Document 8DM6bao4mOkGOKz2eDd7RjEK

RCRA Inspection Report 1) Inspector and Author of Report Laurie Benton DiGaetano Environmental Engineer Phone: 404-562-8948 benton-digaetano.laurie@epa.gov U.S. Environmental Protection Agency, Region 4 Enforcement and Compliance Assurance Division Chemical Safety and Land Enforcement Branch RCRA Enforcement Section 61 Forsyth Street, S.W. Atlanta, Georgia 30303 2) Facility Information US Coast Guard Base Fort Macon 2301 East Fort Macon Road Atlantic Beach, North Carolina 28512 EPA ID#: NC5690308262 NAICS #: 926120 - Regulation and Administration of Transportation Programs 3) Responsible Officials Todd M. Ogle Environmental Protection Specialist todd.m.ogle@uscg.mil 4) Inspection Participants Todd M. Ogle, USCG Fort Macon Eric Bechtel, USCG Fort Macon Wes Hare, NCDEQ Laurie Benton DiGaetano, USEPA 5) Date and Time of Inspection June 12, 2024, at 9:15 AM 6) Applicable Regulations1 Resource Conservation and Recovery Act (RCRA) Sections 3002 (42 U.S. Code - Annotated U.S.C.A. 6925 and 6927), and 40 Code of Federal Regulation (C.F.R.) Parts 260 - 270, 273, 278, & 279; and The North Carolina Solid Waste Management Law, N.C.G.S. 130A-17 to-28 and 130A-290to -310.22, and North Carolina Hazardous Waste Management Rules, 15A NCAC 13A .0101 to .0119. Pursuant to 15A NCAC 13A .0102(b) [40 C.F.R. 260.10], a small quantity generator of hazardous waste (LQG) is a generator who generates greater than 100 kilograms (220 pounds) 1 As the State's authorized hazardous waste program operates in lieu of the federal RCRA program, the citations of those authorized provisions will be to the authorized State program. However, for ease of reference, the federal citations will follow in brackets. but less than 1,000 kilograms (2,200 pounds) of non-acute hazardous waste in a calendar month. Pursuant to 15A NCAC 13A .0119(a) [40 C.F.R. 273.9], a small quantity handler of universal waste (SQHUW) is a universal waste handler who does not accumulate 5,000 kilograms or more of universal waste (batteries, pesticides, mercury-containing equipment, lamps, or aerosol cans, calculated collectively) at any time. Pursuant to 15A NCAC 13A .0107(a) [40 C.F.R. 262.16], an SQG may accumulate hazardous waste on-site for 180 days or less without a permit or without having interim status, as required by Sections 130A-294(c) and (g) of the NCSWML, N.C.G.S. 130A-294(c) to (g) [Section 3005 of RCRA, 42 U.S.C. 6925], provided that the generator complies with the conditions listed in 15A NCAC 13A .0107(a) [40 C.F.R. 262.16] (hereinafter referred to as the "SQG Permit Exemption"). Pursuant to 15A NCAC 13A .0107(a) [40 C.F.R. 262.15(a)], a generator may accumulate as much as 55 gallons of non-acute hazardous waste in containers at or near any point of generation where wastes initially accumulate, which is under the control of the operator of the process generating the waste, without a permit or without having interim status, as required by Sections 130A-294(c) and (g) of the NCSWML, N.C.G.S. 130A-294(c) to (g) [Section 3005 of RCRA, 42 U.S.C. 6925], and without complying with 15A NCAC 13A .0107(a) [40 C.F.R. 262.16(b) or 262.17(a)], except as required in 15A NCAC 13A .0107(a) [40 C.F.R. 262.15(a)(7) and (8)], provided that the generator complies with the satellite accumulation area conditions listed in 15A NCAC 13A .0107(a) [40 C.F.R. 262.15] (hereinafter referred to as the "SAA Permit Exemption"). 7) Purpose of Inspection The purpose of this inspection was to conduct an unannounced compliance evaluation inspection to determine United States Coast Guard (USCG) Base Fort Macon compliance with the applicable requirements of RCRA and the corresponding North Carolina regulations. This was an EPA lead inspection. 8) Facility Description The USCG Base Fort Macon is the USCG Atlantic Area's field office for fulfilling the Sector North Carolina's primary operational missions of the USCG from the North Carolina/South Carolina border to Hobucken, North Carolina. The primary operational missions of the USCG include Search and Rescue, Marine Safety, Ports and Waterways Coastal Security, Marine Environmental Protection, Aids to Navigation (ANT), Maritime Law Enforcement, and Recreational Boating Safety. USCG Base Fort Macon is a 22.6-acre base that is host to six other commands: Group Fort Macon Office, ANT Fort Macon, Coast Guard Cutter (CGC) Primrose, CGC Conifer, CGC Chilula, and Reserve Base Fort Macon. Together, these commands are responsible for maintaining a constant ready status to aid the mariner in distress, keep the various navigational markers in working order, and enforce federal laws such as boating safety and drug interdiction. The base employs over 300 individuals, including active duty and civilian personnel. EPA-RCRA CEI Report June 12, 2024 Page 2 of 7 US Coast Guard Fort Macon EPA ID# NC5690308262 Five ships are moored at USCG Base Fort Macon, including: a 205-foot medium endurance cutter, CGC Chilula; a 180-foot buoy tender, CGC Conifer; a 100-foot construction tender, CGC Primrose; and a 55-foot boat, ANT Fort Macon. The CGC Chilula is a law enforcement vessel that also stands ready to assist vessels in distress. The CGC Conifer is primarily used to maintain and correct navigation discrepancies with large navigation buoys. The CGC Primrose works with small inland buoys, and constructs day beacons, ranges, and other aids to navigation. The bow of the CGC Primrose is equipped with a pile driver, which is used to install pilings when they are necessary during construction activities. The ANT Fort Macon is used to set up temporary aids while others are being replaced, and to perform routine maintenance on navigational aids, such as replacing batteries on the day beacons. In order to carry out the primary missions of the USCG, Base Fort Macon performs a number of various support activities onsite. Although the large tenant ships are sent off-site for maintenance and repair activities, boats up to 55-foot long can be removed from the water at USCG Base Fort Macon and serviced on-site by the Industrial Section. Maintenance activities may include pressure washing growth from the bottom of the vessel, removing shafts and props for service and repair, electronic support for radio and navigation systems, and touch up painting. The base does not have any paint booths on-site, and although small blast units are used on-site for cleaning and servicing parts, no large-scale stripping or blasting activities occur at the facility. The USCG Base Fort Macon operated as a large quantity generator (LQG) of hazardous waste until April 14, 1997, when the facility first notified as a small quantity generator (SQG) of hazardous waste. The base has operated as an SQG for the past twenty-seven years, and most recently re-notified as an SQG on August 26, 2021. In this notification, the USCG Base Fort Macon indicated that the EPA waste codes associated with hazardous waste generated onsite include: D001 (ignitable), D002 (corrosive), D005 (barium), D006 (cadmium), D008 (lead), D009 (mercury), D018 (benzene), D035 (methyl ethyl ketone), F003 (certain spent non-halogenated solvents), and F005 (certain spent nonhalogenated solvents). Manifest records indicate that hazardous waste shipped offsite include waste paint related material, waste solids containing lead, waste aerosols, waste corrosive liquids (acidic and alkaline), and waste flammable liquids. The USCG Base Fort Macon manages one designated satellite accumulation area (SAA) for managing lead contaminated wastes generated in the on-site armory as hazardous waste solids containing lead. All other hazardous wastes are promptly managed in the designated hazardous waste central accumulation area (CAA) when they are generated. 9) Previous Inspection History On June 19, 2006, the North Carolina Department of Environmental Quality (NCDEQ) conducted the most recent RCRA CEI at the subject facility and found no apparent violations of RCRA's requirements. 10) Opening Conference On June 12, 2024, EPA inspector Laurie Benton DiGaetano, accompanied by NCDEQ inspector Wes Hare, arrived at the USCG Base Fort Macon at approximately 9:15 AM. After receiving EPA-RCRA CEI Report June 12, 2024 Page 3 of 7 US Coast Guard Fort Macon EPA ID# NC5690308262 permission for entry from the guard on duty, the inspectors phoned Todd Ogle, Environmental Protection Specialist, and waited for an escort to the operational area of the base. Todd Ogle and Eric Bechtel, Engineer Officer, received the inspectors and participated in an opening conference. The inspectors introduced themselves, showed their credentials to Todd Ogle, and explained the purpose of the visit. The inspectors described the anticipated use of equipment (digital camera) during the inspection and provided a request for records. The Small Business Regulatory Enforcement Fairness Act's classification of a "small business" is generally set by the Small Business Administration using the business' SIC/NAICS code and annual receipts or number of employees. A copy of the EPA's information sheet for small businesses can be found at https://www.epa.gov/sites/production/files/2017-06/documents/smallbusinessinfo.pdf. The EPA inspector discussed the company's ability, pursuant to 40 C.F.R. 2.203, to assert a business confidentiality claim for information submitted to EPA. The base did not assert a business confidentiality claim. Todd Ogle and Eric Bechtel provided an overview of the facility's history and current operations during the opening conference. The inspection participants also discussed health and safety protocols and required personal protective equipment before Todd Ogle and Eric Bechtel led the inspectors on a tour of the Facility operations. 11) Inspection Observations Hazardous Waste CAA: The USCG Base Fort Macon manages a hazardous waste CAA in a locked caged area within the HazMat Building (Photo 1). Containers were arranged within the caged area in parallel rows running from the entrance of the caged area to the far wall. Containers of hazardous waste were staged up on the right side of the area and containers of nonhazardous waste were staged on the left side. The CAA was equipped with a fire alarm system; with an emergency telephone (Photo 2); with portable fire extinguishers; with spill control equipment; with a list of emergency telephone numbers; and with an evacuation route map. The inspectors observed the following containers within the caged CAA: Size 5-gallon 5-gallon Container Number HW-025 HW-016 5-gallon HW-024 5-gallon HW-014 30-gallon FMHW-017 5-gallon HW-011 Label Hazardous Waste unused CBC cable clean rd Hazardous Waste sodium hydroxide Hazardous Waste unused water solvent solder flux Hazardous Waste glaze coat epoxy hardener Hazardous Waste lime away Hazardous Waste polysiloxane Indication of Hazards Toxic Corrosive Corrosive Corrosive Corrosive Flammable liquid Date May 14, 2024 April 4, 2024 May 14, 2024 March 22, 2024 April 8, 2024 March 18, 2024 EPA-RCRA CEI Report June 12, 2024 Page 4 of 7 US Coast Guard Fort Macon EPA ID# NC5690308262 30-gallon 55-gallon 55-gallon 55-gallon 30-gallon 30-gallon FM-0349 HW-021 HW-020 Gasoline from small boat for reuse RCRA fuel exempt waste gasoline Hazardous Waste paint related material sludge Hazardous Waste paint related material sludge Universal Waste aerosol cans Universal Waste aerosol cans Flammable liquid Flammable liquid Flammable liquid Flammable liquid Flammable gas May 3, 2022 April 22, 2024 April 22, 2024 March 26, 2024 April 26, 2024 5-gallon Empty 5-gallon Universal Waste used aerosols November 16, 2023 15-gallon FMHW-008 Hazardous Waste broken lamps DOT Class 9 Toxic February 28, 2024 55-gallon 55-gallon 10-gallon 5-gallon 5-gallon HW-019 HW-010 HW-015 Hazardous Waste paint related material sludge Hazardous Waste paint related material sludge Hazardous Waste epoxy Hazardous Waste methyl ethyl ketone Hazardous Waste carpet spotter and isopropanol Flammable liquid Flammable liquid Flammable liquid Flammable liquid Flammable liquid April 22, 2024 May 13, 2024 April 3, 2024 March 6, 2024 April 3, 2024 The inspectors also observed one 55-gallon container for accumulating used oil (Photo 3). The container was equipped with a lid used to contain used oil filters as their contents drain through a metal grate and into the accumulation container. The lid was closed, and the 55gallon container was labeled with the words "used oil". Additional Universal Waste Storage: The USCG Base Fort Macon accumulates universal waste batteries on a pallet that is equipped with a covered lid (Photos 4). As designed and operated, the covered pallet appears to meet the definition of a container, a portable device used to store universal waste. The inspectors observed that the covered pallet was closed and in good condition, and it was labeled with the words "universal waste batteries" (Photo 5). Armory SAA: The USCG Base Fort Macon manages a SAA in the Armory for managing hazardous waste debris that is generated by cleaning weapons. The inspectors observed one 5-gallon container in this SAA. The container was closed, labeled hazardous waste weapons cleaning debris with lead, and marked with an indication that the contents are toxic. EPA-RCRA CEI Report June 12, 2024 Page 5 of 7 US Coast Guard Fort Macon EPA ID# NC5690308262 Used Oil Containers: The inspectors observed four 500-gallon and two 360-gallon containers used to manage oily water (bilge water) and used oil. When necessary, these containers are moved to the boat dock to accumulate oily water or used oil that is generated on boats at the dock. The oily water or used oil is pumped from the boat(s) into the portable container, and the container is returned to the used oil storage area where the oily water and used oil is stored until it is pumped into a tanker truck for off-site transport. The inspectors observed three 500-gallon containers and one 360-gallon container labeled "oily water" and one 500-gallon container and one 360-gallon container labeled "used oil" in the oil storage area. 12) Records Review Emergency Procedures: Facility personnel explained that the Officer of the Day (OD) is available to respond to an emergency, and the gate shack is manned daily to assist in a response until 5:00 PM. The facility has a memorandum of understanding with the Atlantic Beach Fire Department, and arrangements for response from the Atlantic Beach Police Department if they are called. The USCG Base Fort Macon has a small medical facility for providing first aid services and has arrangements for 911 ambulance service to Carteret General Hospital. Waste Manifest and Land Disposal Restriction (LDR) Records: The inspectors reviewed available hazardous waste manifest records and land disposal restriction forms for shipments of hazardous waste sent since June 2021. Weekly Inspection Records: The inspectors reviewed available records of inspections of the hazardous waste CAA since January 4, 2023. The inspection log includes a four-part checklist to record observations about the CAA, the nonhazardous waste tank area, the fuel farms, and the SAA. The CAA portion of the log includes a checklist to record observations concerning the area security (locks), fire extinguisher, warning signs, eye wash station, secondary containment, condition of containers, closure of containers, container labels, container dates, age of containers (<180 days), compatibility of wastes, total volume of waste (<13,000 pounds), closure of universal waste containers, and age of universal waste containers (<1 year). The form identifies Todd M. Ogle, Environmental Specialist, as the person conducting the inspection, and it includes a space for Todd Ogle to record the date of the inspection and his initials. The form also includes a space to record the name and signature of an alternate inspector and a space for that alternate inspector to record the date that he or she conducts the inspection. 13) Closing Conference The inspectors conducted the exit meeting at 12:00 PM with Todd Ogle and Eric Bechtel. During this meeting, the inspectors stated their preliminary conclusions of the inspection. EPA-RCRA CEI Report June 12, 2024 Page 6 of 7 US Coast Guard Fort Macon EPA ID# NC5690308262 14) List of Attachments Attachment 1 - Photo Log 15) Signed LAURIE Digitally signed by LAURIE DIGAETANO DIGAETANO Date: 2024.07.23 11:49:52 -04'00' Laurie Benton DiGaetano Environmental Engineer 16) Concurrence ALAN Digitally signed by ALAN NEWMAN NEWMAN 11:37:35 -04'00' Date: 2024.07.24 Alan R. Newman Acting Chief RCRA Enforcement Section EPA-RCRA CEI Report June 12, 2024 Page 7 of 7 US Coast Guard Fort Macon EPA ID# NC5690308262 Attachment 1 - Photo Log Five Photos taken on: June 12, 2024 Photos taken by: Laurie Benton DiGaetano Photos taken with: Panasonic DMC TS-5 EPA Property Tag: S09533 Photo 1: Hazardous waste CAA inside a locked caged area within the HazMat Building. Photo 2: Emergency telephone at the CAA. Photo 3: 55-gallon container for accumulating used oil next to the CAA. EPA-RCRA CEI Report June 12, 2024 Attachment 1 - Page 2 of 3 US Coast Guard Fort Macon EPA ID# NC5690308262 Photo 4: Universal waste batteries on a pallet that is equipped with a cover and lid. Photo 5: Closed container labeled universal waste batteries. EPA-RCRA CEI Report June 12, 2024 Attachment 1 - Page 3 of 3 US Coast Guard Fort Macon EPA ID# NC5690308262