Document 0goJY7JYzw7866v0r0EvZjd6d

Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 6 Enforcement Division INSPECTION REPORT 11/4/2024 14:00 (CT) 11/4/2024 14:55 (CT) Announced: No (tenants and related facilities) 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 SSA Marine N/A 1355 Wallace St. Beaumont, TX 77701 Jefferson County Non-generator 488320 SSA Marine is a facility that offloads bulk cargo from ships and loads them onto trucks and railcars for delivery. 30.07391, -94.08275 Additional Persons Participating in Inspection: Name Title Organization Angela Hays Inspector EPA REGION 6 Sandesh Thapa Inspector EPA REGION 6 Jon Herbay Contractor Eastern Research Group (ERG) Email Hays.Angela@epa.gov Thapa.Sandesh@epa.gov Jon.Herbay@erg.com Phone (214) 665-2285 (214) 665-2265 (412) 780-9931 Lead Inspector: Vince Damiano Chemical Engineer ERG Vincent Damiano Digitally signed by Vincent Damiano Date: 2025.02.06 11:53:46 -05'00' Vince.Damiano@erg.com 02/06/2025 (703) 633-1732 Page 1 of 4 SSA Marine Inspection Date: 11/04/2024 SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection The Port of Beaumont 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 Environmental Protection Agency (EPA) during or after the on-site inspection. In addition, information gathered prior to or after the inspection from a review of EPA, State, and public records may be included in this report. Attendees Title/Organization Lead Inspector/ Contractor/ERG Inspector/Enforcement Officer/EPA Region 6 Inspector/Enforcement Officer/EPA Region 6 RCRA Inspector/ Contractor/ERG SSA Marine Name Vince Damiano Angela Hays Sandesh Thapa Jon Herbay Jana Watson Phone Email Opening Closing Conf. Conf. (703) 633- Vince.Damiano@erg.com Yes Yes 1732 (214) 6652285 Hays.Angela@epa.gov Yes Yes (214) 665- Thapa.Sandesh@epa.gov Yes Yes 2265 (412) 7809931 Jon.Herbay@erg.com Yes Yes (409) 988 8189 Jana.Watson@ssamarine.com Yes Yes Page 2 of 4 SSA Marine Facility General Description Inspection Date: 11/04/2024 Tenant/Area SSA Marine Inspection Date 11/04/24 Process Description SSA Marine (SSA) is a stevedore facility that offloads steel billets from ships and loads them onto trucks and railcars. Their facility is covered under Port of Beaumont's MARPOL COA for Annexes I and V. Area of Concern Yes SECTION II - OBSERVATIONS Tenant: SSA Marine Section: 2.1 Date: 11/04/24, 02:00 PM Contains AOC: Yes Lead Inspector: Vince Damiano Attendees: Jana Watson (SSA Safety Manager) Contains CBI: No SSA is located within the Port of Beaumont and operates as a stevedore, loading and unloading cargo from vessels. The cargo SSA handles consists primarily of steel billets, pulp paper, and project cargo. SSA used forklifts and yard trucks to move cargo. Any cranes they may use to conduct their operations are owned and maintained by the Port of Beaumont. SSA will have a mechanic come from the Port Arthur location to conduct maintenance on equipment. Any used oil from maintenance activities is drummed up and brought back to the Port Arthur location and added to their used oil storage. SSA is covered under Port of Beaumont's MARPOL COA, but Ms. Watson stated they do not remove trash or waste from vessels. However, SSA may remove dunnage from vessels. SSA is considered a non-generator of hazardous waste. Following the opening conference, the inspection team conducted a visual inspection of SSA's Maintenance Garage where SSA repairs their trucks and forklifts and stores equipment. The inspection team first observed two used lead-acid batteries (see Appendix 1 - Photos 1 to 2). The batteries were not labeled as universal waste. The inspection team asked Jana Watson if they knew the accumulation start date of the used batteries. Ms. Watson was not sure but said a vendor swaps the batteries out several times throughout a year; no BOLs or receipts were provided following the inspection [ AOC #1 - SSA did not label batteries being managed as universal waste properly or store the batteries in a properly labeled container - 40 CFR 273.14(a)]. Next, the inspection team observed a 55-gallon drum of used antifreeze in the back corner of the maintenance garage that was approximately half full (see Appendix 1 - Photos 3 and 4). Ms. Watson stated the used antifreeze is sent for recycling at Action Oil once SSA fills the drum. The inspection team noticed the funnel on top of the drum was not plugged and suggested the drum of antifreeze should remain closed when not in use to minimize the potential for a release. The inspection team walked through the storage yard and did not observe any other areas of concern (AOCs). The inspection team did not observe other AOCs at the time of the inspection. However, further EPA review may change or add to their potential AOCs. A closing conference was conducted at approximately 2:55 PM with SSA personnel. The AOCs were communicated during the closing. Page 3 of 4 SSA Marine Inspection Date: 11/04/2024 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: SSA Marine AOC #1 - SSA did not label batteries being managed Citation: 40 CFR 273.14(a) as universal waste or store the batteries in a container labeled as "Universal Waste--Battery(ies), "Waste Battery(ies)," or "Used Battery(ies)." Section: 2.1 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. SECTION VI - LIST OF APPENDICES Appendix 1. Photograph Log Page 4 of 4 APPENDIX 1. PHOTOGRAPH LOG UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: SSA Marine City: Beaumont County/Parish: Jefferson State: Texas Photo No. 1 Photo File Name: DSCN7651 Date of Photo: 11/04/2024 Time of Photo: 14:56 hrs. Photographer: Vince Damiano Description: An unlabeled lead-acid battery was found on top of a 5-gal container inside the Maintenance Garage. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: SSA Marine City: Beaumont County/Parish: Jefferson State: Texas Photo No. 2 Photo File Name: DSCN7652 Date of Photo: 11/04/2024 Time of Photo: 14:56 hrs. Photographer: Vince Damiano Description: An unlabeled lead-acid battery was found on top of a plastic drip pad inside the Maintenance Garage. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: SSA Marine City: Beaumont County/Parish: Jefferson State: Texas Photo No. 3 Photo File Name: DSCN7653 Date of Photo: 11/04/2024 Time of Photo: 14:57 hrs. Photographer: Vince Damiano Description: View of a 55-gal drum containing used antifreeze that was approximately half full inside the Maintenance Garage. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: SSA Marine City: Beaumont County/Parish: Jefferson State: Texas Photo No. 4 Photo File Name: DSCN7654 Date of Photo: 11/04/2024 Time of Photo: 14:57 hrs. Photographer: Vince Damiano Description: View of the funnel on the 55-gal used anti-freeze container that was not plugged or closed.