Document DM0R144nGgrOekv6bN5oaK0x5

f t E A ~ United States ..~ . Environmental Protection ~, Agency Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 6 Enforcement Division INSPECTION REPORT 3/25/2025 14:25 (CT) Announced: No 3/25/2025 15:05 (CT) Access: Granted RCRA Compliance Evaluation Inspection (CEI) 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 Seacraft Shipyard Corp. LA0000055590 3820 N Lake Palourde Rd. Amelia, LA 70340 St. Mary SQG 336612 Seacraft Shipyard Corp. (Seacraft) performs repairs and maintenance on marine vessels. 29.6781, -91.1015 Additional Persons Participating in Inspection: Name Title Organization John Penland Inspector EPA REGION 6 Erin Young-Dahl Inspector EPA REGION 6 Janosh Wolters Contractor Eastern Research Group (ERG) Email Penland.John@epa.gov Youngdahl.Erin@epa.gov Janosh.Wolters@erg.com Lead Inspector: Vince Damiano ERG Vincent Damiano Digitally signed by Vincent Damiano Date: 2025.05.01 16:44:01 -04'00' IVince.Damiano@erg.com Page 1 of 4 Seacraft Shipyard Corp SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection Inspection Date: 3/25/2025 The Port of Morgan City 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, port related facilities, and other records, including photographs taken (see Appendix 1), 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 Inspector/Enforcement Officer/EPA Region 6 RCRA Inspector/ Contractor/ERG Seacraft Shipyard/Manager Name Vince Damiano John Penland Erin Young-Dahl Janosh Wolters Marc Mireles Email Vince.Damiano@erg.com Penland.John@epa.gov Youngdahl.Erin@epa.gov Janosh.Wolters@erg.com Marc@seacraftshipyard.com Opening Conf. Yes Closing Conf. Yes Yes Yes Yes Yes Yes Yes Yes Yes Page 2 of 4 Seacraft Shipyard Corp Inspection Date: 3/25/2025 Facility General Description Tenant/Area Seacraft Shipyard Corp Inspection Date Process Description 3/25/25 Seacraft performs repairs and maintenance on marine vessels. The facility does not operate under a MARPOL COA. Area of Concern Yes SECTION II - OBSERVATIONS Facility: Seacraft Shipyard Corp Section: 2.1 Date: 3/25/25, 2:20 PM Contains AOC: Yes Contains CBI: No I I Lead Inspector: Vince Damiano Attendees: Marc Mireles (Manager) Seacraft Shipyard Co (Seacraft), located in Amelia, LA, conducts repairs and maintenance of marine vessels. The facility operates a dry dock and has travel lift capabilities for vessel repair projects. Seacraft rarely provides dockside services. Mr. Mireles stated that the primary waste stream generated at the facility is used oil, which results from routine maintenance on Seacraft's equipment. In cases where a vessel requires tank cleaning prior to maintenance, Seacraft contracts a third-party, National Marine Environmental, to perform the cleaning and manage the oily water generated during the process. Seacraft is registered with the EPA as a Small Quantity Generator (SQG) of hazardous waste under EPA ID LA0000055590. After the opening conference, the inspection team observed Seacraft's used oil storage area. The inspection team observed one half-full 5-gallon container and one full 5-gallon container storing used oil-contaminated PPE. Both containers were not labeled as containing used oil (see Appendix 1- Photos 1 and 2) [AOC #1 - Seacraft did not clearly label containers and aboveground tanks used to store used oil with the words "Used Oil" - 40 CFR 279.22(c)]. The inspection team also observed a 500-gallon used oil tank, which was approximately half-full and was not labeled (see Appendix 1 - Photo 3) [see AOC #1]. Next, the inspection team observed a full 55-gallon drum, which was unlabeled, and Seacraft representatives were not sure of the contents of the drum (see Appendix 1 - Photo 4) [AOC #2 - Seacraft did not make a hazardous waste determination. - 40 CFR 262.11]. In the same used oil storage area, the inspection team observed two full 55-gallon drums containing used oil that were not labeled properly (see Appendix - Photos 5, 6, and 12) [see AOC #1]. Three blue 55-gallon drums were found in the same area and were not labeled. Mr. Carpenter stated the drums were holding good engine oil being stored here for a customer (see Appendix 1 - Photos 7 to 9). An additional black 55-gallon drum was observed in the area labeled as "Coolant." However, Mr. Carpenter opened the drum to show the inspection team it contained a spill kit (see Appendix 1 - Photos 10 and 11). All AOCs observed by the inspection team at the time of the inspection are documented above. However, upon further review, EPA may change or add additional AOCs. A closing conference was conducted at approximately 3:00 PM with Seacraft personnel. The AOCs were communicated during the closing. SECTION III - RECORDS REVIEW No RCRA-regulated records were reviewed during this focused onsite inspection. Page 3 of 4 Seacraft Shipyard Corp Inspection Date: 3/25/2025 SECTION IV - AREAS OF CONCERN The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation. Facility: Seacraft Shipyard Corp AOC #1 - Seacraft did not clearly label containers and Citation: 40 CFR 279.22(c) aboveground tanks used to store used oil with the words "Used Oil." Section: 2.1 AOC #2 - Seacraft did not make a hazardous waste determination. Citation: 40 CFR 262.11 Section: 2.1 SECTION V - FOLLOW UP Any facility follow-up items are as discussed in Section II of this report. Documents or files provided by the facility were transmitted via email and included responses to AOCs or provision of documents requested. SECTION VI - LIST OF APPENDICES Appendix 1. Photograph Log Page 4 of 4 APPENDIX 1. PHOTOGRAPH LOG UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Seacraft Shipyard City: Amelia County/Parish: St. Mary I IState: Louisiana Photo No. 1 Photo File Name: DSCN7738 Date of Photo: 3/25/2025 Time of Photo: 1445 hrs. Photographer: Vince Damiano Description: View of a half-full 5-gallon container storing used oil-contaminated PPE that was unlabeled, observed in the used oil storage area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Seacraft Shipyard City: Amelia County/Parish: St. Mary I IState: Louisiana Photo No. 2 Photo File Name: DSCN7739 Date of Photo: 3/25/2025 Time of Photo: 1445 hrs. Photographer: Vince Damiano Description: View of a full 5-gallon container storing used oil-contaminated PPE that was unlabeled, observed in the used oil storage area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Seacraft Shipyard City: Amelia County/Parish: St. Mary I IState: Louisiana Photo No. 3 Photo File Name: DSCN7740 Date of Photo: 3/25/2025 Time of Photo: 1446 hrs. Photographer: Vince Damiano Description: View of a half-full 500-gallon used oil tank that was unlabeled, observed in the used oil storage area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Seacraft Shipyard City: Amelia County/Parish: St. Mary I IState: Louisiana Photo No. 4 Photo File Name: DSCN7741 Date of Photo: 3/25/2025 Time of Photo: 1448 hrs. Photographer: Vince Damiano Description: View of a full 55-gallon container storing undetermined material that was unlabeled, observed in the used oil storage area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Seacraft Shipyard City: Amelia County/Parish: St. Mary State: Louisiana Photo No. 5 Photo File Name: DSCN7742 Date of Photo: 3/25/2025 Time of Photo: 1448 hrs. Photographer: Vince Damiano Description: View of a full 55-gallon container storing used oil that was unlabeled, observed in the used oil storage area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Seacraft Shipyard City: Amelia County/Parish: St. Mary State: Louisiana Photo No. 6 Photo File Name: DSCN7743 Date of Photo: 3/25/2025 Time of Photo: 1448 hrs. Photographer: Vince Damiano Description: View of the original product label on the full 55-gallon container storing used oil that was unlabeled, observed in the used oil storage area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Seacraft Shipyard City: Amelia County/Parish: St. Mary State: Louisiana Photo No. 7 Photo File Name: DSCN7744 Date of Photo: 3/25/2025 Time of Photo: 1449 hrs. Photographer: Vince Damiano Description: View of two full 55-gallon drums in the used oil storage area holding unused engine oil. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Seacraft Shipyard City: Amelia County/Parish: St. Mary State: Louisiana Photo No. 8 Photo File Name: DSCN7745 Date of Photo: 3/25/2025 Time of Photo: 1449 hrs. Photographer: Vince Damiano Description: View of a full 55-gallon drum in the used oil storage area holding unused engine oil. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Seacraft Shipyard City: Amelia County/Parish: St. Mary State: Louisiana Q o 0/HU r~a Super Plus EC SAl: 15W-40 1>c:2.5JOQ5 I PK:981 I FD 08/30/202! ' B N 24002 I562 Photo No. 9 Photo File Name: DSCN7746 Date of Photo: 3/25/2025 Time of Photo: 1449hrs. Photographer: Vince Damiano Description: View of product label on full 55-gallon drums in the used oil storage area holding unused engine oil. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Seacraft Shipyard City: Amelia County/Parish: St. Mary State: Louisiana Photo No. 10 Photo File Name: DSCN7747 Date of Photo: 3/25/2025 Time of Photo: 1449 hrs. Photographer: Vince Damiano Description: View of a 55-gallon drum found in the used oil storage area with "Coolant" label that was determined to contain a spill kit. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Seacraft Shipyard City: Amelia County/Parish: St. Mary State: Louisiana '>2-t - L---::-f- CONTEN'[,S 1 C~""0", !- "' j ~ {,ft. f- 47< "' ~ : r Photo No. 11 Photo File Name: DSCN7748 Date of Photo: 3/25/2025 Time of Photo: 1449 hrs. Photographer: Vince Damiano Description: View of label on 55-gallon drum that was determined to contain a spill kit. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Seacraft Shipyard City: Amelia County/Parish: St. Mary State: Louisiana Photo No. 12 Photo File Name: DSCN7749 Date of Photo: 3/25/2025 Time of Photo: 1455 hrs. Photographer: Vince Damiano Description: View of a full 55-gallon container storing used oil that was unlabeled, observed in the used oil storage area.