Document 06e9keG33LeODRzoqqd3X9OxJ

Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 6 Enforcement Division INSPECTION REPORT 05/23/2024 10:30 (CT) Announced: No 05/23/2024 11:30 (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 GV Launch Services None 802 Bishop Rd Ingleside, TX 78362 San Patricio County N/A None GV Launch performs lightering services and launch services at its docks. 27.857015, -97.171622 Additional Persons Participating in Inspection: Name Title Organization Cameron Tanaka Erin Young-Dahl Contractor Inspector Eastern Research Group (ERG) EPA REGION 6 John Penland Inspector EPA REGION 6 Email Cameron.Tanaka@erg.com YoungDahl.Erin@epa.gov Penland.John@epa.gov Phone (508) 314-6432 (214) 665-3166 (214) 665-9717 Lead Inspector: Brook McKeown ERG Brook.McKeown@erg.com 09/03/2024 (410) 459-5811 Page 1 of 4 GV Launch Services SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection Inspection Date: 05/23/2024 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, and other 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 Phone Email Opening Closing Conf. Conf. Brook McKeown (410) 459-5811 Brook.McKeown@erg.com Yes No Cameron Tanaka (508) 314-6432 Cameron.Tanaka@erg.com Yes No Erin Young-Dahl (214) 665-3166 YoungDahl.Erin@epa.gov Yes Yes John Penland (214) 665-9717 Penland.John@epa.gov Yes Yes Facility General Description Tenant/Area GV Launch Services Inspection Date 05/23/24 Process Description GV Launch Services (GV Launch) performs lightering services and launch services at its docks. Lightering services include transferring APHIS regulated garbage, used oil, incinerator ash, and general trash from vessels to their own vessel, then transferring the waste to either vessels or trucks owned by Nature Environmental or ACCP, Inc. GV Launch transports this waste from vessels on the water to their vessel or unload wastes at their dock to take to another location. The company performs maintenance on its own vessel and generates used oil. GV Launch does not maintain a MARPOL COA. Area of Concern Yes Page 2 of 4 GV Launch Services SECTION II - OBSERVATIONS Inspection Date: 05/23/2024 Tenant: GV Launch Services Section: 2.1 Date: 05/23/24, 10:30 AM Contains AOC: Yes Contains CBI: No Lead Inspector: Brook McKeown Attendees: Debbie Parker (Office Manager), Mark Seamone (Owner) GV Launch Services (GV Launch) performs lightering services and launch services at its docks, which the company leases from the Valls Port Terminal Dock. GV Launch has one vessel. Lightering services include transferring APHIS regulated garbage, used oil, oily water, incinerator ash, and general trash from vessels to their own vessel, then transferring the waste to either vessels or trucks owned by Nature Environmental or ACCP, Inc. They transport this waste from vessels on the water to their vessel or unload wastes at their dock to take to another location. GV Launch does not store any waste on its docks, since the waste is immediately transferred to another transporter, which takes the waste to its destination facility. The facility maintains records of used oil transports with USDA manifests, and the used oil it transports is typically delivered to Nature Environmental or ACCP, Inc. Shipping agents, such as Valls Ship Agency, GAC Shipping, Max Shipping, and Gulf Harbor Shipping, contact GV Launch to perform loadouts. GV Launch also loads supplies such as water, groceries, and parts onto other vessels. The company performs maintenance on its own vessel and generates used oil. GV Launch does not maintain a MARPOL COA. The facility does not have an EPA ID. The inspection team reviewed several of the company's exchange tickets, which act as transfer manifests, and noted no issues. The inspection team noted that these tickets documented the amounts and contents of the materials GV Launch was transferring. Some of the tickets showed that incinerator ash was being transferred from GV Launch's vessel to a landing company on the shore or over the water. The inspection team performed a visual inspection of the facility's general yard area, warehouse, and dock area. In the general yard area outside of the warehouse, the inspection team observed seven used oil containers that did not have labels (see Appendix 1 - Photo 1) [AOC #1 - GV Launch did not clearly label containers used to store used oil with the words "Used Oil" - 40 CFR 279.22(c)(1)]. Six of these used oil containers were 225-gallon totes and one was a 350-gallon tote. In her follow-up email from 05/29/24 (see Appendix 2), Ms. Parker included photographs of each of these used oil containers, which had been labeled as "waste oil" since the inspection (see Appendix 3). A closing conference was conducted at approximately 11:30 PM with GV Launch personnel. The AOC was communicated to GV Launch during the closing conference; however, further EPA review may change or add to their potential AOCs. Page 3 of 4 GV Launch Services Inspection Date: 05/23/2024 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: GV Launch Services AOC #1 - GV Launch did not clearly label containers used to store used oil with the words "Used Oil." Citation: 40 CFR 279.22(c)(1) Section: 2.1 SECTION V - 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. Communication Log During and after the inspection, additional information was emailed to EPA including: 1. 05/29/24 GV Launch email - Debbie Parker sent an email containing photographs of each of the used oil containers with labels. SECTION VI - LIST OF APPENDICES Appendix 1. Photograph Log Appendix 2. Follow-Up Email from GV Launch Appendix 3. Follow-Up Photographs from GV Launch Page 4 of 4 APPENDIX 1. PHOTOGRAPH LOG UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: GV Launch Services City: Ingleside Photo No. 1 County/Parish: San Patricio State: Texas Photo File Name: DSCN1123 Date of Photo: 05/23/2024 Time of Photo: 11:27 hrs. Photographer: Cameron Tanaka Description: View of seven used oil containers without labels in the general yard area outside of the warehouse. Six of these used oil containers were 225-gallon totes and one was a 350-gallon tote. APPENDIX 2. FOLLOW-UP EMAIL FROM GV LAUNCH Appendix 2 Page 1 of 2 Appendix 2 Page 2 of 2 APPENDIX 3. FOLLOW-UP PHOTOGRAPHS FROM GV LAUNCH Appendix 3 Page 1 of 7 Appendix 3 Page 2 of 7 Appendix 3 Page 3 of 7 Appendix 3 Page 4 of 7 Appendix 3 Page 5 of 7 Appendix 3 Page 6 of 7 Appendix 3 Page 7 of 7