Document 6R9gj9RV67kOm3Ne9pBOey5Z3

EPA REGION 6 ENFORCE~ENT DIVISION INSPECTION REPORT FRS#: Media#: Permit#: Inspection Type: Inspection Date: Company Name: Facility Name: Physical Location: Mailing Address: County/Parish: SIC Code: NAICS Code: Regulatory Programs Facility Representatives: EPA Inspector: State Inspectors: EPA Lead Inspector Signature/Date Peer Reviewer Signature/Date: Supervisor Signature/Date 110003265662 LAD000132167 .. Resource Conservation and Recovery Act, Compliance Evaluation Inspection March 18-20, 2014 T. T. BARGE SERVICES, LLC. T. T. BARGE SERVICES, LLC.- MILE 237 5190 North River Road Port Allen, Louisiana 70767 19368 Highway 36 Covington, Louisiana 70433 West Baton Rouge Parish 4499 48839 RCRA: Large Quantity Generator Mark Toepfer President- T. T. Barge Services, LLC David Hernandez EH&S Manager- T. T. Barge Mile 23 7 Cory Womack Yard Manager- T. T. Barge Mile 23 7 Chad V. Scott, PE MCL Environmental Engineering Solutions Chris Scott Compliance Officer- Marine Chemist of LA John Penland 6EN- Environmental Scientist HE Daniel J. Cheatham LDEQ Environmental Scientist Capital Region L ,1j:;T .f?)A J9n P~nd, Envirom~ntal Scientist ~&-~ ....-....""'" Joyfo .JMhnson, Env#nmental Protection Specialist ~ Gut/,.-TTo;;' Chie0Jazardous Waste Enforcement Section , 225-4 73-8222 225-267-4505 225-267-4505 222-751-7228 214-665-9717 225-219-3026 6/z)zoN {Date} t;./~/~0/ {Date} /M~ "-/ {Date} EPA REGION 6 ENFORCEMENT DIVISION INSPECTION REPORT FRS #: Media #: Permit #: Inspection Type: Inspection Date: Company Name: Facility Name: Physical Location: Mailing Address: County/Parish: SIC Code: NAICS Code: Regulatory Programs Facility Representatives: EPA Inspector: State Inspectors: EPA Lead Inspector Signature/Date 110003265662 LAD000132167 Resource Conservation and Recovery Act, Compliance Evaluation Inspection March 18-20, 2014 T. T. BARGE SERVICES, LLC. T. T. BARGE SERVICES, LLC. - MILE 237 5190 North River Road Port Allen, Louisiana 70767 19368 Highway 36 Covington, Louisiana 70433 West Baton Rouge Parish 4499 48839 RCRA: Large Quantity Generator Mark Toepfer David Hernandez Cory Womack Chad V. Scott, PE Chris Scott John Penland Daniel J. Cheatham President - T. T. Barge Services, LLC EH&S Manager - T. T. Barge Mile 237 Yard Manager - T. T. Barge Mile 237 MCL Environmental Engineering Solutions Compliance Officer- Marine Chemist of LA 6ENHE LDEQ Capital Region Environmental Scientist Environmental Scientist 225-473-8222 225-267-4505 225-267-4505 222-751-7228 214-665-9717 225-219-3026 John Penland, Environmental Scientist {Date} Peer Reviewer Signature/Date: Supervisor Signature/Date Joyce Johnson, Environmental Protection Specialist Guy Tidmore, Chief - Hazardous Waste Enforcement Section {Date} {Date} T. T. Barge Services, LLC. - Mile 237 FY2014 RCRA Compliance Inspection Section I - INTRODUCTION PURPOSE OF THE INSPECTION At 9:30 am on March 18, 2014, I, EPA Region 6 inspector John Penland, and Louisiana Department for Environmental Quality (LDEQ) inspector Daniel Cheatham arrived at the T. T. Barge Services, LLC - Mile 237 facility (the facility) for an unannounced compliance evaluation inspection. I presented my credentials to Mr. David Hernandez, the facility Environmental, Health, & Safety manager, and informed him that this was an EPA inspection to determine compliance with the Resource Conservation and Recovery Act (RCRA). The inspection included a review of the facility's waste determination process, direct observation of the waste management units, and a review of the facility's records in order to evaluate the compliance of the facility with the hazardous waste generator requirements of RCRA. This report serves as documentation of the onsite activities and observations as they pertain to the RCRA CEI. Photographs taken during the inspection to document onsite observations are included as Appendix 1. FACILITY DESCRIPTION1 The T. T. Barge Services, LLC - Mile 237 facility cleans and repairs barges at a location north of Port Allen, W. Baton Rouge Parrish, Louisiana in the batture of the Mississippi River. The facility, formerly known as Tiger Shipyard, Inc., has been in operation since 1987. The facility is comprised of two separate operational areas located approximately one-quarter mile apart. The facility currently has approximately 17 employees who work in two shifts between the hours of 7:00 am to 6:30 pm local time. They also employ either current or former employees to provide 24 hour security. The barge cleaning area is comprised of five moored barges: Office Barge - A dock barge which serves as the site of the Yard Managers office, the caustic storage tank, and a diesel storage tank. Gas Free-l - A dock barge which serves as the primary work barge for the gas freeing process. The units located on the barge include vacuum pumps and product storage tanks. TT-3 - a three compartment tank barge located north of the Office Barge, with a total capacity of approximately 307,658 gallons, used for wash water storage. DM 907 - a twenty-eight compartment tank barge with a total storage capacity of 430,826 gallons, previously used for wash water and product storage. This barge was taken out of service at the end of 2012, but still contains material from its previous service. According to Mark Toepfer, this barge will be scrapped when empty. CHEM 94 - a three compartment tank barge with a total storage capacity of 448,134 gallons, previously used for the storage of wash water. This barge was 1 Appendix 2 - Facility Maps and Diagrams 2 T. T. Barge Services, LLC. - Mile 237 FY2014 RCRA Compliance Inspection taken out of service in the middle of 2012, but still contains material from its previous service. According to Mark Toepfer, this barge will be converted into a dock barge when empty. DM 365 - a dock barge equipped with three above deck product storage tanks. This barge was taken out of service at the end of 2012 and the tanks have been fully cleaned and empty. According to Mark Toepfer, the tanks will be removed and this barge will be brought back into service as a dock barge. Two container storage areas, a hydrocarbon vapor combustor, and the natural gas fired boiler all reside on the batture. Barges arrive at the cleaning area to be gas-freed and/or cleaned. Heels and gases are pumped out and fluids stored for offsite recycling or classified as waste and accumulated onsite prior to being shipped for treatment or disposal offsite. Waste is stored in compartments on the moored barges or in containers onshore. Repairs and maintenance procedures are completed in the repair dock area which is located west of the cleaning area. The Barge repair and maintenance services are performed on moored vessels using equipment located on several work barges, including the DM 4902 (Office Barge), the IC 1 (Work Barge), the DM 4503 (Work Barge), the DM 349 (Work Barge), the LTC 60 (Work Barge), the DM 1701 (Work Barge), and the DM 360 (Work Barge). There are also three dry docks at the facility: DD-1, DD-2, and DD-3. Typical repairs include removal and replacement of worn or damaged pipes, valves, pumps, structural supports, or other relatively small barge parts. Welding and cutting equipment required for these mechanical and structural repairs is maintained in the Office Barge area. Barges are repaired once they have been gas-freed and certified safe by a marine chemist. According to its annual hazardous waste reports2, the facility is a large quantity generator of hazardous waste and a hazardous waste transporter. These reports indicate that the facility's annual generation of hazardous waste is greater than 3 million pounds and includes: benzene contaminated wash waters (D018), caustic soda solution (D002), and flammable wash waters (D001). WASTE MANAGEMENT The facility generates batches of wash water during wet, barge cleaning processes which occur after heels have been removed and a barge has been made gas-free. These wash waters accumulate within the compartment being cleaned. The wash waters are then pumped into a series of containers for processing based on their classification as either hazardous or nonhazardous. These processes are functionally identical and consist of one portable, roll-off container, which serves as a settling box for solids, and a portable, frac tank (container), which serves to separate any oils from the wash water. In each step the wash waters are transferred using portable pumps and flexible hoses directly through the open hatches of the container. Since the facility is located within the batture of the Mississippi River, it is subject to periodic flooding due to high river levels. During these periods of high water, the wash water management containers, which are located on shore, must be removed and wash waters are 2 Appendix 3 - Annual Hazardous Waste Reports 3 T. T. Barge Services, LLC. - Mile 237 FY2014 RCRA Compliance Inspection pumped into compartments on moored barges for storage until the waters recede. Currently Barge TT3 serves as the wash water storage barge. Though this barge is currently moored in place, it could potentially be used for transportation given the proper certifications and could, therefore, be classified as a container under RCRA. RECENT FACILTY COMPLIANCE HISTORY In September of 2012, a RCRA compliance inspection of the facility was conducted by Eva Steele (USEPA Region 6). In her inspection report, Ms. Steele identified a number of areas of concern at the time of the inspection. These concerns included: Potential storage of hazardous waste in containers onsite for a period of time greater than 90 days without a permit. Potential storage of hazardous waste in containers which are unfit for service Potential storage of hazardous waste in containers which are unmarked Potential storage of hazardous waste in containers which are open Potential discharge of hazardous waste to the Mississippi River. Failure to maintain an updated contingency plan Section II - INSPECTION DETAILS & OBSERVATIONS WASTE DETERMINATION The barge cleaning process generates batches of contaminated wash waters which are determined to be hazardous or non-hazardous wastes based on the facility's knowledge of the barge contents prior to cleaning. This determination is made by Cory Womack, Yard Manager, in conjunction with Chris Scott, Marine Chemist. A job sheet is prepared for each customer barge serviced by the facility. The information documented in this job sheet includes: the barge designation, the barge's arrival date at the facility, the customer name, the barge's last known cargo, the barge's next anticipated cargo, the type of service to be performed on the barge, and whether the job created a wash water. However, the job sheet does not specify the how this wash water was managed after its generation. Therefore, on March 19, 2014, I reviewed the job sheets for each barge that had been cleaned at the facility since January 1, 2014 in order to determine whether the wash waters generated during each cleaning were hazardous or non-hazardous. This review was conducted with participation by Mark Toepfer, David Hernandez, Cory Womack, Chad Scott, and Chris Scott (by phone) in attendance. In each case Chris Scott and Cory Womack provided a statement declaring whether the wash waters generated during the cleaning were hazardous or non-hazardous. Their declarations are summarized in the Table 1. Table 1 - Hazardous Waste Declarations for Wash Waters Generated During Barge Cleaning Barge Contents Regulatory Status of Wash Waters Toluene Managed as hazardous, claimed as potentially non-hazardous Olefin - C12 Non-hazardous Olefin - C10 Non-hazardous Methanol Managed as hazardous, potentially D001 BTX Managed as hazardous, D018 4 Tetramer Ethanol Styrene Pygas Cumene Biodiesel Butyl Cellosolve (Ethylene Glycol mono-Butyl Ether) Linear Alky Benzene Naptha Isopropyl Alcohol Reformate Methyl Ethyl Ketone C5 cut Pentadiene Asphalt Natural Gasoline Gasoline Acetone N-butanol Carbitol T. T. Barge Services, LLC. - Mile 237 FY2014 RCRA Compliance Inspection Non-hazardous Managed as non-hazardous, potentially D001 but highly dilute Non-hazardous Managed as hazardous, D018 Non-hazardous Non- hazardous Managed as hazardous, claimed as nonhazardous Managed as hazardous, D001 Non-hazardous Managed as hazardous, D001 Managed as hazardous, D018 Managed as hazardous, D001 D035 Managed as hazardous, claimed as potentially non-hazardous Non-hazardous Managed as hazardous, D018 Managed as hazardous, D018 Non-hazardous Managed as hazardous, D001 Managed as hazardous, D001 A database containing the full collection of job sheets for the facility was collected during the inspection for later review. This database has been claimed as Confidential Business Information (CBI) by the facility due to the presence of customer details. Another aspect of this review revolved around a discussion of the point of generation and regulatory status for the wash water waste streams. According to Mark Toepfer and Chad Scott, the facility does not consider the wash waters to be wastes until they have been removed from the facility's wash water management containers for shipment to an offsite disposal facility. According to Mr. Toepfer, some, but not all, of the wash waters contain recoverable amounts of petroleum which is separated during the wash water management process and sold as a refinable product. According to, 70 Federal Register 57779, wash waters from container cleaning operations are subject to full regulation under Subtitle C if the removal or subsequent management of the residue generates a new hazardous waste that exhibits any of the characteristics identified in Part 261, Subpart C. The relevant exception to this that may apply to the wash waters generated from the cleaning of containers used for the transportation of materials within the petroleum production and refining process is the "recovered oil exclusion" which is codified at 40 CFR 261.4(a)(12)(ii). However, the facility does not take any steps to segregate these petroleumrelated wash waters from their other hazardous wash waters. Consequently, the hazardous wash waters and each unit employed for their management would be subject to regulation under RCRA. 5 T. T. Barge Services, LLC. - Mile 237 FY2014 RCRA Compliance Inspection INSPECTION OBSERVATIONS On March 18, 2014, Daniel Cheatham and I physically inspected the T. T. Barge waste management units. We were accompanied on this inspection by Mr. David Hernandez, Mr. Cory Womack, and Mr. Chad Scott. Frac Tanks3 We began our review with the two, 20,000 gallon capcity, wash water frac tanks. These containers were staged on the soils of the batture within a temporary, secondary containment. One of the frac tanks was being used for the storage of hazardous wash waters and had a hazardous waste label affixed to it. This label, however, was not marked with the date when the accumulation of the waste began. Wastes are transferred into the containers through open hatches in the top of the containers using flexible hoses. At the time of this inspection, the hatches on the containers were open with the hoses left in the containers. Waste was being transferred into the non-hazardous waste container but waste was not being added to the hazardous waste container. After I informed the facility representatives that this could be an area of concern, they closed the hatch on the afternoon of March 18, 2014. On March 20, 2014, Mr. Hernandez stated that the frac tank had last been emptied, with the solids removed, on January 15, 2014. Roll-off Containers4 The two roll-off containers used for gravity separation of solids from the wash waters are located in a sloped, concrete-lined area adjacent to the frac tanks. At the time of this inspection one of the roll-off containers was used for the management of hazardous wash water. This rolloff container had a hazardous waste label affixed to it. This label, however, was not marked with the date when the accumulation of the waste began. Wastes are transferred into the containers through open covers in the top of the containers using flexible hoses. At the time of this inspection, the covers on the containers were open with the hoses left in the containers. Waste was being transferred from the non-hazardous waste container but waste was not being added to or removed from the hazardous waste roll-off container. After I informed the facility representatives that this could be an area of concern, they closed the top of the container on the afternoon of March 18, 2014. On March 18, 2014, I observed an accumulation of solid sludgelike material beneath and around the hazardous waste roll-off container. This material resembled the contents of the container. On March 19, 2014, I observed that these materials were still present. Therefore, I requested that the facility not remove them until I had collected a sample for analysis. On March 20, 2014, I collected a sample of this material and sent it to the EPA Region 6 laboratory in Houston, Texas for analysis in order to determine whether the material demonstrated any of the characteristics of a hazardous waste. The final laboratory report is included as Appendix 4. Storage Barges5 For each of the storage barges (CHEM 94, TT3, and DM907) we visited the barge and asked for the contents of each storage compartment. I addition we requested that the facility 3 Appendix 1- Inspection Photographs - Photos 5-9, 41 4 Appendix 1- Inspection Photographs - Photos 10-18, 42, 46-49 5 Appendix 1- Inspection Photographs - Photos 36 and 37 6 T. T. Barge Services, LLC. - Mile 237 FY2014 RCRA Compliance Inspection provide inventory sheets documenting the contents of the barges since 2011. These inventory sheets are provided as Appendix 5. CHEM 94 - At the time of this inspection CHEM 94 had been out of service for more than 18 months. According to a statement made by Mr. Cory Womack on March 18, 2014, the barge had not been emptied of sludges when it was taken out of service. According to a statement by the facility representatives on March 20, 2014, the barge had least been emptied with sludges removed in 2010. According to Mr. Mark Toepfer, the last inventory conducted on this barge prior to being taken out of service was recorded on April 2, 2012. On March 18, 2014, I requested that the facility provide me the quantity and description of the current contents of each of the three compartments of CHEM 94. In response Mr. Cory Womack manually gauged each compartment and provided the depth measurement and a description of the contents. Using the compartment specific gauging tables provided by the facility, I converted these depth measurements into the corresponding approximate volumes. At the time of this inspection the compartment contents were as follows : CHEM 94 Compartment # 1 - approximately 1,860 gallons of sludge. Previous contents listed on the April 2, 2012 inventory are 7,059 gallons of "Nonhazardous Sludge/Rust". CHEM 94 Compartment # 2 - approximately 9,030 gallons of sludge. The atmosphere of the compartment was measured as being at 20% of the lower explosive limit indicating the presence of volatile organic compounds. Previous contents listed on the April 2, 2012 inventory are 46,712 gallons of "Hazardous Wash Water" and 2,300 gallons of "Dirty BTX" CHEM 94 Compartment # 3 - approximately 4,710 gallons of sludge. Previous contents listed on the April 2, 2012 inventory are 37,722 gallons of "Hazardous Wash Water" and 1,855 gallons of "Dirty BTX" TT3 - At the time of this inspection TT3 was the active storage barge for wash waters generated by the barge cleaning process. According to a statement made by facility representatives on March 20, 2014, the barge had last been emptied with sludges removed on January 12, 2012. According to a statement made by Mr. Cory Womack on March 18, 2014, wash waters had last been loaded into the barge between two and three months prior to this inspection. On March 18, 2014, I requested that the facility provide me the quantity and description of the current contents of each of the three compartments of TT3. In response Mr. Cory Womack manually gauged each compartment and provided the depth measurement and a description of the contents. Using the compartment specific gauging tables provided by the facility, I converted these depth measurements into the corresponding approximate volumes. At the time of this inspection the compartment contents were as follows : TT3 Compartment # 1 - approximately 4,260 gallons of non-hazardous wash water. 7 T. T. Barge Services, LLC. - Mile 237 FY2014 RCRA Compliance Inspection TT3 Compartment # 2 - approximately 5,543 gallons of non-hazardous wash water. TT3 Compartment # 3 - approximately 4,308 gallons of hazardous wash water. At the time of this inspection the hatch for this compartment was open with the hose used to add and remove wash waters left partially inside the compartment. After I informed Mr. Womack that this could potentially be an area of concern, he closed the hatch and secured it. DM907 - At the time of this inspection DM907 had been out of service for more than 15 months. According to a statement made by Mr. Cory Womack on March 18, 2014, no materials had been added to the barge since it was taken out of service and the last time material had been removed from the barge was at least six months prior to this inspection. Time did not permit a full inventory of the barge to be taken during this inspection on March 18, 2014. However, on March 19, 2014, facility representatives stated that the current contents of the barge were reflected on the inventory taken on June 20, 2013. The last inventory provided that predates the time when the barge was alledgedly taken out of service is dated April 2, 2012. Based on the June 20, 2013 inventory, at the time of this inspection the compartment contents were as follows: DM907 Compartment # 1 - approximately 1,849 gallons of "Rust" and 693 gallons of unspecified material. Previous contents listed on the April 2, 2012 inventory are puddles of "Non-Haz Wash Water". DM907 Compartment # 2 - approximately 1,953 gallons of "Rust" and 9,636 gallons of unspecified material. Previous contents listed on the April 2, 2012 inventory as puddles of "Non-Haz Wash Water". DM907 Compartment # 3 - approximately 3,627 gallons of "Rust" and 6,193 gallons of unspecified material. Previous contents listed on the April 2, 2012 inventory as "Hazardous Solids" DM907 Compartment # 4 - approximately 1,001 gallons of "Styrene Polymer". Previous contents listed on the April 2, 2012 inventory as "Contains some styrene polymer". DM907 Compartment # 5 - approximately 5,563 gallons of "Rust" and 696 gallons of unspecified material. Previous contents listed on the April 2, 2012 inventory as puddles of "Non-Haz Wash Water". DM907 Compartment # 6 - approximately 4,532 gallons of unspecified material. Previous contents listed on the April 2, 2012 inventory as 1,040 gallons of "STY/BTX mixture". DM907 Compartment # 7 - approximately 2,714 gallons of "Rust" and 1,206 gallons of unspecified material. Previous contents listed on the April 2, 2012 inventory as puddles of "Non Haz Wash Water" 8 T. T. Barge Services, LLC. - Mile 237 FY2014 RCRA Compliance Inspection DM907 Compartment # 8 - approximately 10,217 gallons of unspecified material. Previous contents listed on the April 2, 2012 inventory as "Clean Tank" DM907 Compartment # 9 - approximately 9,111 gallons of unspecified material. Previous contents listed on the April 2, 2012 inventory as puddles of "Non Haz Wash Water" DM907 Compartment # 10 - approximately 310 gallons of "Rust" and 5,049 gallons of unspecified material. Previous contents listed on the April 2, 2012 inventory as 4,117 gallons of "Haz water" and 1,243 gallons of "Oil" DM907 Compartment # 11 - approximately 7,463 gallons of "Rust" and 777 gallons of unspecified material. Previous contents listed on the April 2, 2012 inventory as "Haz Solids" DM907 Compartment # 12 - approximately 10,514 gallons of unspecified material. Previous contents listed on the April 2, 2012 inventory as 1,435 gallons of "Alcohol Wash Water" DM907 Compartment # 13 - approximately 1,403 of "Rust" and 11,804 gallons of unspecified material. Previous contents listed on the April 2, 2012 inventory as "Empty" DM907 Compartment # 14 - approximately 4,104 gallons of "Rust" and 5,932 gallons of unspecified material. Previous contents listed on the April 2, 2012 inventory as 5,590 gallons of "Haz Wash Water" and 342 gallons of "Oil" DM907 Compartment # 15 - approximately 686 gallons of "Rust" and 12,235 gallons of unspecified material. Previous contents listed on the April 2, 2012 inventory as 3,888 gallons of "Hazardous Wash Water" and 229 gallons of "Oil" DM907 Compartment # 16 - "Clean Tank". Previous contents listed on the April 2, 2012 inventory as "Clean Tank" DM907 Compartment # 17 - approximately 1,413 gallons of "Rust" and 4,237 gallons of unspecified material. Previous contents listed on the April 2, 2012 inventory as puddles of "Ethanol/Oil" DM907 Compartment # 18 - approximately 4,118 gallons of "Rust" and 1,830 gallons of unspecified material. Previous contents listed on the April 2, 2012 inventory as puddles of "Dirty BTX" DM907 Compartment # 19 - approximately 11,022 gallons of "Rust" and an unspecified quantity of "Mold". Previous contents listed on the April 2, 2012 inventory as 6,889 gallons of "Haz Wash Water" 9 T. T. Barge Services, LLC. - Mile 237 FY2014 RCRA Compliance Inspection DM907 Compartment # 20 - approximately 7,038 gallons of "Rust" and 5,751 gallons of unspecified material. Previous contents listed on the April 2, 2012 inventory as 5,870 gallons of "Haz Wash Water" DM907 Compartment # 21 - "Clean Tank". Previous contents listed on the April 2, 2012 inventory as "Clean Tank" DM907 Compartment # 22 - approximately 2,833 gallons of "Rust" and 12,277 gallons of unspecified material. Previous contents listed on the April 2, 2012 inventory as 9,325 gallons of "Haz Wash Water" DM907 Compartment # 23 - approximately 7,217 gallons of "Rust" and 3,249 gallons of unspecified material. Previous contents listed on the April 2, 2012 inventory as 3,610 gallons of "Haz Wash Water" DM907 Compartment # 24 - "Clean Tank". Previous contents listed on the April 2, 2012 inventory as "Clean Tank" DM907 Compartment # 25 - "Mold and Buckets (Molasses)". Previous contents listed on the April 2, 2012 inventory as "Clean Tank" DM907 Compartment # 26 - approximately 4,307 gallons of "Rust" and 1,917 gallons of unspecified material. Previous contents listed on the April 2, 2012 inventory as 13,046 gallons of "Haz Wash Water" DM907 Compartment # 27 - "Clean Tank". Previous contents listed on the April 2, 2012 inventory as "Clean Tank" DM907 Compartment # 28 - approximately 1,476 gallons of "Rust" and 983 gallons of unspecified material. Previous contents listed on the April 2, 2012 inventory as puddles of "Non-Haz Wash Water" Ancillary Equipment6 On March 18, 2014, I observed the transfer of non-hazardous wash waters from the non- hazardous wash water roll-off container to the non-hazardous wash water frac tank using a portable pump. During this transfer a leak from the pump was generating a steady stream of liquids which flowed into the sloped concrete containment area where the containers are located. According to a statement made by Mr. Cory Womack on March 18, 2014, this same pump is also used for the transfer of hazardous wash waters. Document Review On March 20, 2014, we reviewed the documents maintained by the facility to demonstrate compliance with the recordkeeping requirements of RCRA for LQGs. This review encompassed the facility's records of employee training, contingency plans, hazardous waste 6 Appendix 1 - Inspection Photographs - Photos 15-17 10 T. T. Barge Services, LLC. - Mile 237 FY2014 RCRA Compliance Inspection manifests, and annual waste reports. I did not identify any immediate concerns with the employee training records, annual waste reports, or contingency plan. However, twelve hazardous waste manifests issued in 2013 for hazardous waste shipments designated for Lonestar Ecology in Pasadena, Texas were not completed by T. T. Barge Services prior to shipment7. Excerpts of these documents were collected as part of this inspection for further review. 7 Appendix 6 - Selected Hazardous Waste Manifests 11 Section III - AREAS OF CONCERN T. T. Barge Services, LLC. - Mile 237 FY2014 RCRA Compliance Inspection Areas of Concern Documentation Regulatory References Comments 1 Operation of a Hazardous Attachment 5 Waste Storage Unit Without a Permit - Barge TT3 40 CFR 270.1 LAC 33:V.303.B Storage of hazardous waste in barge TT3 without meeting the permit exemption requirements 1a Failure to label containers used for the storage of hazardous waste with the words "Hazardous Waste" 40 CFR 262.34(a)(3) LAC 33:V.1109.E.1.d There were no markings present to indicate that TT3 was in hazardous waste service 1b Failure to label containers used for the storage of hazardous waste with the date of accumulation of the waste 40 CFR 262.34(a)(2) LAC 33:V.1109.E.1.c There were no markings present to indicate when the accumulation of the hazardous waste stored in TT3 began 1c Unpermitted storage of a hazardous waste for a period greater than 90 days 40 CFR 262.34 LAC 33:V.1109.E.1 According to statements made by facility representatives, the compartments of TT3 had not been rendered empty since January 12, 2012. 1d Failure to close containers used Attachment 1 - 40 CFR for the storage of a hazardous waste Photos 36, 37 262.34(a)(1)(i); 40 CFR 265.173(a); LAC 33:V.1109.E.1.a..i; LAC 33:V.2107.A At the time of this inspection the hatch for Compartment #3 was open when waste were not being added or removed. 2 Operation of a Hazardous Attachment 5 Waste Storage Unit Without a Permit - Barge CHEM94 2a Failure to label containers used for the storage of hazardous waste with the words 40 CFR 270.1 LAC 33:V.303.B 40 CFR 262.34(a)(3) LAC 33:V.1109.E.1.d Storage of hazardous waste in barge CHEM94 without meeting the permit exemption requirements There were no markings present to indicate that 12 "Hazardous Waste" 2b Failure to label containers used for the storage of hazardous waste with the date of accumulation of the waste 2c Unpermitted storage of a hazardous waste for a period greater than 90 days T. T. Barge Services, LLC. - Mile 237 FY2014 RCRA Compliance Inspection 40 CFR 262.34(a)(2) LAC 33:V.1109.E.1.c 40 CFR 262.34 LAC 33:V.1109.E.1 CHEM94 was in hazardous waste service There were no markings present to indicate when the accumulation of the hazardous waste stored in CHEM94 began According to statements made by facility representatives, the compartments of CHEM94 had not been rendered empty since 2010. 3 Operation of a Hazardous Attachment 5 Waste Storage Unit Without a Permit - Barge DM907 3a Failure to label containers used for the storage of hazardous waste with the words "Hazardous Waste" 3b Failure to label containers used for the storage of hazardous waste with the date of accumulation of the waste 3c Unpermitted storage of a hazardous waste for a period greater than 90 days 40 CFR 270.1 LAC 33:V.303.B 40 CFR 262.34(a)(3) LAC 33:V.1109.E.1.d 40 CFR 262.34(a)(2) LAC 33:V.1109.E.1.c 40 CFR 262.34 LAC 33:V.1109.E.1 Storage of hazardous waste in barge DM907 without meeting the permit exemption requirements There were no markings present to indicate that DM907 was in hazardous waste service There were no markings present to indicate when the accumulation of the hazardous waste stored in DM907 began According to statements made by facility representatives, the compartments of DM907 had not been rendered empty. 4 Failure to complete the hazardous waste manifest Attachment 6 Manifest #'s: 40 CFR 262.20(a)(1) Twelve hazardous LAC 33:V.1107.B waste manifests 13 006100601FLE 005795798JJK 005260342FLE 005803495JJK 005803477JJK 005803487JJK 005803478JJK 005803486JJK 005260350FLE 005803488JJK 005795843JJK 005795842JJK T. T. Barge Services, LLC. - Mile 237 FY2014 RCRA Compliance Inspection issued in 2013 for hazardous waste shipments designated for Lonestar Ecology in Pasadena, Texas were not completed by T. T. Barge Services prior to shipment 14