Document BM59530906BJQYGjqaNr2X2w

f t E A ~ United States ..~ . Environmental Protection ~, Agency EPA REGION 6 Enforcement Division INSPECTION REPORT Inspection Entry 4/23/2025 11:50 AM (CT) Date/Time Inspection Exit Date/Time 4/23/2025 12:57 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 Cooper Consolidated LLC N/A 5619 665-LA-628 Laplace, LA 70068 St. John the Baptist N/A 488320 Cooper Consolidated LLC (CC) operates as a stevedore on the Mississippi River, loading and unloading customer barges. 30.049879, -90.475624 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 Digitally signed by Vincent Damiano Damiano - Date: 2025.06.11 13:42:02 -04'00' Vince.Damiano@erg.com I Page 1 of 5 Cooper Consolidated LLC Inspection Date: 4/23/2025 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 Safety Coordinator/CC Loss Control/CC Environmental Director Name Email Vince Damiano Vince.Damiano@erg.com Sandesh Thapa Thapa.Sandesh@epa.gov Joseph Watson Joe.Watson@erg.com Shaun Harris Shaun.Harris@coopercons0 lidated.com Byron Borne Byron.Borne@coopercons0 lidated.com Blaine Petite Blain.petite@coopercons0 lidated.com Opening Closing Conf. Conf. Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Page 2 of 5 Cooper Consolidated LLC Inspection Date: 4/23/2025 Facility General Description Tenant/Area Cooper Consolidated LLC Inspection Date Process Description 4/23/25 CC operates as a stevedore on the Mississippi River, loading and unloading customer barges. The facility does not maintain a MARPOL COA. Area of Concern Yes SECTION II - OBSERVATIONS Facility: Cooper Consolidated LLC Section: 2.1 Date: 4/23/25, 11:50 AM Contains AOC: Yes Contains CBI: No I I Lead Inspector: Vince Damiano Attendees: Chad Paradee (Manager) and Andrew Mancuso (Engineering) CC, also known as Laplace Stevedore Warehouse, is located in Laplace, LA and provides stevedoring services on the Mississippi River. CC handles scrap metal, fertilizer, grains, iron, break bulk, and bundles of steel. It has three dockside cranes used to move products either from ship to barge or barge to ship, which belong to customers. Facility representatives stated that materials are never brought into the CC facility itself. All unloading and loading operations are done on the water. Mr. Petite stated that no waste, except for scrap dunnage, is ever brought back to the facility from any marine vessels. CC generates used oil from slops on their tugboats in addition to universal waste, such as batteries and aerosol cans. CC is not registered with the EPA as a hazardous waste generator. After the opening conference, the inspection team observed CC's used oil storage area, universal waste warehouse, and the dock space. The used oil storage area consisted of 22 full 55-gallon drums of used oil filters and rags, one 500-gallon tank of used oil, and four full 55-gallon drums of used oil contaminated solids. All containers were labeled as "used oil", however, the inspection team noted that one of the 55-gallon drums storing used oil was damaged and capped off with rags (see Appendix 1 - Photo 1) [AOC #1 - CC was storing used oil in a container that had visible structural damage - 40 CFR 279.22(b)(1)]. Next, the inspection team observed the warehouse where universal waste and aerosol can waste were stored. The inspection team observed a bundle of universal waste lamps stored on a shelf that were not labeled, were not stored in a container to prevent damage, and did not contain an accumulation start date to indicate residence time (see Appendix 1 - Photo 2) [AOC #2 - CC did not label a container or package in which lamps with one of the following phrases: "Universal Waste--Lamp(s)," or "Waste Lamp(s)," or "Used Lamp(s)" - 40 CFR 273.14(e)]; [AOC #3 - CC did not store universal waste lamps in a closed container that prevents damage or cause releases under reasonably foreseeable conditions - 40 CFR 273.13(d)(1)]; and accumulating [AOC #4 - CC did not demonstrate the length of time that the universal waste has been accumulated from the date it becomes waste - 40 CFR 273.15(c)]. The inspection team then observed the aerosol can puncturing system, which consisted of a can puncture unit affixed to the top of a 55-gallon drum used to collect the residual aerosol waste. The plastic bag, which was collecting the unpunctured aerosol cans, was stationed next to the drum (see Appendix 1 - Photo 3). The drum collecting the aerosol residual waste was not labeled; however, after the inspection, Mr. Petite stated the facility is a very small quantity generator of hazardous waste, therefore, no labeling requirements are required on the drum. The punctured aerosol cans are managed as scrap metal and sent for recycling. The Page 3 of 5 Cooper Consolidated LLC Inspection Date: 4/23/2025 inspection team then observed the dock space and noted no areas of concern (AOCs) in the area. 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 12:57 PM with CC personnel. The AOCs were communicated during the closing. Following the inspection on 4/30/2025, Mr. Petite sent a follow-up email in response to the AOCs observed during the inspection, including: Photos of universal waste lamps stored in a closed box with a label and a start date The used oil from the damaged drum was pumped out and moved into an undamaged drum. A photo of a labeled universal waste - aerosol can container for unpunctured aerosol cans A photo of a hazardous waste label on the aerosol can puncturing drum and a statement that CC is a VSQG under 40 CFR 262.10-14. See the full response in Appendix 2. 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: Cooper Consolidated LLC AOC #1 - CC was storing used oil in a container that had visible structural damage. Citation: 40 CFR 279.22(b)(1) Section: 2.1 AOC #2 - CC did not label a container or package in which lamps with one of the following phrases: "Universal Waste--Lamp(s)," or "Waste Lamp(s)," or "Used Lamp(s)." AOC #3 - CC did not store universal waste lamps in a closed container that prevents damage or cause releases under reasonably foreseeable conditions. AOC #4 - CC did not demonstrate the length of time that the universal waste has been accumulated from the date it becomes waste. Citation: 40 CFR 273.14(e) Citation: 40 CFR 273.13(d)(1) Citation: 40 CFR 273.15(c) Section: 2.1 Section: 2.1 Section: 2.1 Page 4 of 5 Cooper Consolidated LLC SECTION V - FOLLOW UP Inspection Date: 4/23/2025 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. 4/30/25 Cooper Consolidated email - Mr. Petite provided the inspection team with photos and explanations of corrections made towards AOCs observed. SECTION VI - LIST OF APPENDICES Appendix 1. Photograph Log Appendix 2. 4/30/25 Response from Cooper Consolidated Page 5 of 5 APPENDIX 1. PHOTOGRAPH LOG UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Cooper Consolidated LLC City: Laplace County/Parish: St. John the Baptist State: Louisiana Photo No. 1 Photo File Name: DSCN7971 Date of Photo: 4/23/2025 Time of Photo: 1228 hrs. Photographer: Vince Damiano Description: View of a full 55-gallon drum containing used oil that had visible structural damage inside the used oil storage area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Cooper Consolidated LLC City: Laplace County/Parish: St. John the Baptist State: Louisiana Photo No. 2 Photo File Name: DSCN7972 Date of Photo: 4/23/2025 Time of Photo: 1230 hrs. Photographer: Vince Damiano Description: View of universal waste lamps stored on a shelf with no container or label inside the warehouse. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Cooper Consolidated LLC City: Laplace County/Parish: St. John the Baptist State: Louisiana I I Photo No. 3 Photo File Name: DSCN7973 Date of Photo: 3/23/2025 Time of Photo: 1233 hrs. Photographer: Vince Damiano Description: View of the aerosol can puncturing system and plastic bag accumulating unpunctured aerosol cans inside the warehouse. APPENDIX 2. 4/30/25 RESPONSE FROM COOPER CONSOLIDATED Laplace Stevedore Warehouse EPA Site Inspection Follow Up After action report, reported inspection deficiencies and remedies involved 4/28/25 Used Lamps, Universal Waste, No Label, Improperly Stored Photo taken the afternoon of inspection, boxed and ready for transport to off-site accumulation point Lamps transported next day and placed at accumulation site where they will stay until enough used lamps are collected to contact LEI, Inc., our universal waste vendor. LEI last picked up used lamps and Ewaste on 4/17/25 from our accumulation site. Manifest available upon request. Damaged Used Oil Drum Damaged drum pumped into an undamaged drum and damaged drum removed by warehouse personnel. The empty drum was sent to Darrow Maintenance facility and triple rinsed in a permitted wash bay equipped with oil/water separator. Empty, clean drum was crushed and sent out as scrap metal. Non-hazardous waste drums were collected by Mike's Filter, our non-haz waste vendor, on Friday, April 25th. Aerosol Puncture Device Area and Retention Drum A receptacle was added for accumulated but not yet punctured aerosol cans. Labels were applied to both the empty aerosol receptacle and also the residual waste drum connected to the puncture device. The Laplace stevedore warehouse punctures less than (30) aerosol paint cans during its peak month. This is the only waste generated that can be considered hazardous in nature and it is an extremely small amount of residual waste. It puts this location well under the threshold and should be considered a Very Small Quantity Generator (40 CFR 262.10-14). Therefore, we do not have an EPA ID for this warehouse. We have not generated enough waste in the drum since the addition of the puncture device so there are no hazardous waste manifests generated for this site. I've also included the factory instructions for the proper use of the puncture device which are on-site. All warehouse personnel and supervision are trained in it's proper use through both practical and written training. rdf1X Operation Guide r:;-1 lnstan Plunger in Lid l.=J ""~.,.. ...... ......- ...,0....,,....1,....,..6'1. . r ; l Insert Can(s) Into Unit ~ IA'\IW ~~.woo,o...,.oa_.... ~"-""----IWOIUU,. Ai e.o, J(JOIUKWffil c~o,,rtGfOl,M itAIMJ'SOl,l,H;l,'Y Mt4S-VD -~~~ ~ Puntture can L!J "..... W\ljlt.UMl...-~CII-..U..C-"J...,.._._~~t!:!"149!1i, ~--wt.twl~ 1~706 WwwdllWlliiJ>e,<oftl  Outlook RE: Follow-up from EPA Visit on 4/23/2025 From Petite, Blaine <Blaine.Petite@cooperconsolidated.com> Date Wed 4/30/2025 10:23 AM To Vince Damiano <Vince.Damiano@erg.com>; Borne, Byron <Byron.Borne@cooperconsolidated.com>; Harris, Shaun <Shaun.Harris@cooperconsolidated.com> Cc Joe Watson <Joe.Watson@erg.com>; Thapa, Sandesh <Thapa.Sandesh@epa.gov>; Day, Mark < Mark.Day@cooperconsolidated.com > @1 attachment (2 MB) EPA Inspection Follow Up 4.29.25.docx; CAUTION : Don't open links or attachments unless you recognize the sender and know they are safe. Good morning, Please see attached response with corrections and explanations for deficiencies found during the inspection of the Laplace Stevedore Warehouse on 4/23/25. The Laplace stevedore warehouse punctures less than (30) aerosol paint cans during its peak month. This is the only waste generated that can be considered hazardous in nature and it is an extremely small amount of residual waste. It puts this location well under the threshold and should be considered a Very Small Quantity Generator (40 CFR 262.10-14). Therefore, we do not have an EPA ID for this warehouse. Please let me know if you need more information . Thanks, From: Vince Damiano <Vince.Damiano@erg.com> Sent: Wednesday, April 23, 2025 4:36 PM To: Petite, Blaine <Blaine.Petite@cooperconsolidated.com>; Borne, Byron <Byron .Borne@cooperconsolidated .com>; Harris, Shaun <Shaun .Harris@cooperconsolidated.com> Cc: Joe Watson <Joe.Watson@erg.com>; Thapa, Sandesh <Thapa.Sandesh@epa .gov> Subject: Follow-up from EPA Visit on 4/23/2025 EXTERNAL EMAIL: Please use caution when clicking links or downloading files. [CTS Postmaster) Hello All, 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: A 55-gallon drum of used oil that was damaged Universal waste light bulbs not in a container, unlabeled, and non-dated  55-gallon drum of aerosol can residual waste not labeled Follow up on EPA ID 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 This message, including any attachments, is for the use of the intended recipient and may contain privileged and confidential information of this Company or its affiliates. If the reader of this message is not the intended recipient, or the employee or agent responsible to deliver it to the intended recipient, you are strictly prohibited from reviewing, forwarding, printing, copying, distributing or using this information in any way, and are hereby requested to contact the sender by reply email and destroy all copies of the original message.