. Coast Guard (see Appendix 3). Timeline from the NFE Hazardous Waste Event where a contract was held by Keiweit to have a client manage their hazardous waste on Keiweit property during a refabrication contract (see Appendix 4). The inspection team did not observe other areas of concern at the time of the inspection. A closing conference was conducted at approximately 4:10 PM with Kiewit personnel. The AOCs were communicated Page 5 of 9 Kiewit Offshore Services LTD during the closing. Inspection Date: 03/12/2024 Page 6 of 9 Kiewit Offshore Services LTD Inspection Date: 03/12/2024 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. Tenant: Kiewit Offshore Services LTD AOC #1 - Kiewit did not clearly label containers used Citation: 30 TAC 335.262(c)(2)(F) to store waste paint with the words "Universal Waste: Paint and Paint Related Waste". Section: 2.1 AOC #2 - Kiewit was storing waste paint in open containers. Citation: 30 TAC 335.262(c)(2)(A) Section: 2.1 AOC #3 - Kiewit was allowing waste paint to dry prior Citation: 30 TAC 335.261(b)(21) to disposal. AOC #4 - Kiewit was storing unpunctured waste aerosol cans in an unlabeled drum. Citation: 40 CFR 273.14(f) AOC #5 - Kiewit did not clearly label containers used Citation: 40 CFR 279.22(c)(1) to store used oil with the words "Used Oil". AOC #6 - Kiewit did not provide adequate aisle space Citation: 40 CFR 262.16(b)(8)(v) between rows of drums. AOC #7 - Kiewit did not clearly mark an indication of Citation: 40 CFR 262.16(b)(6)(i) the hazards on a hazardous waste label. AOC #8 - Kiewit did not immediately transfer hazardous waste from damaged containers to containers that were in good condition. Citation: 40 CFR 262.16(b)(2)(i) AOC #9 - Kiewit did not label a container in which universal waste batteries were stored. Citation: 40 CFR 273.14(a) AOC #10 - Kiewit did not clearly label containers of potentially hazardous waste as "Hazardous Waste" while the waste analysis was pending. Citation: 40 CFR 262.16(b)(6)(i) Section: 2.1 Section: 2.1 Section: 2.1 Section: 2.1 Section: 2.1 Section: 2.1 Section: 2.1 Section: 2.1 Page 7 of 9 Kiewit Offshore Services LTD Inspection Date: 03/12/2024 SECTION V - FOLLOW UP Follow-Up Any facility follow-up items are as discussed in the observations in Section II. Documents or files provided by the facility were transmitted via email and included responses to AOCs or provision of documents requested. Page 8 of 9 Kiewit Offshore Services LTD Communication Log Inspection Date: 03/12/2024 During and after the inspection, additional information was emailed to EPA including: 1. 03/13/24 Kiewit email - Diana Villenas sent several photos and descriptions showing corrective actions implemented at the warehouses and CAA. 2. 03/14/24 Kiewit email - Diana Villenas sent SDS for unleaded gas and Permaclean PC-56. 3. 03/20/24 Kiewit email - Hannah Johnson sent several photos to show corrective actions being implemented on universal waste paint and paint related waste. 4. 03/21/24 Kiewit email - Hannah Johnson sent a written statement outlining the timeline for the hazardous waste that was offloaded from the vessels last year by their client. 5. 03/26/24 Kiewit email - Diana Villenas sent several photos and descriptions showing corrective actions implemented at the warehouses and CAA. SECTION VI - LIST OF APPENDICES Appendix 1. Photograph Log Appendix 2. Kiewit Offshore Services LTD 03/20/24 and 03/26/24 Response Appendix 3. Kiewit Offshore Services LTD 03/13/24 Response Appendix 4. Kiewit Offshore Services LTD 03/21/24 Response Page 9 of 9 APPENDIX 1. PHOTOGRAPH LOG UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: Kiewit Offshore Services LTD City: Ingleside County/Parish: San Patricio State: Texas Photo File Name: DSCN7092 Date of Photo: 03/12/2024 Time of Photo: 13:03 hrs. Photographer: Vince Damiano Description: Overview of Back Booth Waste Area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: Kiewit Offshore Services LTD City: Ingleside County/Parish: San Patricio State: Texas Photo File Name: DSCN7093 Date of Photo: 03/12/2024 Time of Photo: 13:03 hrs. Photographer: Vince Damiano Description: View of unlabeled, open 5-gallon container of paint waste container with residual liquid paint at the bottom in the Back Booth Waste Area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: Kiewit Offshore Services LTD City: Ingleside County/Parish: San Patricio State: Texas Photo File Name: DSCN7094 Date of Photo: 03/12/2024 Time of Photo: 13:03 hrs. Photographer: Vince Damiano Description: View of unlabeled, open 5-gallon container of paint waste container with residual liquid paint at the bottom in the Back Booth Waste Area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: Kiewit Offshore Services LTD City: Ingleside County/Parish: San Patricio State: Texas Photo File Name: DSCN7095 Date of Photo: 03/12/2024 Time of Photo: 13:03 hrs. Photographer: Vince Damiano Description: View of unlabeled, open 5-gallon container of paint waste container with residual liquid paint at the bottom in the Back Booth Waste Area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: Kiewit Offshore Services LTD City: Ingleside County/Parish: San Patricio State: Texas Photo File Name: DSCN7096 Date of Photo: 03/12/2024 Time of Photo: 13:04 hrs. Photographer: Vince Damiano Description: View of 55-gallon waste paint drum in the Back Booth Waste Area with label obscured. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: Kiewit Offshore Services LTD City: Ingleside County/Parish: San Patricio State: Texas Photo File Name: DSCN7097 Date of Photo: 03/12/2024 Time of Photo: 13:04 hrs. Photographer: Vince Damiano Description: View of 55-gallon waste paint drum in the Back Booth Waste Area with label obscured. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: Kiewit Offshore Services LTD City: Ingleside County/Parish: San Patricio State: Texas Photo File Name: DSCN7098 Date of Photo: 03/12/2024 Time of Photo: 13:04 hrs. Photographer: Vince Damiano Description: View of 55-gallon waste paint drum in the Back Booth Waste Area with label partially obscured. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: Kiewit Offshore Services LTD City: Ingleside County/Parish: San Patricio State: Texas Photo File Name: DSCN7099 Date of Photo: 03/12/2024 Time of Photo: 13:11 hrs. Photographer: Vince Damiano Description: View of two unlabeled, open 5-gallon containers of paint waste container with residual paint at the bottom in the Can Crushing Area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 Location: Kiewit Offshore Services LTD City: Ingleside County/Parish: San Patricio State: Texas Photo File Name: DSCN7100 Date of Photo: 03/12/2024 Time of Photo: 13:11 hrs. Photographer: Vince Damiano Description: View of two unlabeled, open 5-gallon containers of paint waste container with residual paint at the bottom in the Can Crushing Area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 10 Location: Kiewit Offshore Services LTD City: Ingleside County/Parish: San Patricio State: Texas Photo File Name: DSCN7101 Date of Photo: 03/12/2024 Time of Photo: 13:11 hrs. Photographer: Vince Damiano Description: View of several 5-gallon containers in the Can Crushing Area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 11 Location: Kiewit Offshore Services LTD City: Ingleside County/Parish: San Patricio State: Texas Photo File Name: DSCN7102 Date of Photo: 03/12/2024 Time of Photo: 13:12 hrs. Photographer: Vince Damiano Description: View of several unlabeled, open 5-gallon containers of paint waste with residual paint at the bottom in the Can Crushing Area UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 12 Location: Kiewit Offshore Services LTD City: Ingleside County/Parish: San Patricio State: Texas Photo File Name: DSCN7104 Date of Photo: 03/12/2024 Time of Photo: 13:12 hrs. Photographer: Vince Damiano Description: View of unlabeled, open 1-gallon containers of paint waste container with residual paint at the bottom in the Can Crushing Area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 13 Location: Kiewit Offshore Services LTD City: Ingleside County/Parish: San Patricio State: Texas Photo File Name: DSCN7105 Date of Photo: 03/12/2024 Time of Photo: 13:13 hrs. Photographer: Vince Damiano Description: View of unlabeled, open 1-gallon containers of paint waste container with residual paint at the bottom in the Can Crushing Area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 14 Location: Kiewit Offshore Services LTD City: Ingleside County/Parish: San Patricio State: Texas Photo File Name: DSCN7106 Date of Photo: 03/12/2024 Time of Photo: 13:14 hrs. Photographer: Vince Damiano Description: Overview of the Can Crushing Area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 15 Location: Kiewit Offshore Services LTD City: Ingleside County/Parish: San Patricio State: Texas Photo File Name: DSCN7107 Date of Photo: 03/12/2024 Time of Photo: 13:14 hrs. Photographer: Vince Damiano Description: Overview of the Can Crushing Area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 16 Location: Kiewit Offshore Services LTD City: Ingleside County/Parish: San Patricio State: Texas Photo File Name: DSCN7108 Date of Photo: 03/12/2024 Time of Photo: 13:14 hrs. Photographer: Vince Damiano Description: Overview of the Can Crushing Area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 17 Location: Kiewit Offshore Services LTD City: Ingleside County/Parish: San Patricio State: Texas Photo File Name: DSCN7109 Date of Photo: 03/12/2024 Time of Photo: 13:14 hrs. Photographer: Vince Damiano Description: Overview of the Can Crushing Area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 18 Location: Kiewit Offshore Services LTD City: Ingleside County/Parish: San Patricio State: Texas Photo File Name: DSCN7110 Date of Photo: 03/12/2024 Time of Photo: 13:31 hrs. Photographer: Vince Damiano Description: Unlabeled 55-gallon drum containing unpunctured aerosol cans found in the Paint SAA. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 19 Location: Kiewit Offshore Services LTD City: Ingleside County/Parish: San Patricio State: Texas Photo File Name: DSCN7111 Date of Photo: 03/12/2024 Time of Photo: 13:31 hrs. Photographer: Vince Damiano Description: Unlabeled 55-gallon drum containing unpunctured aerosol cans found in the Paint SAA. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 20 Location: Kiewit Offshore Services LTD City: Ingleside County/Parish: San Patricio State: Texas Photo File Name: DSCN7112 Date of Photo: 03/12/2024 Time of Photo: 13:31 hrs. Photographer: Vince Damiano Description: Overview of SAA found on the west side of the Paint Building. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 21 Location: Kiewit Offshore Services LTD City: Ingleside County/Parish: San Patricio State: Texas Photo File Name: DSCN7113 Date of Photo: 03/12/2024 Time of Photo: 14:05 hrs. Photographer: Vince Damiano Description: View of 55-gallon drum of defoamer found in the DSA UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 22 Location: Kiewit Offshore Services LTD City: Ingleside County/Parish: San Patricio State: Texas Photo File Name: DSCN7114 Date of Photo: 03/12/2024 Time of Photo: 14:05 hrs. Photographer: Vince Damiano Description: View of 55-gallon drum of scale inhibitor found in the DSA. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 23 Location: Kiewit Offshore Services LTD City: Ingleside County/Parish: San Patricio State: Texas Photo File Name: DSCN7115 Date of Photo: 03/12/2024 Time of Photo: 14:06 hrs. Photographer: Vince Damiano Description: View of 55-gallon drum of hazardous waste contaminated gas with no waste codes in the DSA. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 24 Location: Kiewit Offshore Services LTD City: Ingleside County/Parish: San Patricio State: Texas Photo File Name: DSCN7116 Date of Photo: 03/12/2024 Time of Photo: 14:06 hrs. Photographer: Vince Damiano Description: View of hazardous waste 55-gallon drum with no indication of its contents or waste codes in the DSA. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 25 Location: Kiewit Offshore Services LTD City: Ingleside County/Parish: San Patricio State: Texas Photo File Name: DSCN7117 Date of Photo: 03/12/2024 Time of Photo: 14:06 hrs. Photographer: Vince Damiano Description View of hazardous waste 55-gallon drum with no indication of its contents or waste code in the DSA. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 26 Location: Kiewit Offshore Services LTD City: Ingleside County/Parish: San Patricio State: Texas Photo File Name: DSCN7118 Date of Photo: 03/12/2024 Time of Photo: 14:06 hrs. Photographer: Vince Damiano Description: View of hazardous waste 55-gallon drum with no indication of its contents or waste codes in the DSA. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 27 Location: Kiewit Offshore Services LTD City: Ingleside County/Parish: San Patricio State: Texas Photo File Name: DSCN7119 Date of Photo: 03/12/2024 Time of Photo: 14:08 hrs. Photographer: Vince Damiano Description: View of 55-gallon drum of "Hose Oil" found in the DSA. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 28 Location: Kiewit Offshore Services LTD City: Ingleside County/Parish: San Patricio State: Texas Photo File Name: DSCN7120 Date of Photo: 03/12/2024 Time of Photo: 14:08 hrs. Photographer: Vince Damiano Description: View of 55-gallon drum of "Oily Water" found in the DSA. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 29 Location: Kiewit Offshore Services LTD City: Ingleside County/Parish: San Patricio State: Texas Photo File Name: DSCN7121 Date of Photo: 03/12/2024 Time of Photo: 14:09 hrs. Photographer: Vince Damiano Description: Overview of the DSA. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 30 Location: Kiewit Offshore Services LTD City: Ingleside County/Parish: San Patricio State: Texas Photo File Name: DSCN7122 Date of Photo: 03/12/2024 Time of Photo: 14:09 hrs. Photographer: Vince Damiano Description: Example of label found on one of the 55-gallon Universal Paint Waste drums in the DSA. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 31 Location: Kiewit Offshore Services LTD City: Ingleside County/Parish: San Patricio State: Texas Photo File Name: DSCN7123 Date of Photo: 03/12/2024 Time of Photo: 14:09 hrs. Photographer: Vince Damiano Description: View of paint waste drum with a budging top in the DSA UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 32 Location: Kiewit Offshore Services LTD City: Ingleside County/Parish: San Patricio State: Texas Photo File Name: DSCN7124 Date of Photo: 03/12/2024 Time of Photo: 14:10 hrs. Photographer: Vince Damiano Description: View of one of two unlabeled 55-gallon drums found in the DSA. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 33 Location: Kiewit Offshore Services LTD City: Ingleside County/Parish: San Patricio State: Texas Photo File Name: DSCN7125 Date of Photo: 03/12/2024 Time of Photo: 14:10 hrs. Photographer: Vince Damiano Description: View of two of two unlabeled 55-gallon drums found in the DSA. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 34 Location: Kiewit Offshore Services LTD City: Ingleside County/Parish: San Patricio State: Texas Photo File Name: DSCN7126 Date of Photo: 03/12/2024 Time of Photo: 14:13 hrs. Photographer: Vince Damiano Description: Overview of second waste storage area in the DSA. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 35 Location: Kiewit Offshore Services LTD City: Ingleside County/Parish: San Patricio State: Texas Photo File Name: DSCN7127 Date of Photo: 03/12/2024 Time of Photo: 14:13 hrs. Photographer: Vince Damiano Description: View of seven unlabeled 20-liter containers of lube oil waste in the DSA. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 36 Location: Kiewit Offshore Services LTD City: Ingleside County/Parish: San Patricio State: Texas Photo File Name: DSCN7128 Date of Photo: 03/12/2024 Time of Photo: 14:13 hrs. Photographer: Vince Damiano Description: View of four 55-gallon drums of jet fuel waste labeled as hazardous waste in the DSA. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 37 Location: Kiewit Offshore Services LTD City: Ingleside County/Parish: San Patricio State: Texas Photo File Name: DSCN7129 Date of Photo: 03/12/2024 Time of Photo: 14:13 hrs. Photographer: Vince Damiano Description: View of label on 55-gallon drums of jet fuel waste labeled as hazardous waste in the DSA. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 38 Location: Kiewit Offshore Services LTD City: Ingleside County/Parish: San Patricio State: Texas Photo File Name: DSCN7130 Date of Photo: 03/12/2024 Time of Photo: 14:13 hrs. Photographer: Vince Damiano Description: View of label on 55-gallon drums of jet fuel waste labeled as hazardous waste in the DSA. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 39 Location: Kiewit Offshore Services LTD City: Ingleside County/Parish: San Patricio State: Texas Photo File Name: DSCN7131 Date of Photo: 03/12/2024 Time of Photo: 14:13 hrs. Photographer: Vince Damiano Description: View of one crushed 55-gallon container and five 5-gallon containers that are not labeled in the DSA. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 40 Location: Kiewit Offshore Services LTD City: Ingleside County/Parish: San Patricio State: Texas Photo File Name: DSCN7132 Date of Photo: 03/12/2024 Time of Photo: 14:14 hrs. Photographer: Vince Damiano Description: Damaged and unlabeled 55-gallon waste drums in the DSA. The facility did not know the contents of the drums. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 41 Location: Kiewit Offshore Services LTD City: Ingleside County/Parish: San Patricio State: Texas Photo File Name: DSCN7133 Date of Photo: 03/12/2024 Time of Photo: 14:17 hrs. Photographer: Vince Damiano Description: Close up view of bulging 55-gallon containers of unknown contents in the DSA. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 42 Location: Kiewit Offshore Services LTD City: Ingleside County/Parish: San Patricio State: Texas Photo File Name: DSCN7134 Date of Photo: 03/12/2024 Time of Photo: 14:19 hrs. Photographer: Vince Damiano Description: View of punctured aerosol cans in 55-gallon trash can in the DSA. APPENDIX 2. KIEWIT OFFSHORE SERVICES LTD 03/20/24 AND 03/26/24 RESPONSE Andrew Gates From: Sent: To: Cc: Subject: Attachments: Diana.Villenas <Diana.Villenas@kiewit.com> Tuesday, March 26, 2024 6:48 PM Young-Dahl, Erin; Hannah.Johnson Andrew Gates; Johnson, Joyce-R6; Vince Damiano; Tim.Storheim; Bo.Johnson RE: [External]Follow-up from EPA Inspection 3/12/2024 Paint Drums Paint Booth 1 and 2.jpg; Undetermined Waste Warehouse 1.jpg; Undetermined Waste Warehouse 2.jpg; Undetermined Waste Warehouse 3.jpg CAUTION: Don't open links or attachments unless you recognize the sender and know they are safe. All, Please find our corrective actions attached and a brief description of each below - 1. Paint Drums at Paint Booths 1 and 2: Drums are appropriately labeled with lids fixed. 2. Undetermined Waste Warehouse (Central Accumulation Area) 1 and 2: We're still waiting for waste determinations to be finalized by our Vendor. As such, you'll find Hazardous Waste and Pending Analysis stickers on each. 3. Undetermined Waste Warehouse 3: This waste stream was identified as non-hazardous based on SDS and generator knowledge per New Fortress Energy (NFE). Specifically, the waste is a mixture of AFFF/water/dirt. As always, I'm available via email or at my direct cell below if you have any questions. Thank you, Diana Villenas Diana Villenas District Environmental Manager KIEWIT OFFSHORE SERVICES, LTD 2440 Kiewit Road, Ingleside, TX 78362 361-244-1270 Cell kiewit.com Please consider the environment before printing this e-mail From: Young-Dahl, Erin <YoungDahl.Erin@epa.gov> Sent: Wednesday, March 20, 2024 9:51 AM To: Hannah.Johnson <Hannah.Johnson@kiewit.com> Cc: Andrew Gates <andrew.gates@erg.com>; Johnson, Joyce-R6 <johnson.joyce-r6@epa.gov>; Vince Damiano <Vince.Damiano@erg.com>; Tim.Storheim <Tim.Storheim@kiewit.com>; Bo.Johnson <Bo.Johnson@kiewit.com>; 1 Appendix 2 Page 1 of 8 Diana.Villenas <Diana.Villenas@kiewit.com> Subject: RE: [External]Follow-up from EPA Inspection 3/12/2024 Some people who received this message don't often get email from youngdahl.erin@epa.gov. Learn why this is important Excellent! Thank you! Erin From: Hannah.Johnson <Hannah.Johnson@kiewit.com> Sent: Wednesday, March 20, 2024 9:44 AM To: Young-Dahl, Erin <YoungDahl.Erin@epa.gov> Cc: Andrew Gates <andrew.gates@erg.com>; Johnson, Joyce-R6 <johnson.joyce-r6@epa.gov>; Vince Damiano <Vince.Damiano@erg.com>; Tim.Storheim <Tim.Storheim@kiewit.com>; Bo.Johnson <Bo.Johnson@kiewit.com>; Diana.Villenas <Diana.Villenas@kiewit.com> Subject: RE: [External]Follow-up from EPA Inspection 3/12/2024 Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open attachments or click on provided links. Good morning, I have attached a couple photos to show that we have implemented the labeling correction that you mentioned below for paint waste. Thank you so much for informing us of that discrepancy! 2 Appendix 2 Page 2 of 8 We are still diligently working on the remaining AOC's mentioned during the inspection and will continue to send over proof of corrective actions as they are completed. Please feel free to reach out with questions. Sincerely, Hannah Johnson Environmental Coordinator Kiewit Offshore Services, LTD. 2440 Kiewit Rd. Ingleside, TX 78362 3 Appendix 2 Page 3 of 8 Mobile: 361.484.6182 Email: Hannah.Johnson@kiewit.com From: Young-Dahl, Erin <YoungDahl.Erin@epa.gov> Sent: Friday, March 15, 2024 9:59 AM To: Diana.Villenas <diana.villenas@kiewit.com> Cc: Andrew Gates <andrew.gates@erg.com>; Johnson, Joyce-R6 <johnson.joyce-r6@epa.gov>; Vince Damiano <Vince.Damiano@erg.com>; Tim.Storheim <Tim.Storheim@kiewit.com>; Hannah.Johnson <Hannah.Johnson@kiewit.com>; Bo.Johnson <Bo.Johnson@kiewit.com> Subject: RE: [External]Follow-up from EPA Inspection 3/12/2024 Hi Diana, Thanks so much for sending those photos! One quick note: the universal paint waste containers need to say "Universal Waste: Paint and Paint-Related Waste." Since those label stickers already have "Universal Waste" printed on them, the only words that are missing are the "Paint and Paint-Related Waste." It seems cumbersome, I know, but it is literally what is printed in the regulations, and we are beholden to it. The regs for PPRW are found here. Thank you again for sending those corrections so quickly! Those changes look great. Please don't hesitate to reach out if you have any questions. Best, -Erin Young-Dahl She/her/hers Physical Scientist RCRA Enforcement Section U.S. Environmental Protection Agency, Region 6 E-mail: youngdahl.erin@epa.gov Office: (214) 665-3166 4 Appendix 2 Page 4 of 8 3/26/24 Follow-up: Paint Drums Paint Booth 1 and 2 Appendix 2 Page 5 of 8 3/26/24 Follow-up: Undetermined Waste Warehouse 1 Appendix 2 Page 6 of 8 3/26/24 Follow-up: Undetermined Waste Warehouse 2 Appendix 2 Page 7 of 8 3/26/24 Follow-up: Undetermined Waste Warehouse 3 Appendix 2 Page 8 of 8 APPENDIX 3. KIEWIT OFFSHORE SERVICES LTD 03/13/24 RESPONSE From: To: Cc: Subject: Date: Attachments: Diana.Villenas Vince Damiano; Bo.Johnson; Tim.Storheim; Hannah.Johnson Andrew Gates; Johnson, Joyce-R6; Young-Dahl, Erin RE: [External]Follow-up from EPA Inspection 3/12/2024 Wednesday, March 13, 2024 6:19:34 PM image020.png Certificate of Adequacy_exp May2027.pdf Antifoam 71D5_PLUS_SDS_USA_(GHS)_English (002).pdf RO Antiscalant PC-191T_SDS_USA_(GHS)_English.pdf UnleadedGas.pdf Permaclean PC-56_SDS_USA_(GHS)_English.pdf CAUTION: Don't open links or attachments unless you recognize the sender and know they are safe. Vince, Thank you for coming out. Attached are records requested during yesterday's visit on Wednesday, March 12, 2024. Following the discussed Areas of Concern, you will additionally find corrective actions implemented below. I would also like to confirm that a waste determination for Contaminated Gas and the Biocide PC56 were the only waste determinations requested in your email below. Corrective actions for the bulging containers and timeline will be submitted soon. Please let me know if you have any additional questions. Corrective Actions implemented at the Warehouse, Central Accumulation Area - 1. The following photos show the corrected "UNIVERSAL WASTE" labels naming the waste as "PAINT WASTE". Appendix 3 Page 1 of 58 2. The following photos are of the 2 drums that were identified in the paint waste area without labels. Appendix 3 Page 2 of 58 3. The following photos show the proper "USED OIL" stickers were placed on the drums with free flowing oil inside. Appendix 3 Page 3 of 58 4. The following photo is of the lube oil pending sampling with proper labels. 5. The following photo shows the new aisle spacing of at least 30in. Appendix 3 Page 4 of 58 6. The following photo shows the two used battery bins properly labeled with "UNIVERSAL WASTE". Appendix 3 Page 5 of 58 Corrective Actions implemented at the Painting Building - 7. The following photos show the can crushing area that was cleaned up and only housing the appropriate empty paint cans. 8. The following photo shows the drum of aerosol cans on the west side of the paint building with the correct labeling. Appendix 3 Page 6 of 58 Regards, Diana Villenas Diana Villenas District Environmental Manager KIEWIT OFFSHORE SERVICES, LTD 2440 Kiewit Road, Ingleside, TX 78362 361-244-1270 Cell kiewit.com Please consider the environment before printing this e-mail Appendix 3 Page 7 of 58 ) United States Coast Guard Certificate OfAdequacy for Reception Facility Thi t't'tlilks that: -KI- EW-IT- !lF- FSl- lllR-E - Sl:R-Vl- l'F S, L-TIJ-. -- has focilitiesa<icqualc lo rccdvc MARl'OI. I MARl'OL V h,1m 1..:o:an1:,1in hi1H, ;i., l<''iu1r,;.I h) the lnh:nuliuna! ('umrnlion for the P1c\cnlivn M l'iillutivn rrom Ship, 1973. 1\s motlilicJ by thc prutoco! or 1978 (MAHl'Ot 7i7l\), Tllc i\o I) l'tc\,;t1t l'ulh11ion ffllm Ship. J3 lJS(.' 1901 1912 und tMocialctl lJ,S. llcgul;1lion in 33 t'l'H 15R, lhis (<n- ifkJ\\' h j,,u,;J pi.lru.inl to an :1ppli(atilm dJt,;,I l8M,\ \'2021 nnJ nn impl'(lion 1!Jt..:J 181'1AY2022, (opi,: of which nrc alluchcd, amJ pail ofthi,; cc1til1c.1tc. l:ath tamin.11 11,1,:J in 1hc apphc.iti,m kill 111aint1in a rop)' <,f 1hi c,'r1ifkatc ,wnilali!c for inpc..:tiun hy Cv.,t Guard pcrr-ouncl nnd the mastcr, operator, ag,:nt, or 011 ncr of nny l1ip U\lllB nr int\'ndinf !o iN: 1'11, trmarML Th\' lcmlmJI r\fl 1i.:1ot1 in d1M, ilkntili,:d in lhc au.1d1rJ applk;,\ion hall ntify lho; U.S. C'oait Uu:1rJ l'a11tain of lhc l'ort (COTP) in writin!:l 110.cr uny (If I.he 1cccption lacil1l) infom1:1.1ion or 10:miin.il 'r}<Ht infomn1inn idc1111ikd in ).1 ('I'll \ 5X. ll,5 chang,:. The trnn(nal'pmt m,11,:r, op,:rJtor, ur pc1,1,n in dmgl' h li.ihlc for \'iul;1tiot1\ oflhc pru,bions of 33 CFR 158 11nJ ma)' hil ubjl'l'I lo thc m.i.,imum pcnalty under 33 tJSt' Ji}OX, ll\ :1dju\tl1! for iull.1tion an,l found M 3l ('JI{ 27.3 1 hc trnnin;1l.'po11 O\\lllf, op,;1,,lor, llr p,:n<m in d1:iri;c hall cmurc 1Jiat tlw rcc.:ptiun focilily lmld l'ach l.itr, locul, ond ti.dc1,1I pnnil 11ml lk,nc r,:quilcJ hy cn1iwnmcn1.1l l.m unJ rq;ul.i!i@\ concnnin l'Pth.J.);!1', ll 1idut\ and mb,IUrcs rnn1ai11i11g oil or noxinu liquid M1b111nccs. Thi\ cc11ilicalc ccrtilics t'omp!iancl!' with 11pplic,1b!c s,:cliun of 31 <TR ISX, bul Jo,;\ m,t (t:r1if> u,mpl1,11\{\' V,tth any 1,thc1 law or ICJ(Ulalion. 01 until JO tl,1ys nlkr \hi.' opcrntor dtcd (Ht the cntifk.it hang.:; ;ii Thh Ccrllflc111r 1:1pho: 18MAY2027 s )<'lln from datt or lm111nH U. SAUK ('f>lt, IJSCO, lly tlir\'diun 1)ri,d Nmm of con n.11, Sector l'of!UJ\ ( tui\li Waiver U1erripliun (b1icf dnniption) \ J Dept. cif Homeland Sec., USCG, CGS40l (Rcv01-20l9l{vl), OMO No. 1625-0045, Pre';lous [diUons iHC Obso!cle P.igclof2 Appendix 3 Page 8 of 58 \ i l't1tifirnlt' 111" J\(kq11:11:y lnsp,ction l -'111h11:-.v11\l'11t ln h:1'.t!o1t-_'.lk1 r,i. )-1y11!-,_1 Lu iht_y in_pnl1011_! 111,pl'l'IOI', Nnml' (IYJ"'d Ill fll inll'd) fttvMrrsb.-giii,tJ !b,,._-nic?J1eS1.L , ?d"":::;g.-mm, - --- -------- Dept. of Homeland Sec, USCG, CG-$401 {Bcv0l2019l(v3), 0MB No. 162S-004S, Previous [dillons are Obsolete Appendix 3 Page 9 of 58 P.ige 'lof 2 APPLICATION FOR CERTIFICATE OF ADEQUACY (COA) FOR RECEPTION FACILITIES FORM A 1. General. The United States as a party to the International Convention for the Prvent!on of Pollut!on from Ships, 1973, as modified by the Protocol of 1978 relating thereto (MARPOL 73/78) Is required by Annex I and the Act to Prevent Po!lutlon from Ships (33 U,S,C. 1901 et. seq.) to Issue certificates to reception facl!ities verifying their adequacy to receive oily waste from ships. Regulatlons Implementing t!le United Stateswaste reception facility program are in 33 CFR 158 Code of Federal Regu!allons. 2. The Certificate of Adequacy remains valid until suspended or revoked. 3. Upon suspension or revocation, a Certificate of Adequacy shall be promptly returned to the Issuing U.S. Coast Guard Captain of the Port (COTP). 4. The Application, as submitted, shall be permanently a_ttached to and become a part of the Certificate of Adequacy upon Issuance. 5. A copy of the Certificate of Adequacy with the Application attached shall be available at each port and terminal to which 1t applles and shall be available for Inspection by Coast Guard personnel and the master, person In charge or agent of an oceangoing ship using or Intending to use the reception facility. 6. A copy of the Certificate of Adequacy shall be attached to the operations manual for marine oil transfer facilities described in 33 CFR 154.300. 7. The terminal/port person In charge Identified !n the Applicatlon shall notify the U.S. Coast Guard Captain of the Port {COTP) In writing within 10 days after any of the reception faciHty Information supplled under 33 CFR 158.140 changes. The termlnal/port person in charge shall notify the U.S, Coast Guard COTP In writing within 30 days after any of the termlnal/port information supplied under 33 CFR 158.140 changes. 8. C!v!f Penalties. A person who after notice and an opportunity for a hearing, Is found: a. to have made a false, fictitious or fraudulent statement or representation in any matter in which a statement or representation ls required to be inade under the Act to Prevent Pollution from Ships, or the regulations thereunder, shall be liable to the United States for a civil penalty, not to exceed $8,000 for each statement or representation; or b. to have violated the Act to Prevent Pollution from Ships, or the regulations Issued thereunder, shall be liable to the United States for a clv!I penalty not to exceed $40,000 for each violation. GENERAL INSTRUCTIONS THE CERTIFICATE OF ADEQUACY (COA) APPLICATION FORM A The folloWing instructions for lndlvldual !lne Items are provided to assist In completing the Application for a Certificate of Adequacy (COA). If you have any questions or need assistance in completing the Appllcalion, please contact the U.S. Coast Guard Captain of the Port (COTP) for your area. A list of definitions, which you may find helpful In completing the Application, Is provided In 33 Code of Federal Regulations Part 158 (33 CFR 158), 1.A. Indicate terminal If you are applying as a single terminal or Indicate port If you are app!y!ng as a group of term!nats. Do not mark "COTP Designated Port" unless you have a letter from the COTP with such a designation. COTP designation of a facility or an area as a port Is for unusual situations. !f you have a question as to whether COTP designation as a port applles to your situation, contact the COTP for your area. 1.C.{1) For a terminal, enter the company or corporation name. For a port, enter the company, corporation, port authority, or organization by which the group of terminals Is legally known. 1.C,(3) Enter the name of a person authorized to act In behalf of the terminal or port, 1.C.(5) For a terminal, enter the company or c9rporation name. For a port, enter the company, corporation, port authority, or organization of which the person in charge Is a member. 1.0.(1) Those applying as terminals do not have to complete this section, since the information is the same as In 1.C. Ports are to Provide this Information for each of the terminals Indicated in 1.B. 2.A.(1} Enter the company or corporation name of the reception facillty. 2,A.{5) Check as many of the types of reception facilities as may be used. 3.A Enter the value as calculated on the Coast Guard optional worksheet Hne "AY" or other calculation sheet. 3.8. Enter the value as calculated on the Coast Guard optlonal worksheet llne "AZ" or other calculation sheet. Calculate from vessel traffic at the terminal/port for the last 12 months. 3.C. Describe the waste the reception facility can receive. Enter "oil" for all types of oily waste. \ 3.0. Describe the ship types or principal trades, e.g., crude tankers, product tankers, container ships, grain ships, fishing vessels, etc. 3.E. Enter a value based upon discharging waste through a single connection. This ls necessary since ships are not required to discharge waste through multiple connections. Oily ballast discharge rates may be based on discharging through more than one connection If all of the vessels and reception facilities have this capability. 3.F. Enter a value upon discharging waste through a single connection. This ls necessary since ships are not required to discharge waste through multiple connections. CG-5401 A (04/15) Appendix 3 Page 10 of 58 DEPARTMENT OF HOMELAND SECURITY 0MB No.1625-0045 U.S. Coast Guard Exp. Date: 08/31/2018 j APPLICATION FOR A RECEPTION FACILITY CERTIFICATE OF ADEQUACY FOR OIL FORM A 1. PARTICULARS OF TERMINAL OR PORT A. APPLYING AS: (Check one) lx]Terminal D Port D COTP Designated Port B. NUMBER OF TERMINALS TO WHICH THIS APPLICATION APPLIES: ------- C. TERMINAL/PORT INFORMATION (1) NAME OF TERMINAL/PORT: Kiewit Offshore Services, Ltd. (2) ADDRESS OF TERMINAL/PORT: 2440 Kiewit Road, Ingleside, Texas 70362 (3) NAME OF TERMINAL/PORT PERSON-IN-CHARGE: (4) TITLE/POSITION: (5) ORGANIZATION: (6) OFFICE PHONE NUMBER: Shea Page Fae I l I ty Secur l ty Off I cer Kiewl t Offshore Services, Ltd. 361-222-4664 D. INDIVIDUAL TERMINAL INFORMATION. If applying as a port, list the Information indicated for each terminal In the port. If more space is needed, continue on a separate sheet of paper and attach to the back of the application. The signature of the person in charge of the terminal acknowledges that the terminal agrees and volunteers to being ) considered as a member of the port, described in section 1, for purposes of these reception facilities. Complete the terminal name, location, etc. below. (1) NAME OF TERMINAL: (a) ADDRESS OF TERMINAL: (b) NAME!flTLE PERSON-IN-CHARGE: ___________________ (c) OFFICE PHONE NUMBER:: (d) SIGNATURE OF TERMINAL PERSON-IN-CHARGE: (2) NAME OF TERMINAL: (a) ADDRESS OF TERMINAL: (b) NAME!flTLE PERSON-IN-CHARGE: ___________________ (c) OFFICE PHONE NUMBER:: (d) SIG NATURE OF TERMINAL PERSON-IN-CHARGE: CG-5401A (04/15) Appendix 3 Page 11 of 58 Page 1 of 3 2. PARTICULARS OF RECEPTION FACILITY. Enter information for each reception facility used by the terminal/port. If necessary, continue on a separate sheet and attach to the back of the Application. ; A. TYPE OF RECEPTION FACILITY: {Check those that apply) OFixed 00 Mobile D Tank Truck D Tank Barge D Other (Describe Other): _____________________________ (1) NAME OF RECEPTION FACILITY: Nature Environmental & Marine Services, LLC (a) ADDRESS: 8713 Root St Corpus Christi, TX 78409 (b) NAME/TITLE PERSON-IN-CHARGE: _u_u_"'_'_'--__u _, _ ' _______________ (c) OFFICE PHONE NUMBER: 866-770-7952 option #1 (d) SIGNATURE OF TERMINAL PERSON-IN-CHARGE: 3. RECEPTION AND TRANSFER REQUIREMENTS A. ESTIMATED DAILY CAPACITY OF RECEPTION FACILITY: (metric tons) 8. ESTIMATED DAILY CAPACITY REQUIREMENT OF THE TERMINAL/PORT: (metric tons) C. TYPES OF WASTE THE RECEPTION FACILITY CAN RECEIVE: J..J..l..L':,j,:;: WaLei., t11<::J.l.Ut::: 1.UV!ll ::..l.UU'::Jt::, J.Jct..L..LctbL WctLel., UL.U<d.l. L-Yl--'t::b UJ.. U.J....LY V.l. Wct.::>Lt:: Wctl.t:J..::i D. SHIP TYPES OR PRINCIPAL TRADES OF SHIPS VISITING TERMINAL(S): ) E. OILY BALLAST WASTE TRANSFER RATE (GPM): (GPM) F. ALL OTHER OILY RESIDUES AND MIXTURES TRANSFER RATE (GPM): (GPM) G. RECEPTION FACILITY CAN RECEIVE ALL THE OILY BALLAST FROM SHIPS VISITING THE TERMINAL OR PORT WITHIN 10 HOURS OF WASTE TRANSFER COMMENCEMENT. Enter either 11YES1\ 11NOu, OR 11 N/A11 . (Yes, No, N/A) (If entering other than "YES" explain): with proper notification and ships pumps are capable H. RECEPTION FACILITY CAN RECEIVE ALL OTHER OILY RESIDUES AND MIXTURES FROM SHIPS VISITING THE TERMINAL OR PORT WITHIN 4 HOURS OF WASTE TRANSFER COMMENCEMENT. Enter either "YES", "NO", OR "N/A". (If entering other than "YES" explain): if ships pumps are capabable (Yes, No, N/A) I. RECEPTION FACILITY FOR OIL WASTE WILL BE PROVIDED WITHIN 24 HOURS OF NOTIFICATION. Enter either "YES", "NO", OR "N/A". (If entering other than "YES" explain): J. OILY WASTE WILL BE TRANSFERRED PRIOR TO SHIP LEAVING SHIP REPAIR YARD. Enter 1YES11, 11N01\ OR 11N/A11 , {If entering Qther than "YES" explain): (Yes, No, N/A) (Yes, No, N/A) CERTIFICATION CG-5401A (04/15) Appendix 3 Page 12 of 58 Page 2 of3 RECEPTION FACILITY INFORMATION SHEET \ I ********** THIS PAGE FOR COMPLETION BY U.S. COAST GUARD********** COAST GUARD COTP COMPLETE THE FOLLOWING INFORMATION AND FORWARD TO DISTRICT (m) FOR QUARTERLY SUBMISSION TO COMMANDANT (G-FAC-2) COTP ISSUING CERTIFICATE OF ADEQUACY: NAME OF TERMINAL/PORT: LOCATION OF TERMINAL/PORT (City/State): NAME OF PERSON IN CHARGE: PHONE NUMBER: TYPE OF WASTE THE RECEPTION FACILITY CAN RECEIVE: DAILY CAPACITY OF RECEPTION FACILITY (metric tons): OILY BALLAST WASTE TRANSFER RATE (GPM): \ ALL OTHER OILY RESIDUES AND MIXTURES TRANSFER RATE (GPM): Privacy Act Statement Authority: The United States as a p8rty to the International Convenllon for the Prevention of Pollution from Ships, 1973, as modified by the Protocol of 1978 relating thereto (MARPOL 73ll8) Is required by Annex I and the Act to Prevent Pollullon from Ships (33 U,S,C, 1901 et. seq.) to Issue certificates to receptlon facilities verifying their adequacy to receive oily waste from ships. Regulations Implementing the United States waste reception factllty program are In 33 CFR 158 Code of Federal Regulations. Purpose: Waterfront Facil!tles are required to be certlfted to have adequate reception capabllil!es when receiving Olly mixtures from oceangoing tankers and any other oceangoing ships of 400 gross tons or more. Routine Uses: Tha Information supplied on the form will ba used by and dlsc!osed to Coast Guard personnel. Addlt!onally, the Coast Guard may share the lnformat!on with law enforcement or other government agencies as necessary to respond to any Incidents that may occur as a res ult of any discharge of Oil pollutlon, or pursuant to Its published Privacy Act system of records notice. D!sclosure: Furnishing this Information ls voluntary: however, failure to furnish the requested Information may delay or prevent the Issuance of the Certificate of Adequacy (Form CG-5401). Jurden Statement: The Coast Guard estimates that the average burden for this report Is 3 hours. You may submit any comments concerning the accuracy of this burden estimate or any suggestions for reduclng the burden to: Commandant (CG-FAC-2), U.S. Coast Guard, 2703 Martin Luther King Jr Ave SE Stop 7501, Washington, DC 20593-7501 or Office 9f Management and Bodgel, Paperwork Reduction Project {1625-0045), Washington, DC 20593, CG-5401 A (04/15) Submit the application to: THE LOCAL CAPTAIN OF THE PORT OFFICE Appendix 3 Page 13 of 58 Page 3 of 3 Appendix 3 Page 14 of 58 Appendix 3 Page 15 of 58 Appendix 3 Page 16 of 58 SAFETY DATA SHEET NALCO 71D5 PLUS Section: 1. PRODUCT AND COMPANY IDENTIFICATION Product name : NALCO 71D5 PLUS Other means of identification : Not applicable. Recommended use : ANTIFOAM Restrictions on use : Refer to available product literature or ask your local Sales Representative for restrictions on use and dose limits. Company : Nalco Company 1601 W. Diehl Road Naperville, Illinois 60563-1198 USA TEL: (630)305-1000 Emergency telephone number : (800) 424-9300 (24 Hours) CHEMTREC Issuing date : 05/04/2015 Section: 2. HAZARDS IDENTIFICATION GHS Classification Flammable liquids Acute toxicity (Inhalation) Aspiration hazard : Category 4 : Category 4 : Category 1 GHS Label element Hazard pictograms : Signal Word Hazard Statements Precautionary Statements : Danger : Combustible liquid May be fatal if swallowed and enters airways. Harmful if inhaled. : Prevention: Keep away from heat/sparks/open flames/hot surfaces. - No smoking. Avoid breathing dust/ fume/ gas/ mist/ vapours/ spray. Use only outdoors or in a well-ventilated area. Wear protective gloves/ eye protection/ face protection. Response: IF SWALLOWED: Immediately call a POISON CENTER or doctor/physician. IF INHALED: Remove victim to fresh air and keep at rest in a position comfortable for breathing. Call a POISON CENTER or doctor/ physician if you feel unwell. Do NOT induce vomiting. In case of fire: Use dry sand, dry chemical or alcoholresistant foam for extinction. Storage: 1 / 11 Appendix 3 Page 17 of 58 SAFETY DATA SHEET NALCO 71D5 PLUS Other hazards Store in a well-ventilated place. Keep cool. Store locked up. Disposal: Dispose of contents/ container to an approved waste disposal plant. : None known. Section: 3. COMPOSITION/INFORMATION ON INGREDIENTS Pure substance/mixture : Mixture Chemical Name Straight Run Middle Distillate Hydrotreated Light Distillate Polypropylene Glycol 1-Octanol Fatty Alkyl Polyglycol Aliphatic alcohol Paraffin Wax CAS-No. 64741-44-2 64742-47-8 25322-69-4 111-87-5 Proprietary Proprietary 8002-74-2 Concentration: (%) 30 - 60 10 - 30 5 - 10 1 - 5 1 - 5 1 - 5 1 - 5 Section: 4. FIRST AID MEASURES In case of eye contact In case of skin contact If swallowed If inhaled Protection of first-aiders Notes to physician Most important symptoms and effects, both acute and delayed : Rinse with plenty of water. Get medical attention if symptoms occur. : Wash off with soap and plenty of water. Get medical attention if symptoms occur. : Do NOT induce vomiting. Never give anything by mouth to an unconscious person. Aspiration hazard if swallowed - can enter lungs and cause damage. Get medical attention immediately. : Get medical attention if symptoms occur. : In event of emergency assess the danger before taking action. Do not put yourself at risk of injury. If in doubt, contact emergency responders.Use personal protective equipment as required. : Treat symptomatically. : See Section 11 for more detailed information on health effects and symptoms. Section: 5. FIREFIGHTING MEASURES Suitable extinguishing media : Use extinguishing measures that are appropriate to local circumstances and the surrounding environment. Unsuitable extinguishing media : High volume water jet Specific hazards during firefighting : Fire Hazard Keep away from heat and sources of ignition. Flash back possible over considerable distance. Hazardous combustion products : Carbon oxides 2 / 11 Appendix 3 Page 18 of 58 SAFETY DATA SHEET NALCO 71D5 PLUS Special protective equipment : Use personal protective equipment. for firefighters Specific extinguishing methods : Fire residues and contaminated fire extinguishing water must be disposed of in accordance with local regulations. In the event of fire and/or explosion do not breathe fumes. Section: 6. ACCIDENTAL RELEASE MEASURES Personal precautions, protective equipment and emergency procedures : Remove all sources of ignition. Refer to protective measures listed in sections 7 and 8. Environmental precautions : Do not allow contact with soil, surface or ground water. Methods and materials for containment and cleaning up : Eliminate all ignition sources if safe to do so. Stop leak if safe to do so. Contain spillage, and then collect with non-combustible absorbent material, (e.g. sand, earth, diatomaceous earth, vermiculite) and place in container for disposal according to local / national regulations (see section 13). Flush away traces with water. For large spills, dike spilled material or otherwise contain material to ensure runoff does not reach a waterway. Do not flush into surface water or sanitary sewer system. Section: 7. HANDLING AND STORAGE Advice on safe handling : Take necessary action to avoid static electricity discharge (which might cause ignition of organic vapours). Keep away from fire, sparks and heated surfaces. Wash hands thoroughly after handling. Use only with adequate ventilation. Conditions for safe storage : Keep away from heat and sources of ignition. Keep away from oxidizing agents. Keep out of reach of children. Keep container tightly closed. Store in suitable labeled containers. Suitable material : Keep in properly labelled containers. Unsuitable material : not determined Section: 8. EXPOSURE CONTROLS/PERSONAL PROTECTION Components with workplace control parameters Components CAS-No. Hydrotreated Light Distillate 64742-47-8 Polypropylene Glycol 1-Octanol 25322-69-4 111-87-5 Form of exposure TWA TWA TWA (Mist) TWA (Mist) STEL (Mist) TWA (Aerosol.) TWA Permissible concentration 500 ppm 2,000 mg/m3 200 mg/m3 5 mg/m3 5 mg/m3 10 mg/m3 10 mg/m3 50 ppm 3 / 11 Appendix 3 Page 19 of 58 Basis OSHA Z1 ACGIH OSHA Z1 NIOSH REL NIOSH REL WEEL WEEL SAFETY DATA SHEET NALCO 71D5 PLUS Paraffin Wax 8002-74-2 TWA (Fumes) TWA (Fumes) 2 mg/m3 2 mg/m3 ACGIH NIOSH REL Engineering measures : Effective exhaust ventilation system Maintain air concentrations below occupational exposure standards. Personal protective equipment Eye protection : Safety glasses Hand protection : Wear protective gloves. Gloves should be discarded and replaced if there is any indication of degradation or chemical breakthrough. Skin protection : Wear suitable protective clothing. Respiratory protection : When workers are facing concentrations above the exposure limit they must use appropriate certified respirators. Hygiene measures : Handle in accordance with good industrial hygiene and safety practice. Remove and wash contaminated clothing before re-use. Wash face, hands and any exposed skin thoroughly after handling. Section: 9. PHYSICAL AND CHEMICAL PROPERTIES Appearance Colour Odour Flash point : Liquid : clear : hydrocarbon-like : 92 C Method: ASTM D 93, Pensky-Martens closed cup pH Odour Threshold Melting point/freezing point Initial boiling point and boiling range Evaporation rate Flammability (solid, gas) Upper explosion limit Lower explosion limit Vapour pressure Relative vapour density Relative density Density Water solubility Solubility in other solvents : Not applicable. : no data available : PRECIPITATION POINT: 10 C POUR POINT: -45 C, ASTM D-1177 : 132.2 C Method: ASTM D 86 : no data available : no data available : no data available : no data available : 5.1 mm Hg (37.8 C) : no data available : 0.84 (25 C) ASTM D-1298 : 0.84 g/cm3 7.0 lb/gal : insoluble : no data available 4 / 11 Appendix 3 Page 20 of 58 SAFETY DATA SHEET NALCO 71D5 PLUS Partition coefficient: noctanol/water Auto-ignition temperature Thermal decomposition temperature Viscosity, dynamic : no data available : no data available : no data available : 10 mPa.s (22.2 C) Method: ASTM D 2983 Viscosity, kinematic : 7.52 mm2/s (22.2 C) Method: ASTM D 445 VOC : 57.9 % EPA Method 24 Section: 10. STABILITY AND REACTIVITY Chemical stability : Stable under normal conditions. Possibility of hazardous reactions Conditions to avoid : No dangerous reaction known under conditions of normal use. : Heat, flames and sparks. Incompatible materials : Oxidizing agents Bases Hazardous decomposition products : Oxides of carbon Section: 11. TOXICOLOGICAL INFORMATION Information on likely routes of : Inhalation, Eye contact, Skin contact exposure Potential Health Effects Eyes : Health injuries are not known or expected under normal use. Skin : May be harmful in contact with skin. Ingestion : May be fatal if swallowed and enters airways. Inhalation : Health injuries are not known or expected under normal use. Chronic Exposure : Health injuries are not known or expected under normal use. Experience with human exposure Eye contact : No symptoms known or expected. Skin contact : No symptoms known or expected. Ingestion : Vomiting Inhalation : No symptoms known or expected. Toxicity 5 / 11 Appendix 3 Page 21 of 58 SAFETY DATA SHEET NALCO 71D5 PLUS Product Acute oral toxicity : LD50 rat: > 15,380 mg/kg Test substance: Similar Product Acute inhalation toxicity : Acute toxicity estimate : 3.38 mg/l Exposure time: 4 h Acute dermal toxicity : LD50 rabbit: > 3,038 mg/kg Test substance: Similar Product Skin corrosion/irritation : Species: Rabbit Result: 3.1 Method: Draize Test Test substance:Similar Product Serious eye damage/eye irritation : Species: rabbit Result: 6.0 Method: Draize Test Test substance: Similar Product Respiratory or skin sensitization Carcinogenicity IARC : no data available No component of this product present at levels greater than or equal to 0.1% is identified as probable, possible or confirmed human carcinogen by IARC. OSHA NTP Reproductive effects Germ cell mutagenicity Teratogenicity STOT - single exposure STOT - repeated exposure Aspiration toxicity No component of this product present at levels greater than or equal to 0.1% is identified as a carcinogen or potential carcinogen by OSHA. No component of this product present at levels greater than or equal to 0.1% is identified as a known or anticipated carcinogen by NTP. : no data available : no data available : no data available : no data available : no data available : no data available Section: 12. ECOLOGICAL INFORMATION Ecotoxicity Environmental Effects : Toxic to aquatic life with long lasting effects. 6 / 11 Appendix 3 Page 22 of 58 SAFETY DATA SHEET NALCO 71D5 PLUS Product Toxicity to fish : LC50 Oncorhynchus mykiss (rainbow trout): 310 mg/l Exposure time: 96 hrs Test substance: Product LC50 Pimephales promelas (fathead minnow): 190 mg/l Exposure time: 96 hrs Test substance: Similar Product NOEC Oncorhynchus mykiss (rainbow trout): < 78 mg/l Exposure time: 96 hrs Test substance: Product NOEC Pimephales promelas (fathead minnow): 100 mg/l Exposure time: 96 hrs Test substance: Similar Product Toxicity to daphnia and other aquatic invertebrates : LC50 Daphnia magna (Water flea): 220 mg/l Exposure time: 48 hrs Test substance: Product LC50 Ceriodaphnia dubia: 4.32 mg/l Exposure time: 48 hrs Test substance: Similar Product EC50 Daphnia magna (Water flea): 130 mg/l Exposure time: 48 hrs Test substance: Product NOEC Daphnia magna (Water flea): 16 mg/l Exposure time: 48 hrs Test substance: Product NOEC Ceriodaphnia dubia: 2.50 mg/l Exposure time: 48 hrs Test substance: Similar Product Toxicity to daphnia and other aquatic invertebrates (Chronic toxicity) : NOEC: 1.5 mg/l Exposure time: 7 d Species: Ceriodaphnia dubia Test substance: Product LOEC: 3.0 mg/l Exposure time: 7 d Species: Ceriodaphnia dubia Test substance: Product NOEC: 0.19 mg/l Exposure time: 7 d Species: Ceriodaphnia dubia Test substance: Product LOEC: 0.38 mg/l Exposure time: 7 d Species: Ceriodaphnia dubia Test substance: Product EC25 / IC25: 0.40 mg/l Exposure time: 7 d 7 / 11 Appendix 3 Page 23 of 58 SAFETY DATA SHEET NALCO 71D5 PLUS Species: Ceriodaphnia dubia Test substance: Product Components Toxicity to algae : Hydrotreated Light Distillate EC50 : > 1,000 mg/l Exposure time: 48 h Components Toxicity to bacteria : Hydrotreated Light Distillate > 1,000 mg/l Persistence and degradability The organic portion of this preparation is expected to be inherently biodegradable. Total Organic Carbon (TOC) : 195,870 mg/l Chemical Oxygen Demand (COD): 2,200,000 mg/l Biochemical Oxygen Demand (BOD): Incubation Period Value 102,440 mg/l OECD 301 D (Closed Bottle) 28 Day 70-80% Test Descriptor Product Mobility The environmental fate was estimated using a level III fugacity model embedded in the EPI (estimation program interface) Suite TM, provided by the US EPA. The model assumes a steady state condition between the total input and output. The level III model does not require equilibrium between the defined media. The information provided is intended to give the user a general estimate of the environmental fate of this product under the defined conditions of the models. If released into the environment this material is expected to distribute to the air, water and soil/sediment in the approximate respective percentages; Air Water Soil : 10 - 30% : 30 - 50% : 30 - 50% The portion in water is expected to be soluble or dispersible. Bioaccumulative potential This preparation or material is not expected to bioaccumulate. Other information no data available Section: 13. DISPOSAL CONSIDERATIONS If this product becomes a waste, it is not a hazardous waste as defined by the Resource Conservation and Recovery Act (RCRA) 40 CFR 261, since it does not have the characteristics of Subpart C, nor is it listed under Subpart D. Disposal methods : The product should not be allowed to enter drains, water courses or the soil. Where possible recycling is preferred to disposal or incineration. If recycling is not practicable, dispose of in compliance with local regulations. Dispose of wastes in 8 / 11 Appendix 3 Page 24 of 58 SAFETY DATA SHEET NALCO 71D5 PLUS an approved waste disposal facility. Disposal considerations : Dispose of as unused product. Empty containers should be taken to an approved waste handling site for recycling or disposal. Do not re-use empty containers. Section: 14. TRANSPORT INFORMATION The shipper/consignor/sender is responsible to ensure that the packaging, labeling, and markings are in compliance with the selected mode of transport. Land transport (DOT) For Packages Less Than Or Equal To 119 Gallons: Proper shipping name : PRODUCT IS NOT REGULATED DURING TRANSPORTATION For Packages Greater Than 119 Gallons: Proper shipping name Technical name(s) UN/ID No. Hazard Class - Primary Packing group : COMBUSTIBLE LIQUID, N.O.S. : PETROLEUM HYDROCARBON : NA 1993 : COMBUSTIBLE LIQUID : III Air transport (IATA) Proper shipping name : PRODUCT IS NOT REGULATED DURING TRANSPORTATION Sea transport (IMDG/IMO) Proper shipping name : PRODUCT IS NOT REGULATED DURING TRANSPORTATION Section: 15. REGULATORY INFORMATION EPCRA - Emergency Planning and Community Right-to-Know Act CERCLA Reportable Quantity Components CAS-No. Naphthalene 91-20-3 Component RQ (lbs) 100 Calculated product RQ (lbs) 139860 SARA 304 Extremely Hazardous Substances Reportable Quantity This material does not contain any components with a section 304 EHS RQ. SARA 311/312 Hazards : Fire Hazard Acute Health Hazard SARA 302 : No chemicals in this material are subject to the reporting requirements of SARA Title III, Section 302. 9 / 11 Appendix 3 Page 25 of 58 SAFETY DATA SHEET NALCO 71D5 PLUS SARA 313 : This material does not contain any chemical components with known CAS numbers that exceed the threshold (De Minimis) reporting levels established by SARA Title III, Section 313. California Prop 65 This product does not contain any chemicals known to State of California to cause cancer, birth defects, or any other reproductive harm. INTERNATIONAL CHEMICAL CONTROL LAWS : TOXIC SUBSTANCES CONTROL ACT (TSCA) The substances in this preparation are included on or exempted from the TSCA 8(b) Inventory (40 CFR 710) CANADIAN ENVIRONMENTAL PROTECTION ACT (CEPA) The substance(s) in this preparation are included in or exempted from the Domestic Substance List (DSL). AUSTRALIA All substances in this product comply with the National Industrial Chemicals Notification & Assessment Scheme (NICNAS). CHINA All substances in this product comply with the Provisions on the Environmental Administration of New Chemical Substances and are listed on or exempt from the Inventory of Existing Chemical Substances China (IECSC). EUROPE The substances in this preparation have been reviewed for compliance with the EINECS or ELINCS inventories. JAPAN All substances in this product comply with the Law Regulating the Manufacture and Importation Of Chemical Substances and are listed on the Existing and New Chemical Substances list (ENCS). KOREA All substances in this product comply with the Toxic Chemical Control Law (TCCL) and are listed on the Existing Chemicals List (ECL) NEW ZEALAND All substances in this product comply with the Hazardous Substances and New Organisms (HSNO) Act 1996,and are listed on or are exempt from the New Zealand Inventory of Chemicals. PHILIPPINES All substances in this product comply with the Republic Act 6969 (RA 6969) and are listed on the Philippines Inventory of Chemicals & Chemical Substances (PICCS). Section: 16. OTHER INFORMATION 10 / 11 Appendix 3 Page 26 of 58 SAFETY DATA SHEET NALCO 71D5 PLUS NFPA: Flammability 2 2 0 Healt h Special hazard. Instability HMIS III: HEALTH 2 FLAMMABILITY 2 PHYSICAL HAZARD 0 0 = not significant, 1 =Slight, 2 = Moderate, 3 = High 4 = Extreme, * = Chronic Revision Date Version Number Prepared By : 05/04/2015 : 1.2 : Regulatory Affairs REVISED INFORMATION: Significant changes to regulatory or health information for this revision is indicated by a bar in the left-hand margin of the SDS. The information provided in this Safety Data Sheet is correct to the best of our knowledge, information and belief at the date of its publication. The information given is designed only as a guidance for safe handling, use, processing, storage, transportation, disposal and release and is not to be considered a warranty or quality specification. The information relates only to the specific material designated and may not be valid for such material used in combination with any other materials or in any process, unless specified in the text. For additional copies of an MSDS visit www.nalco.com and request access. 11 / 11 Appendix 3 Page 27 of 58 SAFETY DATA SHEET PERMACLEAN PC-56 Section: 1. PRODUCT AND COMPANY IDENTIFICATION Product name : PERMACLEAN PC-56 Other means of identification : Not applicable. Restrictions on use : Refer to available product literature or ask your local Sales Representative for restrictions on use and dose limits. Company : Nalco Company 1601 W. Diehl Road Naperville, Illinois 60563-1198 USA TEL: (630)305-1000 Emergency telephone number : (800) 424-9300 (24 Hours) CHEMTREC Issuing date : 11/21/2014 Section: 2. HAZARDS IDENTIFICATION GHS Classification Acute toxicity (Inhalation) Skin corrosion Serious eye damage/eye irritation Skin sensitization : Category 4 : Category 1A : Category 1 : Category 1 GHS Label element Hazard pictograms : Signal Word Hazard Statements Precautionary Statements : Danger : Causes severe skin burns and eye damage. May cause an allergic skin reaction. Harmful if inhaled. : Prevention: Avoid breathing dust/ fume/ gas/ mist/ vapours/ spray. Wash skin thoroughly after handling. Use only outdoors or in a well-ventilated area. Contaminated work clothing should not be allowed out of the workplace. Wear protective gloves/ protective clothing/ eye protection/ face protection. Response: IF SWALLOWED: rinse mouth. Do NOT induce vomiting. IF ON SKIN (or hair): Remove/ Take off immediately all contaminated clothing. Rinse skin with water/ shower. IF INHALED: Remove victim to fresh air and keep at rest in a position comfortable for breathing. IF IN EYES: Rinse cautiously with water for several minutes. Remove contact lenses, if present and easy to do. 1 / 11 Appendix 3 Page 28 of 58 SAFETY DATA SHEET PERMACLEAN PC-56 Other hazards Continue rinsing. Immediately call a POISON CENTER or doctor/ physician. If skin irritation or rash occurs: Get medical advice/ attention. Wash contaminated clothing before reuse. Storage: Store locked up. Disposal: Dispose of contents/ container to an approved waste disposal plant. : None known. Section: 3. COMPOSITION/INFORMATION ON INGREDIENTS Pure substance/mixture : Mixture Chemical Name Magnesium Nitrate 5-Chloro-2-Methyl-4-Isothiazolin-3-one 2-Methyl-4-Isothiazolin-3-one CAS-No. 10377-60-3 26172-55-4 2682-20-4 Concentration: (%) 1 - 5 1 - 5 0.1 - 1 Section: 4. FIRST AID MEASURES In case of eye contact In case of skin contact If swallowed If inhaled Protection of first-aiders Notes to physician Most important symptoms and effects, both acute and delayed : Rinse immediately with plenty of water, also under the eyelids, for at least 15 minutes. Remove contact lenses, if present and easy to do. Continue rinsing. Get medical attention immediately. : Wash off immediately with plenty of water for at least 15 minutes. Use a mild soap if available. Wash clothing before reuse. Thoroughly clean shoes before reuse. Get medical attention immediately. : Rinse mouth with water. Do NOT induce vomiting. Never give anything by mouth to an unconscious person. Get medical attention immediately. : Remove to fresh air. Treat symptomatically. Get medical attention. : In event of emergency assess the danger before taking action. Do not put yourself at risk of injury. If in doubt, contact emergency responders.Use personal protective equipment as required. : Treat symptomatically. : See Section 11 for more detailed information on health effects and symptoms. Section: 5. FIREFIGHTING MEASURES Suitable extinguishing media : Use extinguishing measures that are appropriate to local circumstances and the surrounding environment. Unsuitable extinguishing media : None known. Specific hazards during firefighting : Not flammable or combustible. 2 / 11 Appendix 3 Page 29 of 58 SAFETY DATA SHEET PERMACLEAN PC-56 Hazardous combustion products : Carbon oxides Special protective equipment : Use personal protective equipment. for firefighters Specific extinguishing methods : Fire residues and contaminated fire extinguishing water must be disposed of in accordance with local regulations. In the event of fire and/or explosion do not breathe fumes. Section: 6. ACCIDENTAL RELEASE MEASURES Personal precautions, protective equipment and emergency procedures : Ensure adequate ventilation. Keep people away from and upwind of spill/leak. Avoid inhalation, ingestion and contact with skin and eyes. When workers are facing concentrations above the exposure limit they must use appropriate certified respirators. Ensure clean-up is conducted by trained personnel only. Refer to protective measures listed in sections 7 and 8. Environmental precautions : Do not allow contact with soil, surface or ground water. Methods and materials for containment and cleaning up : Stop leak if safe to do so. Contain spillage, and then collect with non-combustible absorbent material, (e.g. sand, earth, diatomaceous earth, vermiculite) and place in container for disposal according to local / national regulations (see section 13). Flush away traces with water. For large spills, dike spilled material or otherwise contain material to ensure runoff does not reach a waterway. DEACTIVATION SOLUTION - prepare a fresh solution of 5% sodium bicarbonate and 5% sodium hypochlorite in water (i.e. add 50 grams of sodium bicarbonate per 1 liter of household bleach, seal container then shake well for 1 minute) away from the immediate area of spill. Prepare 10 times the estimated volume of the residual spill. The materials and equipment for preparing solutions should be kept available for use in areas where spills may occur. Section: 7. HANDLING AND STORAGE Advice on safe handling : Do not ingest. Do not breathe dust/fume/gas/mist/vapours/spray. Do not get in eyes, on skin, or on clothing. Wash hands thoroughly after handling. Use only with adequate ventilation. Conditions for safe storage : Keep out of reach of children. Keep container tightly closed. Store in suitable labeled containers. Suitable material : HDPE (high density polyethylene), PTFE, Polyvinylidene difluoride, Polypropylene, Plexiglass, Perfluoroelastomer, CPVC (rigid), BunaN Keep in properly labelled containers. Unsuitable material : The following compatibility data is suggested based on similar product data and/or industry experience: Shipping and long term storage compatibility with construction materials can vary; we therefore recommend that compatibility is tested prior to use. Section: 8. EXPOSURE CONTROLS/PERSONAL PROTECTION 3 / 11 Appendix 3 Page 30 of 58 SAFETY DATA SHEET PERMACLEAN PC-56 Components with workplace control parameters Contains no substances with occupational exposure limit values. Engineering measures : Effective exhaust ventilation system Maintain air concentrations below occupational exposure standards. Personal protective equipment Eye protection : Safety goggles Face-shield Hand protection : Wear the following personal protective equipment: Standard glove type. Gloves should be discarded and replaced if there is any indication of degradation or chemical breakthrough. Skin protection : Personal protective equipment comprising: suitable protective gloves, safety goggles and protective clothing Respiratory protection : When workers are facing concentrations above the exposure limit they must use appropriate certified respirators. Hygiene measures : Handle in accordance with good industrial hygiene and safety practice. Remove and wash contaminated clothing before re-use. Wash face, hands and any exposed skin thoroughly after handling. Provide suitable facilities for quick drenching or flushing of the eyes and body in case of contact or splash hazard. Section: 9. PHYSICAL AND CHEMICAL PROPERTIES Appearance Colour : Liquid : colourless Odour Flash point pH Odour Threshold Melting point/freezing point Initial boiling point and boiling range Evaporation rate Flammability (solid, gas) Upper explosion limit Lower explosion limit Vapour pressure Relative vapour density Relative density Density : Mild : Not applicable. : 2.0 - 5.0, 100 % (25 C) : no data available : FREEZING POINT: -4 C, ASTM D-1177 : 100 C Method: ASTM D 86 : no data available : no data available : no data available : no data available : similar to water : no data available : 1.026 (25 C) : 8.5 lb/gal 4 / 11 Appendix 3 Page 31 of 58 SAFETY DATA SHEET PERMACLEAN PC-56 Water solubility Solubility in other solvents Partition coefficient: noctanol/water Auto-ignition temperature Thermal decomposition temperature Viscosity, dynamic Viscosity, kinematic : completely soluble : no data available : no data available : no data available : no data available : no data available : 3 mm2/s (20 C) VOC : 0.80 % 8.39 g/l Section: 10. STABILITY AND REACTIVITY Chemical stability : Stable under normal conditions. Possibility of hazardous reactions Conditions to avoid : No dangerous reaction known under conditions of normal use. : None known. Incompatible materials : Contact with strong oxidizers (e.g. chlorine, peroxides, chromates, nitric acid, perchlorate, concentrated oxygen, permanganate) may generate heat, fires, explosions and/or toxic vapors. Hazardous decomposition products : Oxides of carbon Oxides of nitrogen Oxides of sulfur HCl Section: 11. TOXICOLOGICAL INFORMATION Information on likely routes of : Inhalation, Eye contact, Skin contact exposure Potential Health Effects Eyes : Causes serious eye damage. Skin : Causes severe skin burns. May cause allergic skin reaction. Ingestion : Causes digestive tract burns. Inhalation : Harmful if inhaled. May cause nose, throat, and lung irritation. Chronic Exposure : Health injuries are not known or expected under normal use. Experience with human exposure Eye contact : Redness, Pain, Corrosion Skin contact : Redness, Pain, Irritation, Corrosion, Allergic reactions Ingestion : Corrosion, Abdominal pain 5 / 11 Appendix 3 Page 32 of 58 SAFETY DATA SHEET PERMACLEAN PC-56 Inhalation Toxicity Product Acute oral toxicity : Respiratory irritation, Cough : Acute toxicity estimate : > 5,000 mg/kg Acute inhalation toxicity : LC50 rat: 13.7 mg/l Exposure time: 4 hrs Test substance: Product Acute dermal toxicity : no data available Skin corrosion/irritation Serious eye damage/eye irritation Respiratory or skin sensitization Carcinogenicity Reproductive effects Germ cell mutagenicity Teratogenicity STOT - single exposure STOT - repeated exposure Aspiration toxicity Components Acute dermal toxicity : no data available : no data available : no data available : no data available : no data available : no data available : no data available : no data available : no data available : no data available : Magnesium Nitrate LD50 rat: > 5,000 mg/kg 5-Chloro-2-Methyl-4-Isothiazolin-3-one LD50 rabbit: 200 mg/kg 2-Methyl-4-Isothiazolin-3-one LD50 rabbit: 200 mg/kg Section: 12. ECOLOGICAL INFORMATION Ecotoxicity Environmental Effects Product Toxicity to fish : Very toxic to aquatic life. : LC50 Cyprinodon variegatus (sheepshead minnow): 32.000 6 / 11 Appendix 3 Page 33 of 58 SAFETY DATA SHEET PERMACLEAN PC-56 mg/l Exposure time: 96 hrs Test substance: Product LC50 Pimephales promelas (fathead minnow): 8 mg/l Exposure time: 144 hrs Test substance: Product (estimated) LC50 Lepomis macrochirus (Bluegill sunfish): 18.67 mg/l Exposure time: 96 hrs Test substance: Product LC50 Rainbow Trout: 12.67 mg/l Exposure time: 96 hrs Test substance: Product LC50 Inland Silverside: 16.62 mg/l Exposure time: 96 hrs Test substance: Product LC50 Cyprinodon variegatus (sheepshead minnow): 0.3 mg/l Exposure time: 96 hrs Test substance: Active Substance Product Toxicity to daphnia and other aquatic invertebrates : LC50 Mysid Shrimp (Mysidopsis bahia): 18.000 mg/l Exposure time: 96 hrs Test substance: Product LC50 Ceriodaphnia dubia: 13 mg/l Exposure time: 48 hrs Test substance: Product LC50 Daphnia magna (Water flea): 8.7 - 12 mg/l Exposure time: 48 hrs Test substance: Product (estimated) LC50 Blue Mussel: 865 mg/l Exposure time: 48 hrs Test substance: Product (estimated) LC50 American Oyster: 1,730 mg/l Exposure time: 48 hrs Test substance: Product (estimated) 7 / 11 Appendix 3 Page 34 of 58 SAFETY DATA SHEET PERMACLEAN PC-56 Product Toxicity to algae : EC50 Marine Algae (Skeletonema costatum): 0.003 mg/l Exposure time: 72 h Test substance: Active Substance Product Toxicity to terrestrial organisms EC50 Green Algae (Pseudokirchneriella subcapitata, previously Selenastrum capricornutum): 0.018 mg/l Exposure time: 72 h Test substance: Active Substance : LC50 Pekin Duck: > 100 mg/kg Exposure time: 8 Days Test substance: Active Substance LC50 Bobwhite Quail: 85 mg/kg Exposure time: 21 Days Test substance: Active Substance LC50 Bobwhite Quail: > 60 mg/kg Exposure time: 8 Days Test substance: Active Substance Persistence and degradability The degradation of the major active substance begins with ring opening and elimination of chloride ion. Degradation leads to the formation of a variety of small organic acids, methylamine, carbon dioxide and elemental sulfur. The half life of each active substance is dependent upon the initial concentration. Total Organic Carbon (TOC) : 7,850 mg/l Chemical Oxygen Demand (COD): 20,000 mg/l Biochemical Oxygen Demand (BOD): Incubation Period Value 20 mg/l Test Descriptor Mobility The environmental fate was estimated using a level III fugacity model embedded in the EPI (estimation program interface) Suite TM, provided by the US EPA. The model assumes a steady state condition between the total input and output. The level III model does not require equilibrium between the defined media. The information provided is intended to give the user a general estimate of the environmental fate of this product under the defined conditions of the models. If released into the environment this material is expected to distribute to the air, water and soil/sediment in the approximate respective percentages; Air Water Soil : <5% : 30 - 50% : 50 - 70% The portion in water is expected to be soluble or dispersible. Bioaccumulative potential 8 / 11 Appendix 3 Page 35 of 58 SAFETY DATA SHEET PERMACLEAN PC-56 This preparation or material is not expected to bioaccumulate. Other information no data available Section: 13. DISPOSAL CONSIDERATIONS If this product becomes a waste, it could meet the criteria of a hazardous waste as defined by the Resource Conservation and Recovery Act (RCRA) 40 CFR 261. Before disposal, it should be determined if the waste meets the criteria of a hazardous waste. Disposal methods : The product should not be allowed to enter drains, water courses or the soil. Where possible recycling is preferred to disposal or incineration. If recycling is not practicable, dispose of in compliance with local regulations. Dispose of wastes in an approved waste disposal facility. Disposal considerations : Dispose of as unused product. Empty containers should be taken to an approved waste handling site for recycling or disposal. Do not re-use empty containers. Section: 14. TRANSPORT INFORMATION The shipper/consignor/sender is responsible to ensure that the packaging, labeling, and markings are in compliance with the selected mode of transport. Land transport (DOT) The presence of an RQ component (Reportable Quantity for U.S. EPA and DOT) in this product causes it to be regulated with an additional description of RQ for road, or as a class 9 for road and air, ONLY when the net weight in the package exceeds the calculated RQ for the product. Proper shipping name Technical name(s) UN/ID No. Transport hazard class(es) Packing group Reportable Quantity (per package) RQ Component : CORROSIVE LIQUID, ACIDIC, ORGANIC, N.O.S. : ISOTHIAZOLINONE MICROBIOCIDE : UN 3265 : 8 : II : 132,270 lbs : CUPRIC NITRATE Air transport (IATA) The presence of an RQ component (Reportable Quantity for U.S. EPA and DOT) in this product causes it to be regulated with an additional description of RQ for road, or as a class 9 for road and air, ONLY when the net weight in the package exceeds the calculated RQ for the product. Proper shipping name Technical name(s) UN/ID No. Transport hazard class(es) Packing group Reportable Quantity (per package) RQ Component : CORROSIVE LIQUID, ACIDIC, ORGANIC, N.O.S. : ISOTHIAZOLINONE MICROBIOCIDE : UN 3265 : 8 : II : 132,270 lbs : CUPRIC NITRATE Sea transport (IMDG/IMO) 9 / 11 Appendix 3 Page 36 of 58 SAFETY DATA SHEET PERMACLEAN PC-56 Proper shipping name Technical name(s) UN/ID No. Transport hazard class(es) Packing group : CORROSIVE LIQUID, ACIDIC, ORGANIC, N.O.S. : ISOTHIAZOLINONE MICROBIOCIDE : UN 3265 : 8 : II *Marine pollutant : ISOTHIAZOLINONE MICROBIOCIDE *Note: This product is regulated as a Marine Pollutant when shipped by Rail, Highway (in bulk quantities), or Air (if no other hazard class applies), and when shipped by water in all quantities. Section: 15. REGULATORY INFORMATION EPA Reg. No. : 1706-183 EPCRA - Emergency Planning and Community Right-to-Know Act CERCLA Reportable Quantity Components CAS-No. Cupric Nitrate 3251-23-8 Component RQ (lbs) 100 Calculated product RQ (lbs) 132275 SARA 304 Extremely Hazardous Substances Reportable Quantity This material does not contain any components with a section 304 EHS RQ. SARA 311/312 Hazards : Acute Health Hazard SARA 302 SARA 313 : No chemicals in this material are subject to the reporting requirements of SARA Title III, Section 302. : This material does not contain any chemical components with known CAS numbers that exceed the threshold (De Minimis) reporting levels established by SARA Title III, Section 313. California Prop 65 This product does not contain any chemicals known to State of California to cause cancer, birth defects, or any other reproductive harm. INTERNATIONAL CHEMICAL CONTROL LAWS : TOXIC SUBSTANCES CONTROL ACT (TSCA) This product is exempted under TSCA and regulated under FIFRA. The inerts are on the Inventory List. CANADIAN ENVIRONMENTAL PROTECTION ACT (CEPA) Substances regulated under the Pest Control Products Act are exempt from CEPA New Substance Notification requirements. AUSTRALIA All substances in this product comply with the National Industrial Chemicals Notification & Assessment Scheme (NICNAS). CHINA All substances in this product comply with the Provisions on the Environmental Administration of New Chemical Substances and are listed on or exempt from the Inventory of Existing Chemical Substances China (IECSC). 10 / 11 Appendix 3 Page 37 of 58 SAFETY DATA SHEET PERMACLEAN PC-56 EUROPE The substances in this preparation have been reviewed for compliance with the EINECS or ELINCS inventories. JAPAN All substances in this product comply with the Law Regulating the Manufacture and Importation Of Chemical Substances and are listed on the Existing and New Chemical Substances list (ENCS). KOREA All substances in this product comply with the Toxic Chemical Control Law (TCCL) and are listed on the Existing Chemicals List (ECL) NEW ZEALAND All substances in this product comply with the Hazardous Substances and New Organisms (HSNO) Act 1996,and are listed on or are exempt from the New Zealand Inventory of Chemicals. PHILIPPINES All substances in this product comply with the Republic Act 6969 (RA 6969) and are listed on the Philippines Inventory of Chemicals & Chemical Substances (PICCS). Section: 16. OTHER INFORMATION Healt h NFPA: Flammability 0 3 0 Instability HMIS III: HEALTH 3 FLAMMABILITY 0 PHYSICAL HAZARD 0 Special hazard. 0 = not significant, 1 =Slight, 2 = Moderate, 3 = High 4 = Extreme, * = Chronic Revision Date Version Number Prepared By : 11/21/2014 : 1.1 : Regulatory Affairs REVISED INFORMATION: Significant changes to regulatory or health information for this revision is indicated by a bar in the left-hand margin of the SDS. The information provided in this Safety Data Sheet is correct to the best of our knowledge, information and belief at the date of its publication. The information given is designed only as a guidance for safe handling, use, processing, storage, transportation, disposal and release and is not to be considered a warranty or quality specification. The information relates only to the specific material designated and may not be valid for such material used in combination with any other materials or in any process, unless specified in the text. For additional copies of an MSDS visit www.nalco.com and request access. 11 / 11 Appendix 3 Page 38 of 58 SAFETY DATA SHEET PERMATREATTM PC-191T Section: 1. PRODUCT AND COMPANY IDENTIFICATION Product name : PERMATREATTM PC-191T Other means of identification : Not applicable. Recommended use : REVERSE OSMOSIS ANTISCALANT Restrictions on use : Refer to available product literature or ask your local Sales Representative for restrictions on use and dose limits. Company : Nalco Company 1601 W. Diehl Road Naperville, Illinois 60563-1198 USA TEL: (630)305-1000 Emergency telephone number : (800) 424-9300 (24 Hours) CHEMTREC Issuing date : 11/03/2015 Section: 2. HAZARDS IDENTIFICATION GHS Classification Not a hazardous substance or mixture. GHS Label element Precautionary Statements : Prevention: Wash hands thoroughly after handling. Response: Specific measures: consult SDS Section 4. Storage: Store in accordance with local regulations. Other hazards : None known. Section: 3. COMPOSITION/INFORMATION ON INGREDIENTS No hazardous ingredients Section: 4. FIRST AID MEASURES In case of eye contact : Rinse with plenty of water. Get medical attention if symptoms occur. In case of skin contact : Wash off with soap and plenty of water. Get medical attention if symptoms occur. If swallowed : Rinse mouth. Get medical attention if symptoms occur. If inhaled : Get medical attention if symptoms occur. Protection of first-aiders : In event of emergency assess the danger before taking action. Do not put 1 / 10 Appendix 3 Page 39 of 58 SAFETY DATA SHEET PERMATREATTM PC-191T yourself at risk of injury. If in doubt, contact emergency responders. Use personal protective equipment as required. Notes to physician : Treat symptomatically. Most important symptoms and effects, both acute and delayed : See Section 11 for more detailed information on health effects and symptoms. Section: 5. FIREFIGHTING MEASURES Suitable extinguishing media : Use extinguishing measures that are appropriate to local circumstances and the surrounding environment. Unsuitable extinguishing media : None known. Specific hazards during firefighting : Not flammable or combustible. Hazardous combustion products : Decomposition products may include the following materials: Carbon oxides nitrogen oxides (NOx) Sulphur oxides Oxides of phosphorus Special protective equipment : Use personal protective equipment. for firefighters Specific extinguishing methods : Fire residues and contaminated fire extinguishing water must be disposed of in accordance with local regulations. Section: 6. ACCIDENTAL RELEASE MEASURES Personal precautions, protective equipment and emergency procedures : Refer to protective measures listed in sections 7 and 8. Environmental precautions : No special environmental precautions required. Methods and materials for : Stop leak if safe to do so. Contain spillage, and then collect with noncontainment and cleaning up combustible absorbent material, (e.g. sand, earth, diatomaceous earth, vermiculite) and place in container for disposal according to local / national regulations (see section 13). For large spills, dike spilled material or otherwise contain material to ensure runoff does not reach a waterway. Flush away traces with water. Section: 7. HANDLING AND STORAGE Advice on safe handling : For personal protection see section 8. Wash hands after handling. Conditions for safe storage : Keep out of reach of children. Keep container tightly closed. Store in suitable labeled containers. 2 / 10 Appendix 3 Page 40 of 58 SAFETY DATA SHEET PERMATREATTM PC-191T Suitable material : The following compatibility data is suggested based on similar product data and/or industry experience: HDPE (high density polyethylene), Stainless Steel 304, Polyethylene (rigid), Polypropylene (rigid), CPVC (rigid), 100% phenolic resin liner, Epoxy phenolic resin, coated steel Unsuitable material : The following compatibility data is suggested based on similar product data and/or industry experience: Brass, Buna-N, EPDM, Neoprene, Polyurethane, Fluoroelastomer, Chlorosulfonated polyethylene rubber, Shipping and long term storage compatibility with construction materials can vary; we therefore recommend that compatibility is tested prior to use. Section: 8. EXPOSURE CONTROLS/PERSONAL PROTECTION Components with workplace control parameters Contains no substances with occupational exposure limit values. Engineering measures : Good general ventilation should be sufficient to control worker exposure to airborne contaminants. Personal protective equipment Eye protection : Safety glasses Hand protection : Wear protective gloves. Gloves should be discarded and replaced if there is any indication of degradation or chemical breakthrough. Skin protection : Wear suitable protective clothing. Respiratory protection : No personal respiratory protective equipment normally required. Hygiene measures : Wash hands before breaks and immediately after handling the product. Section: 9. PHYSICAL AND CHEMICAL PROPERTIES Appearance Colour Odour Flash point : Liquid : Clear, yellow to amber greenish : Ammoniacal : > 93.3 C pH Odour Threshold Melting point/freezing point Initial boiling point and boiling range Evaporation rate : 10.0 - 11.5, 1 % (25 C) : no data available : no data available : no data available : no data available 3 / 10 Appendix 3 Page 41 of 58 SAFETY DATA SHEET PERMATREATTM PC-191T Flammability (solid, gas) Upper explosion limit Lower explosion limit Vapour pressure Relative vapour density Relative density Density Water solubility Solubility in other solvents Partition coefficient: noctanol/water Auto-ignition temperature Thermal decomposition temperature Viscosity, dynamic Viscosity, kinematic Molecular weight VOC : no data available : no data available : no data available : no data available : no data available : 1.335 - 1.362 (15.6 C) : 1.127 g/cm3 11.3 lb/gal : completely soluble : no data available : Pow: 3.5 log Pow: 0.544 : no data available : no data available : no data available : no data available : no data available : 0 % Calculation method Section: 10. STABILITY AND REACTIVITY Chemical stability : Stable under normal conditions. Possibility of hazardous reactions : No dangerous reaction known under conditions of normal use. Conditions to avoid : Freezing temperatures. Incompatible materials : Strong oxidizing agents Strong acids Hazardous decomposition products : Decomposition products may include the following materials: Carbon oxides nitrogen oxides (NOx) Sulphur oxides Oxides of phosphorus Section: 11. TOXICOLOGICAL INFORMATION Information on likely routes of : Inhalation, Eye contact, Skin contact exposure Potential Health Effects Eyes : Health injuries are not known or expected under normal use. 4 / 10 Appendix 3 Page 42 of 58 SAFETY DATA SHEET PERMATREATTM PC-191T Skin : Health injuries are not known or expected under normal use. Ingestion : Health injuries are not known or expected under normal use. Inhalation : Health injuries are not known or expected under normal use. Chronic Exposure : Health injuries are not known or expected under normal use. Experience with human exposure Eye contact : No symptoms known or expected. Skin contact : No symptoms known or expected. Ingestion : No symptoms known or expected. Inhalation : No symptoms known or expected. Toxicity Product Acute oral toxicity : LD50 rat: > 17,800 mg/kg Test substance: Similar Product Acute inhalation toxicity : no data available Acute dermal toxicity : LD50 rabbit: > 15,800 mg/kg Test substance: Similar Product Skin corrosion/irritation : Species: Rabbit Exposure time: 24 hrs Result: 0.3 Method: Draize Test Test substance:Similar Product Serious eye damage/eye irritation : Species: rabbit Exposure time: 24 hrs Result: 3.7 Method: Draize Test Test substance: Similar Product Respiratory or skin sensitization Carcinogenicity Reproductive effects Germ cell mutagenicity Teratogenicity : no data available : no data available : no data available : no data available : no data available 5 / 10 Appendix 3 Page 43 of 58 SAFETY DATA SHEET PERMATREATTM PC-191T STOT - single exposure STOT - repeated exposure Aspiration toxicity : no data available : no data available : no data available Section: 12. ECOLOGICAL INFORMATION Ecotoxicity Environmental Effects : This product has no known ecotoxicological effects. Product Toxicity to fish : LC50 Oncorhynchus mykiss (rainbow trout): > 330 mg/l Exposure time: 96 hrs Test substance: Similar Product LC50 Cyprinodon variegatus (sheepshead minnow): 8,132 mg/l Exposure time: 96 hrs Test substance: Similar Product LC50 Lepomis macrochirus (Bluegill sunfish): > 330 mg/l Exposure time: 96 hrs Test substance: Similar Product LC50 Ictalurus punctatus (channel catfish): 1,212 mg/l Exposure time: 96 hrs Test substance: Similar Product LC50 Oncorhynchus mykiss (rainbow trout): 4,530 mg/l Exposure time: 96 hrs Test substance: Product Test Type: Static NOEC Oncorhynchus mykiss (rainbow trout): 3,600 mg/l Exposure time: 96 hrs Test substance: Product Test Type: Static LC50 Inland Silverside: > 10,000 mg/l Exposure time: 96 h Test substance: Product NOEC Inland Silverside: 10,000 mg/l Exposure time: 96 h Test substance: Product Toxicity to daphnia and other aquatic invertebrates : LC50 Grass Shrimp: 4,575 mg/l Exposure time: 96 hrs Test substance: Similar Product LC50 Daphnia magna (Water flea): 1,673 mg/l 6 / 10 Appendix 3 Page 44 of 58 SAFETY DATA SHEET PERMATREATTM PC-191T Exposure time: 48 hrs Test substance: Product Test Type: Static EC50 Daphnia magna (Water flea): 297 mg/l Exposure time: 48 hrs Test substance: Similar Product NOEC Daphnia magna (Water flea): 1,296 mg/l Exposure time: 48 hrs Test substance: Product Test Type: Static LC50 Mysid Shrimp (Mysidopsis bahia): 8,263 mg/l Exposure time: 96 h Test substance: Product NOEC Mysid Shrimp (Mysidopsis bahia): 6,000 mg/l Exposure time: 96 h Test substance: Product Toxicity to algae : LC50 Green Algae (Pseudokirchneriella subcapitata, previously Selenastrum capricornutum): 20 mg/l Exposure time: 96 hrs Test substance: Similar Product Toxicity to fish (Chronic toxicity) : LOEC: 47.6 mg/l Exposure time: 60 Days Species: Oncorhynchus mykiss (rainbow trout) Test substance: Similar Product NOEC: 23 mg/l Exposure time: 60 Days Species: Oncorhynchus mykiss (rainbow trout) Test substance: Similar Product Toxicity to daphnia and other aquatic invertebrates (Chronic toxicity) : LOEC: 50 mg/l Exposure time: 28 Days Species: Daphnia magna Test substance: Similar Product Test Type: 3 Brood NOEC: 25 mg/l Exposure time: 28 Days Species: Daphnia magna Test substance: Similar Product Test Type: 3 Brood Toxicity to terrestrial organisms : LC50 Bobwhite Quail: > 2,510 mg/kg Exposure time: 14 Days Test substance: Similar Product LC50 Mallard Duck: > 2,510 mg/kg Exposure time: 14 Days Test substance: Similar Product 7 / 10 Appendix 3 Page 45 of 58 SAFETY DATA SHEET PERMATREATTM PC-191T Persistence and degradability Total Organic Carbon (TOC) : 65,000 mg/l Mobility The environmental fate was estimated using a level III fugacity model embedded in the EPI (estimation program interface) Suite TM, provided by the US EPA. The model assumes a steady state condition between the total input and output. The level III model does not require equilibrium between the defined media. The information provided is intended to give the user a general estimate of the environmental fate of this product under the defined conditions of the models. If released into the environment this material is expected to distribute to the air, water and soil/sediment in the approximate respective percentages; Air Water Soil : <5% : 30 - 50% : 50 - 70% The portion in water is expected to be soluble or dispersible. Bioaccumulative potential This preparation or material is not expected to bioaccumulate. Other information no data available Section: 13. DISPOSAL CONSIDERATIONS If this product becomes a waste, it is not a hazardous waste as defined by the Resource Conservation and Recovery Act (RCRA) 40 CFR 261, since it does not have the characteristics of Subpart C, nor is it listed under Subpart D. Disposal methods : Where possible recycling is preferred to disposal or incineration. If recycling is not practicable, dispose of in compliance with local regulations. Dispose of wastes in an approved waste disposal facility. Disposal considerations : Dispose of as unused product. Empty containers should be taken to an approved waste handling site for recycling or disposal. Do not re-use empty containers. Section: 14. TRANSPORT INFORMATION The shipper/consignor/sender is responsible to ensure that the packaging, labeling, and markings are in compliance with the selected mode of transport. Land transport (DOT) Proper shipping name Air transport (IATA) : PRODUCT IS NOT REGULATED DURING TRANSPORTATION 8 / 10 Appendix 3 Page 46 of 58 SAFETY DATA SHEET PERMATREATTM PC-191T Proper shipping name : PRODUCT IS NOT REGULATED DURING TRANSPORTATION Sea transport (IMDG/IMO) Proper shipping name : PRODUCT IS NOT REGULATED DURING TRANSPORTATION Section: 15. REGULATORY INFORMATION EPCRA - Emergency Planning and Community Right-to-Know Act CERCLA Reportable Quantity This material does not contain any components with a CERCLA RQ. SARA 304 Extremely Hazardous Substances Reportable Quantity This material does not contain any components with a section 304 EHS RQ. SARA 311/312 Hazards : No SARA Hazards SARA 302 SARA 313 : No chemicals in this material are subject to the reporting requirements of SARA Title III, Section 302. : This material does not contain any chemical components with known CAS numbers that exceed the threshold (De Minimis) reporting levels established by SARA Title III, Section 313. California Prop 65 This product does not contain any chemicals known to State of California to cause cancer, birth defects, or any other reproductive harm. INTERNATIONAL CHEMICAL CONTROL LAWS : TOXIC SUBSTANCES CONTROL ACT (TSCA) The substances in this preparation are included on or exempted from the TSCA 8(b) Inventory (40 CFR 710) CANADIAN ENVIRONMENTAL PROTECTION ACT (CEPA) The substance(s) in this preparation are included in or exempted from the Domestic Substance List (DSL). AUSTRALIA All substances in this product comply with the National Industrial Chemicals Notification & Assessment Scheme (NICNAS). CHINA All substances in this product comply with the Provisions on the Environmental Administration of New Chemical Substances and are listed on or exempt from the Inventory of Existing Chemical Substances China (IECSC). JAPAN All substances in this product comply with the Law Regulating the Manufacture and Importation Of Chemical Substances and are listed on the Existing and New Chemical Substances list (ENCS). 9 / 10 Appendix 3 Page 47 of 58 SAFETY DATA SHEET PERMATREATTM PC-191T KOREA All substances in this product comply with the Toxic Chemical Control Law (TCCL) and are listed on the Existing Chemicals List (ECL) NEW ZEALAND All substances in this product comply with the Hazardous Substances and New Organisms (HSNO) Act 1996,and are listed on or are exempt from the New Zealand Inventory of Chemicals. PHILIPPINES All substances in this product comply with the Republic Act 6969 (RA 6969) and are listed on the Philippines Inventory of Chemicals & Chemical Substances (PICCS). Section: 16. OTHER INFORMATION Healt h NFPA: Flammability 1 0 0 Instability HMIS III: HEALTH 0 FLAMMABILITY 1 PHYSICAL HAZARD 0 Special hazard. 0 = not significant, 1 =Slight, 2 = Moderate, 3 = High 4 = Extreme, * = Chronic Revision Date Version Number Prepared By : 11/03/2015 : 1.1 : Regulatory Affairs REVISED INFORMATION: Significant changes to regulatory or health information for this revision is indicated by a bar in the left-hand margin of the SDS. The information provided in this Safety Data Sheet is correct to the best of our knowledge, information and belief at the date of its publication. The information given is designed only as a guidance for safe handling, use, processing, storage, transportation, disposal and release and is not to be considered a warranty or quality specification. The information relates only to the specific material designated and may not be valid for such material used in combination with any other materials or in any process, unless specified in the text. For additional copies of an SDS visit www.nalco.com and request access. 10 / 10 Appendix 3 Page 48 of 58 Safety Data Sheet According to OSHA HCS 2012 (29 CFR 1910.1200) !SECTION 1: Identification Product Identifier Other means of identification SOS Number MARP0L Annex I Category Relevant identified uses Uses advised against 24 Hour Emergency Phone Number Unbranded Conventional Gasoline Gasoline, Unleaded, Conventional (All Grades) Gasoline, Low Sulfur Unleaded (All Grades) Gasoline Treated as Blendstock (GTAB) 724020 Gasoline and Spirits Fuel All others CHEMTREC 1-800-424-9300 CANUTEC 613-996-6666 CHEMTREC Mexico 01-800-681-9531 Manufacturer/Supplier Phillips 66 Company P.O. Box 4428 Houston, Texas 77210 SOS Information Phone: 800-762-0942 Email: SDS@P66.com URL: www.Phillips66.com lsECTION 2: Hazard identification Classified Hazards Hazards Not Otherwise Classified (HNOC) H224 Flammable liquids Category 1 H304 - Aspiration Hazard - Category 1 H315 Skin corrosion/irritation -- Category 2 H336 -- Specific target organ toxicity (single exposure) -- Category 3 H350 -- Carcinogenicity -- Category 18 H411 - Hazardous to the aquatic environment, chronic toxicity -- Category 2 PHNOC: Electrostatic charge may be generated during pumping and other operations HHNOC: None known Label Elements 0 DANGER Extremely flammable liquid and vapor May be fatal if swallowed and enters airways Causes skin irritation May cause drowsiness or dizziness May cause cancer Toxic to aquatic life with long lasting ettects Obtain special instructions before use; Do not handle until all safety precautions have been read and understood; Keep away from heat/sparks/open flames/hot surfaces. - No smoking; Keep container tightly closed; Ground/bond container and receiving equipment; Use only non-sparking tools; Take precautionary measures against static discharge; Avoid breathing dust/fume/gas/mist/vapours/spray; Wash skin thoroughly after handling; Use only outdoors or in a well-ventilated area; Avoid release to the environment; Wear protective gloves/protective clothing and eye/face protection; IF SWALLOWED: Immediately call a POISON CENTER or doctor/physician; Do NOT induce vomiting; IF ON SKIN (or hair): Remove/Take olf immediately all contaminated clothing. Rinse skin with water/shower; IF INHALED: Remove victim to fresh air and keep at rest in a position comfortable for breathing; Call a POISON CENTER or doctor/physician if you feel unwell; Take off contaminated clothing and wash before reuse; In case of fire: Use CO2, dry chemical, or foam for extinction: Collect spillage; Dispose of contents/container to an approved waste disposal plant --------------------------------------------------------------------- 724020 - Unbranded Conventional Gasoline Appendix 3 Page 49 of 58 Page 1/10 Issue Date: 07-Dec-2015 Status: FINAL Appendix 3 Page 50 of 58 Appendix 3 Page 51 of 58 Appendix 3 Page 52 of 58 Appendix 3 Page 53 of 58 Appendix 3 Page 54 of 58 Appendix 3 Page 55 of 58 Appendix 3 Page 56 of 58 Appendix 3 Page 57 of 58 Appendix 3 Page 58 of 58 APPENDIX 4. KIEWIT OFFSHORE SERVICES LTD 03/21/24 RESPONSE From: To: Cc: Subject: Date: Attachments: Hannah.Johnson Vince Damiano Andrew Gates; Johnson, Joyce-R6; Young-Dahl, Erin; Bo.Johnson; RE: [External]Follow-up from EPA Inspection 3/12/2024 Thursday, March 21, 2024 4:25:43 PM image001.png image002.png image003.png Kiewit Offshore Services_Hazardous Waste Timeline.pdf Tim.Storheim; Diana.Villenas CAUTION: Don't open links or attachments unless you recognize the sender and know they are safe. Good afternoon, I have attached a written statement outlining the timeline for the hazardous waste that was offloaded from the vessels last year by our client. Please let me know if you have any further questions regarding this topic. Sincerely, Hannah Johnson Environmental Coordinator Kiewit Offshore Services, LTD. 2440 Kiewit Rd. Ingleside, TX 78362 Mobile: 361.484.6182 Email: Hannah.Johnson@kiewit.com Appendix 4 Page 1 of 2 NFE Hazardous Waste Timeline The company New Fortress Energy, the owner of the vessels that came to KOS under a refabrication contract, were the sole handlers of all hazardous waste that resulted from the vessels preexisting inventory before reaching our facility. This agreement had been made between Kiewit and NFE via contract before the job was awarded due to the allowable quantity of hazardous waste that KOS may dispose of versus the amount of waste that was needing to be disposed of. Waste began being offloaded from the vessels late January 2023 and NFE contracted out GHD Consulting to assess and help properly mange the waste for disposal. Safety-Kleen was then hired by NFE to begin removing the materials in April 2023, and the first load of waste was removed April 24th, 2023. Over the next month, several pickups were made to remove all the hazardous material which concluded with the final shipment on July 28th, 2023. KOS assisted NFE with containment for the waste, advised on proper labeling, and helped manage spacing and overall housekeeping of the area where their waste was stored. This was the extent to which KOS had in the waste management and handling of New Fortress Energy's hazardous waste. 1 Appendix 4 Page 2 of 2