Document 3QqxwRV3qOamXpNZy4DzbYJox

Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 6 Enforcement Division INSPECTION REPORT 6/5/2024 09:15 AM (CT) 6/5/2024 10:10 AM (CT) RCRA Focused Compliance Inspection (FCI) Announced: No Access: Granted 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 Galliano Marine Service, LLC LAD981599632 16201 E Main St Cut Off, LA 70345 Lafourche Parish Very Small Quantity Generator (VSQG) 493110, 493190 Galliano Marine Service, LLC operates a fleet of vessels transporting wastes from offshore drill ships and oil platforms to Port Fourchon 29.47578, -90.316946 Additional Persons Participating in Inspection: Name Title Organization Email Phone Joyce Johnson Inspector EPA REGION 6 Johnson.Joyce-r6@epa.gov (214) 665-8548 Dedriel Gardner Inspector EPA REGION 6 Gardner.Dedriel@epa.gov (281) 983-2133 Neil Rapp Contractor Eastern Research Neil.Rapp@erg.com Group (ERG) (480) 450-6517 Lead Inspector: Vince Damiano Vincent Damiano ERG Digitally signed by Vincent Damiano Date: 2024.09.09 17:50:16 -04'00' Vince.Damiano@erg.com (703) 835-6281 1 of 5 Galliano Marine Service, LLC Inspection Date: 06/05/2024 SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection Type of inspection: Focused Compliance Inspection (FCI) Port Fourchon 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 maintaining 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 verbal or written statements made during or after the on-site inspection, and 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 Name Lead Inspector/ Contactor/ERG RCRA Inspector/ Contractor/ERG Inspector/Enforcement Officer/EPA Region 6 Inspector/Enforcement Officer/EPA Region 6 Vince Damiano Neil Rapp Joyce Johnson Dedriel Gardner Phone Email (703) 835-6281 Vince.Damiano@erg.com Opening Conf. Yes Closing Conf. Yes (480) 450-6517 Neil.Rapp@erg.com Yes Yes (214) 665-8548 Johnson.Joyce-r6@epa.gov Yes Yes (281) 983-2133 Gardner.Dedriel@epa.gov Yes Yes 2 of 6 Galliano Marine Service, LLC Facility General Description Inspection Date: 06/05/2024 Tenant/Area Inspection Date Galliano Marine Service, LLC 06/05/24 Process Description Areas of Concern Galliano Marine Service, LLC (GMS) operates a fleet of No vessels transporting hazardous waste, non-hazardous waste, and used oil from offshore drill ships and oil platforms to Port Fourchon. The company does not have its own dock space, but delivers waste generated offshore directly to its customers' facilities at the port. Customers are responsible for unloading, storing, and disposing of the waste once it arrives at the dock. GMS does not store any transported waste for its customers. Maintenance on GMS's vessels is performed at third party shipyards that manage any waste generated during cleaning or overhauling the boats. GMS is a VSQG of hazardous waste and does not maintain a MARPOL COA. 3 of 6 Galliano Marine Service, LLC Inspection Date: 06/05/2024 SECTION II - OBSERVATIONS Tenant: Galliano Marice Service, LLC Section: 2.4 Date: 6/5/2024, 9:15 A.M. Contains AOC: No Contains CBI: No Lead Inspector: Vince Damiano Attendees: Matt Labat (QHSE Manager), Brittney Serigney (Environmental Supervisor) Mr. Labat and Ms. Serigney provided the inspection team with a summary of operations at GMS. GMS operates a fleet of vessels transporting hazardous waste, non-hazardous waste, and used oil from offshore drill ships and oil platforms to Port Fourchon. GMS also transports MARPOL Annex V waste (i.e., municipal waste) from ships to shore. Although GMS's vessels operate out of Port Fourchon, the company's office is in Cut Off, Louisiana. GMS is registered as a transporter of hazardous waste (LAD98159932). When transporting hazardous waste, GMS signs the hazardous waste manifest as Transporter #1, with the drill ship or oil platform signing as the generator. The company does not have its own dock space, but delivers waste generated offshore directly to its customers' facilities at the port. Customers are responsible for unloading, storing, and disposing of the waste once it arrives at their docks. GMS does not store any transported waste for its customers and does not maintain a MARPOL COA. GMS is a VSQG of hazardous waste, mostly generated from day-to-day operations on its vessels (i.e., paint waste). GMS arranges for third party transporters to pick up any hazardous waste generated onboard directly from the boats when they dock. GMS does not store any hazardous waste generated by its vessels at the port. In addition, all maintenance on GMS's vessels is performed at third party shipyards, which manage any waste generated during cleaning or overhauling the boats. Since GMS does not maintain a facility at Port Fourchon, no visual inspection was conducted following the opening meeting. No apparent areas of concern (AOCs) were identified during the opening conference; however, further EPA review may change or add to their potential AOCs. At the end of the opening conference, the inspection team requested the following information from GMS: Information on the approximate number of vessels owned and people employed by GMS, as well as clarification on the name used by the company to register as a transporter with EPA (see Appendix 1). The company's most recent RCRA notification (see Appendix 2). The hazardous waste manifests for any waste transported in May 2024 by the vessels C-Ranger and Island Ventures. In a follow-up email, Ms. Serigney explained that neither C-Ranger nor Island Ventures transported hazardous waste in May 2024; however, other GMS vessels did transport hazardous waste that month, and GMS provided those manifests instead (see Appendix 3). SECTION III - RECORDS REVIEW No RCRA regulated records were reviewed during this focused onsite inspection besides those mentioned in Section II. SECTION IV - AREA OF CONCERN No apparent AOCs were identified during this inspection. SECTION V -FOLLOW UP Documents or files provided by the facility were transmitted via email and included the provision of documents requested. 4 of 5 Galliano Marine Service, LLC Inspection Date: 06/05/2024 Communication Log After the inspection, additional information was emailed to EPA including: 1. 6/20/2024 GMS email - Brittney Serigney provided additional information on GMS's operations, GMS's most recent RCRA notification, and May 2024 hazardous waste manifest. SECTION VI - LIST OF APPENDICES Appendix 1 Appendix 2 Appendix 3 - Email Correspondence Follow-Up from GMS GMS 2021 RCRA Notification GMS May 2024 Hazardous Waste Manifest 5 of 5 Appendix 1 Email Correspondence Follow-Up from GMS Neil Rapp From: Sent: To: Cc: Subject: Attachments: Brittney Serigny <brittney.serigny@chouest.com> Thursday, June 20, 2024 10:38 AM Neil Rapp matt.labat@chouest.com; Vince Damiano; Gardner, Dedriel; Johnson, Joyce-R6; Kacey Youens Re: [*EXT*] Follow-Up From EPA Visit 6/5 - Galliano Marine Service June_29_2021_LDEQ_Acknowledgement_of_Receipt_of_HW_1.pdf; GMS 2021 RCRA Notification.pdf; 024661807JJK.pdf; 024661776JJK.pdf; 024661730JJK.pdf; 024660405JJK.pdf; 019581093FLE.pdf; 019580964FLE.pdf; 024077286JJK.pdf; 019253290FLE.pdf; 019253291FLE.pdf; 019253288FLE.pdf; 019253281FLE.pdf; 019253196FLE.pdf; 019253169FLE.pdf; 018805172FLE.pdf; 015243876FLE.pdf; 001290659WAS.pdf; 001290587WAS.pdf; 018805187FLE.pdf CAUTION: Don't open links or attachments unless you recognize the sender and know they are safe. Good Day All, In response to the previous requests: Hazardous wastes manifests for any waste transported by Island Ventures and C-Ranger in May 2024. The MV C-Ranger has been cold-stacked since 2015 and did not transport waste in May 2024. The MV Island Intervention did not transport hazardous waste in May 2024. However, we have attached manifests from May 2024 in which GMS vessels were the transporters. Clarification on the name of the transporter registered with EPA (Galliano Marine Service vs. Galliano Marine Services) - Galliano Marine Service, LLC is the EPA ID LAD981559632 and is a transporter for hazardous waste - Galliano Marine Services, LLC (Fourchon) is the EPA ID LAR000051029; and currently VSQG The property is permitted under a common name, Galliano Marine Services-Fourchon. The parcel is leased by Offshore Support Services, LLC. We are submitting a Notification of Change Form (NOC-1) at the request of LDEQ to change the name from Galliano Marine ServicesFourhcon to Offshore Support Services, LLC and move existing permits to the new name. The approximate number of employees and number of vessels operated by Galliano Marine Service. 80 vessels operating in GOM for the month of May 2024, approximately 700 mariners Your most recent RCRA notification See attached "June_29_2021_LDEQ_Acknowledgement_of_Receipt_of_HW_1" and "GMS 2021 RCRA Notification." for Galliano Marine Service, LLC, EPA ID LAD981559632 1 Appendix 1 Page 1 of 2 To help protect y our priv acy , Microsoft O ffice prev ented automatic download of this picture from the Internet. Brittney Serigny| Environmental Supervisor Edison Chouest Offshore Companies Direct (985) 601-4277 | Cell (985) 213-8100 Receptionist (985) 601-4444 | Ext. 51714 16201 E. Main St. | Cut Off, LA 70345 On Wed, Jun 5, 2024 at 5:01PM Neil Rapp <Neil.Rapp@erg.com> wrote: Hi Brittney, Thank you for your assistance in completing the inspection this morning at Galliano Marine Service. No areas of concern were noted at the time of the inspection. I am following up with a list of requested items from our inspection today. We would like you to send us: Hazardous wastes manifests for any waste transported by Island Ventures and C-Ranger in May 2024. Clarification on the name of the transporter registered with EPA (Galliano Marine Service vs. Galliano Marine Services) The approximate number of employees and number of vessels operated by Galliano Marine Service. Your most recent RCRA notification Please send the requested information to me and the persons copied on this email within two weeks from this Friday. Thanks again for your time and please let us know if you have any questions or concerns. Regards, Neil Rapp, P.E. Senior Engineer Cell: 480-450-6517 neil.rapp@erg.com 2 Appendix 1 Page 2 of 2 Appendix 2 GMS 2021 RCRA Notification LDEQ-EDMS Document 12778399, Page 1 of 2 Appendix 2 Page 1 of 10 LDEQ-EDMS Document 12778399, Page 2 of 2 Appendix 2 Page 2 of 10 LDEQ-EDMS Document 12797796, Page 1 of 8 Appendix 2 Page 3 of 10 LDEQ-EDMS Document 12797796, Page 2 of 8 Appendix 2 Page 4 of 10 LDEQ-EDMS Document 12797796, Page 3 of 8 Appendix 2 Page 5 of 10 LDEQ-EDMS Document 12797796, Page 4 of 8 Appendix 2 Page 6 of 10 LDEQ-EDMS Document 12797796, Page 5 of 8 Appendix 2 Page 7 of 10 LDEQ-EDMS Document 12797796, Page 6 of 8 Appendix 2 Page 8 of 10 LDEQ-EDMS Document 12797796, Page 7 of 8 Appendix 2 Page 9 of 10 LDEQ-EDMS Document 12797796, Page 8 of 8 Appendix 2 Page 10 of 10 Appendix 3 GMS May 2024 Hazardous Waste Manifests Appendix 3 Page 1 of 40 Appendix 3 Page 2 of 40 Appendix 3 Page 3 of 40 Appendix 3 Page 4 of 40 Appendix 3 Page 5 of 40 Appendix 3 Page 6 of 40 Appendix 3 Page 7 of 40 Appendix 3 Page 8 of 40 Appendix 3 Page 9 of 40 Appendix 3 Page 10 of 40 Appendix 3 Page 11 of 40 Appendix 3 Page 12 of 40 Appendix 3 Page 13 of 40 Appendix 3 Page 14 of 40 Appendix 3 Page 15 of 40 Appendix 3 Page 16 of 40 Appendix 3 Page 17 of 40 Appendix 3 Page 18 of 40 Appendix 3 Page 19 of 40 Appendix 3 Page 20 of 40 Appendix 3 Page 21 of 40 Appendix 3 Page 22 of 40 Appendix 3 Page 23 of 40 Appendix 3 Page 24 of 40 Appendix 3 Page 25 of 40 Appendix 3 Page 26 of 40 Appendix 3 Page 27 of 40 Appendix 3 Page 28 of 40 Appendix 3 Page 29 of 40 Appendix 3 Page 30 of 40 Appendix 3 Page 31 of 40 Appendix 3 Page 32 of 40 Appendix 3 Page 33 of 40 Appendix 3 Page 34 of 40 Appendix 3 Page 35 of 40 Appendix 3 Page 36 of 40 Appendix 3 Page 37 of 40 Appendix 3 Page 38 of 40 Appendix 3 Page 39 of 40 Appendix 3 Page 40 of 40