Document 99N32Yq93pbQpgp11b7nJQzqD

f t E A ~ United States ..~ . Environmental Protection ~, Agency EPA REGION 6 Enforcement Division INSPECTION REPORT Inspection Entry 4/24/2025 1:30 PM (CT) Date/Time Inspection Exit Date/Time 4/24/2025 2:30 PM (CT) Regulatory Program Type of Inspection RCRA Compliance Evaluation Inspection (CEI) Announced: No (tenants and related facilities) 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 BWC New Orleans LLC LAD034426288 660 La Bauve Dr. Westwego, LA 70094 Jefferson Large Quantity Generator (LQG) 493190 BWC New Orleans LLC (BWC NOLA) is a bulk liquid storage terminal where barges, vessels, trucks, and railcars transport products in and out of the facility. 29.9135, -90.1400 Additional Persons Participating in Inspection: Name Title Organization Email Sandesh Thapa Inspector EPA REGION 6 Thapa.Sandesh@epa.gov Joseph Watson Contractor Eastern Research Joe.Watson@erg.com Group (ERG) Lead Inspector: Vince Damiano ERG Vincent Damiano u1911a11y s,gnea oy v,ncent Damiano Date: 2025.06.06 15:29:36 -04'00' Vince.Damiano@erg.com I Page 1 of 4 BWC New Orleans LLC Inspection Date: 4/24/2025 SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection The Port of New Orleans and surrounding facilities were selected for inspection based on a 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, portrelated facilities, and other records, including photographs taken, 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 RCRA Inspector/ Contractor/ERG HSEQ Manager/BWC Operations Manager/BWC Terminal Manager/BWC Name Vince Damiano Sandesh Thapa Joseph Watson Walter Pertuit Salvador Boudreaux Josh Carter Email Vince.Damiano@erg.com Thapa.Sandesh@epa.gov Joe.Watson@erg.com Wpertuit@bwcterminals.com Sboudreax@bwcterminals.com Jcarter@bwcterminals.com Opening Closing Conf. Conf. Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Page 2 of 4 BWC New Orleans LLC Inspection Date: 4/24/2025 Facility General Description Tenant/Area BWC New Orleans LLC Inspection Date 4/24/25 Process Description BWC NOLA is a bulk liquid storage terminal where barges, vessels, trucks, and railcars transport products in and out of the facility. The facility maintains a MARPOL Annex I and V COA. Area of Concern Yes SECTION II - OBSERVATIONS Facility: BWC New Orleans LLC Section: 2.1 Date: 4/24/25, 01:30 PM Contains AOC: Yes Contains CBI: No I I Lead Inspector: Vince Damiano Attendees: Walter Pertuit (HSEQ Manager), Josh Carter (Terminal Manager), and Salvador Boudreaux (Operations Manager) BWC NOLA is located in Westwego, LA, and operates as a bulk liquid storage terminal on the Mississippi River. The facility stores and handles products such as base oil, caustic soda, vegetable oils, and diethanolamine. BWC NOLA has 42 storage tanks ranging in capacity from 5,000 barrels to 100,000 barrels. BWC NOLA can load and unload products via trucks, railcars, and marine barges at its single dock berth. The facility also has a product drumming operation. The facility maintains a MARPOL Annex I and V COA. Tank cleaning and maintenance activities, such as painting, are conducted by third-party contractors who are responsible for managing any waste generated from those operations. According to Mr. Carter, no waste is allowed to be transferred across the dock space. BWC is registered with the EPA as a LQG of hazardous waste under EPA ID LAD034426288. After the opening conference, the inspection team observed BWC NOLA's hazardous waste central accumulation area and the dock space. In the hazardous waste central accumulation area, the inspection team observed two full 55-gallon drums labeled as glycerin flush, dated June 19, 2020 (see Appendix 1 - Photos 1 to 3). The facility representatives stated these drums were from a line flush and have been in the waste storage area for a long time. They believed the waste was non-hazardous waste, but were uncertain [AOC #1 - BWC NOLA did not make a waste determination - 40 CFR 262.11]. The inspection noted that there was no posted signage in the area or on the building indicating this was BWC NOLA's hazardous waste central accumulation area, and indicated it is a best management practice to indicate a hazardous waste storage area (see Appendix 1 - Photo 4) The inspection team then observed the dock space. No areas of concern (AOCs) were noted at the dock. 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 2:30 PM with BWC personnel. The AOCs were communicated during the closing. Following the inspection on 5/8/2025, Mr. Josh Carter sent a follow-up email in response to the AOCs observed during the inspection, including: Photos of the two drums of glycerin flush labeled as non-hazardous waste and a posted hazardous waste sign in the hazardous waste storage area (see Appendix 2). Page 3 of 4 BWC New Orleans LLC Inspection Date: 4/24/2025 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. Facility: BWC New Orleans LLC AOC #1 - BWC NOLA did not make a waste determination. Citation: 40 CFR 262.11 Section: 2.1 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. 5/8/25 BWC NOLA email - Mr. Josh Carter provided the inspection team with photos of corrections made towards AOCs observed. SECTION VI - LIST OF APPENDICES Appendix 1. Photograph Log Appendix 2. 5/8/2025 BWC NOLA Response Page 4 of 4 APPENDIX 1. PHOTOGRAPH LOG UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: BWC New Orleans LLC City: Westwego County/Parish: Jefferson State: Louisiana Photo No. 1 Photo File Name: DSCN7982 Date of Photo: 4/24/2025 Time of Photo: 1404 hrs. Photographer: Vince Damiano Description: View of two full 55-gallon drums of glycerin flush found in the hazardous waste central accumulation area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: BWC New Orleans LLC City: Westwego County/Parish: Jefferson State: Louisiana NE.S061~ L'<CE.Rl E. -- Photo No. 2 Photo File Name: DSCN7983 Date of Photo: 4/24/2025 Time of Photo: 1404 hrs. Photographer: Vince Damiano Description: View of label on one of the full 55-gallon drums of glycerin flush found in the hazardous waste central accumulation area building, dated 6/19/2020. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: BWC New Orleans LLC City: Westwego County/Parish: Jefferson State: Louisiana Photo No. 3 Photo File Name: DSCN7984 Date of Photo: 4/24/2025 Time of Photo: 1404 hrs. Photographer: Vince Damiano Description: View of label on one of the full 55-gallon drums of glycerin flush found in the hazardous waste central accumulation area, dated 6/19/2020. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: BWC New Orleans LLC City: Westwego County/Parish: Jefferson State: Louisiana Photo No. 4 Photo File Name: DSCN7985 Date of Photo: 4/24/2025 Time of Photo: 1408 hrs. Photographer: Vince Damiano Description: Overview of the hazardous waste central accumulation area with no signage. APPENDIX 2. 5/8/2025 BWC NOLA RESPONSE  Outlook RE: Follow-up from EPA Visit on 4/24/2025 (New Orleans) From Carter, Josh (Westwego) <jcarter@bwcterminals.com> Date Thu 5/8/2025 11 :34 AM To Vince Damiano <Vince.Damiano@erg.com>; wpartuit@bwcterminals.com <wpartuit@bwcterminals.com>; Boudreaux Jr, Salvador (Westwego) <sboudreaux@bwcterminals.com> Cc Joe Watson <Joe.Watson@erg.com>; Thapa, Sandesh <Thapa.Sandesh@epa.gov> @2 attachments (8 MB) IMG_5964Jpeg; IMG_5963Jpeg; CAUTION : Don't open links or attachments unless you recognize the sender and know they are safe. Hey Vince, Please see attached for the signage for the waste storage area and the two 55-gallon drums. Our LDEQ Al# is LA0073679. Thanks, Josh Carter Terminal Manager BWC Terminals LLC 660 La Bauve Dr Westwego, LA 70094 0: (504) 340-3000 (Ext 9213) I M: (504) 912-1183 jcarter@bwcterminals.com I www.BWCTerminals.com BWC Terminals (a)i BULK LIQUID STORAGE From: Vince Damiano <Vince.Damiano@erg.com> Sent: Thursday, April 24, 2025 6:18 PM To: wpartuit@bwcterminals.com; Boudreaux Jr, Salvador (Westwego) <sboudreaux@bwcterminals.com>; Carter, Josh (Westwego) <jcarter@bwcterminals.com> Cc: Joe Watson <Joe.Watson@erg.com>; Thapa, Sandesh <Thapa.Sandesh@epa .gov> Subject: Follow-up from EPA Visit on 4/24/2025 (New Orleans) Some people who received this message don't often get email from vince.damiano@gg.com. Learn whY. this is imP.ortant *** External Email *** Hello, I am following up with a list of items and notes from our inspection today. Below are initial Areas of Concern and items requested; you may follow up with pictures, write-ups, sample results, or however you see fit: Waste determinations on the two 55-gallon drums in the waste storage area Posted a sign of the Waste Storage Area LDEQAI # Again, thank you for taking the time out of your day to meet with us. Please let us know if you have any questions or concerns. Thanks, Vince ERG Vince Damiano Chemical Engineer, Chantilly Office Cell: (703) 835-6281 Vince.Damiano@fil9.:Q!!l