Document 3J6YajwO9OKX6DVo1ejD9jx6n

Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 6 Enforcement Division INSPECTION REPORT 05/23/2024 08:45 (CT) Announced: No 05/23/2024 10:15 (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 Brown Water Marine Service None 843 Bishop Road Ingleside, TX 73862 San Patricio County N/A None Brown Water Marine Service is a barge transport company, operating between Houston, Bolivar, and Brownsville. 27.853413, -97.174173 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 5 Brown Water Marine Service Inspection Date: 05/23/2024 SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection 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 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 Page 2 of 5 Brown Water Marine Service Inspection Date: 05/23/2024 Facility General Description Tenant/Area Brown Water Marine Service Inspection Date 05/23/24 Process Description Brown Water Marine Service (Brown Water) is a barge transport company, operating between Houston, Bolivar, and Brownsville. Brown Water uses inland tow boats to transport barges. The location in Ingleside is a fleeting location where customers park their barges. Brown Water performs maintenance including overhauls and fueling for its own vessels. The company also fuels, provides water, and receives bilge slop, used oil, used oil filters, and trash from its own vessels and other vessels. The facility does not maintain a MARPOL COA. Area of Concern No Page 3 of 5 Brown Water Marine Service SECTION II - OBSERVATIONS Inspection Date: 05/23/2024 Tenant: Brown Water Marine Service Section: 2.1 Date: 05/23/24, 8:45 AM Contains AOC: No Contains CBI: No Lead Inspector: Brook McKeown Attendees: Tabitha Brown (Operations) Brown Water began as an oil field service company servicing oil rigs and smaller vessels in 1989. Since then, Brown Water has transitioned to being a barge transport company. The company uses inland tow boats to transport these barges between Houston, Bolivar, and Brownsville. Its customers' barges carry materials such as sugar, crude oil, fertilizer, and scrap metal. Brown Water does not transport waste barges, and it always knows what its customers' barges are carrying before transporting them. This location, in Ingleside, is a fleeting location where customers park their barges. Brown Water also has a couple of small barges that mostly stay in Ingleside. Brown Water performs maintenance including overhauls and fueling for its own vessels. The company also fuels, provides water, and receives bilge slop, used oil, used oil filters, and trash from its own vessels and other vessels at the Ingleside location. Oil filters and oil contaminated debris are collected and disposed of off-site by Sun Coast Resources. Brown Water has a bilge slop tank and a used oil tank. The company has third parties such as Western Gulf Recycling empty these tanks out about 2-3 times per month. To keep track of these activities, the company's maintenance manager runs a ticketing system. Brown Water also generates used batteries that are removed from site once a week. Brown Water does not receive, store, or transport solid or hazardous waste and does not have an EPA ID number. The facility does not maintain a MARPOL COA. During the inspection, the inspection team performed a visual inspection of Brown Water's general yard area, maintenance shop, and tanks and oily debris area. In the maintenance shop, the company's maintenance manager explained that Valley Solvents in Corpus Christi, TX handles all its paint waste, which is collected in 55-gallon drums. Brown Water also contracts for Valley Solvents to perform most of the painting at the facility, although Brown Water does some painting itself. In addition, Valley Solvents manages Brown Water's used parts washer solvents, including testing the solvent. When viewing the tanks, Brown Water personnel indicated that vessels use their own pumps to put bilge slop or used oil into the tanks. The team noted that the used oil tank and the containers for used oil filters had proper labels. After the visual inspection, the inspection team viewed fueling tickets that included dropping off trash, bilge water, filters, and used oil. The inspection team noted no issues with these tickets. No areas of concern (AOCs) were identified during the visual inspection; however, further EPA review may change or add to their potential AOCs. A closing conference was conducted at approximately 10:00 AM with Brown Water personnel. On 05/24/2024, Ms. Brown followed up with an email stating that Brown Water does not have a MARPOL COA (see Appendix 1). Page 4 of 5 Brown Water Marine Service 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 No areas of concern were found during the inspection. 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. 05/24/24 Brown Water email - Tabitha Brown sent an email clarifying that Brown Water does not have a MARPOL COA. SECTION VI - LIST OF APPENDICES Appendix 1. Follow-Up Email from Brown Water Page 5 of 5 APPENDIX 1. FOLLOW-UP EMAIL FROM BROWN WATER Appendix 1 Page 1 of 2 Appendix 1 Page 2 of 2