Document EQ577vj28vE2BVr16Vr1qwJL
Inspection Entry Date/Time Inspection Exit Date/Time
Regulatory Program Type of Inspection
EPA REGION 6 Enforcement Division
INSPECTION REPORT
07/15/2024 11:00 AM (CT)
Announced: No
07/15/2024 12:30 PM (CT)
Access: Granted
RCRA Focused Compliance Inspection (FCI)
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
Belle Chasse Marine Transportation Services N/A 301 Alabo St. New Orleans, LA 70117 Orleans Parish N/A 483212 Belle Chasse Marine Transportation Services (BCMT) operates as a service station for vessels, crews, and pilots. 29.9515, -90.01474
Additional Persons Participating in Inspection:
Name
Title
Organization
Dedriel Gardner
Inspector
EPA REGION 6
Joe Watson
Contractor
Eastern Research Group (ERG)
Email Gardner.Dedriel@epa.gov Joe.Watson@erg.com
Phone (281) 983-2133 (215) 891-6615
Lead Inspector: Vince Damiano
Vincent Damiano
ERG
Digitally signed by Vincent Damiano Date: 2024.10.03 10:13:12 -04'00'
Vince.Damiano@erg.com
(703) 835-6281
Page 1 of 4
Belle Chase Marine Transportation Services
Inspection Date: 07/15/2024
SECTION I - INTRODUCTION
Site Entry and Purpose of the Inspection
The Port of New Orleans and surrounding facilities were selected for inspection based on an Environmental Justice and 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, and 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 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 RCRA Inspector/ Contractor/ERG Inspector/Enforcement Officer/EPA Region 6
Name Vince Damiano
Phone
Email
(703) 835-6281 Vince.Damiano@erg.com
Opening Conf.
Yes
Closing Conf.
Yes
Joe Watson
(215) 891-6615 Joe.Watson@erg.com Yes
Yes
Dedriel Gardner (281) 983-2133 Gardner.Dedriel@epa.gov Yes
Yes
Facility General Description
Tenant/Area Belle Chasse Marine Transportation
Inspection Date
07/15/24
Process Description Belle Chasse Marine Transportation Services (BCMT) is a tenant of Port of New Orleans and operates as a service station for vessel crews and pilots. BCMT transports pilots and crews to and from the vessels the pilots are working on while supplying food, spare parts, and other supplies the vessels may need. BCMT is covered under the Port of New Orleans' MARPOL COA.
Area of Concern
Yes
Page 2 of 4
Belle Chase Marine Transportation Services SECTION II - OBSERVATIONS
Inspection Date: 07/15/2024
Tenant: Belle Chasse Marine Transportation Services
Section: 2.1
Date: 07/15/24, 11:00 AM Contains AOC: Yes
Lead Inspector: Vince Damiano Attendees: Frank Hannan (Manager)
Contains CBI: No
BCMT is a tenant of Port of New Orleans and operates as a launch service station for vessel crews and pilots. BCMT transports pilots and crews to and from their vessels in addition to supplying food, spare parts, and other supplies the vessels may need. BCMT has three vessels in their fleet in this region they use for transportation. BCMT is covered under Port of New Orleans MARPOL COA, but Mr. Hannan stated BCMT has not landed any waste, used oil, or slops from vessels through their operations. BCMT is not registered with EPA because they do not generate or transport any RCRA-regulated waste.
Mr. Hannan explained most of the waste generated on site is from maintenance of their vessels such as bilge water mixed with used oil or radiator coolant. Following the opening conference, the inspection team took a visual inspection of BCMT's yard space where drums and totes were stored. The inspection team first observed four 275-gallon totes and fifteen 55-gallon drums containing used oil or oily water, all ranging from full to completely full (see Appendix 1 - Photos 1 to 7). All 19 containers were unlabeled [AOC #1 - BCMT did not clearly label containers used to store used oil with the words "Used Oil" - 40 CFR 279.22(c)(1)]. Two of the drums, seen in Appendix 1 - Photos 2 and 5, appeared rusted and in poor condition [AOC #2: BCMT was storing used oil in containers that were in poor condition - 40 CFR 279.22(b)(1)].
Next, the inspection team moved to the storage area near BCMT's maintenance shop where the inspection team observed nine 275- to 300-gallon totes (see Appendix 1 - Photos 8 to 11). Three of the totes were empty, while the other six ranged from 1/3 full to completely full filled with material Mr. Hannan was not able to identify at the time of the inspection. One of the totes had a broken top (see Appendix 1 - Photo 11). Mr. Hannan stated most of the totes were products intended for transport out to a vessel, but the customer never picked them up. The inspection team also observed fourteen 55-gallon drums and one 5-gallon container next to the totes that were all full at the time of the inspection (see Appendix 1 - Photo 12 to 16). Mr. Hannan was unsure of the contents of the drums and totes but suspected some of them contained coolant or engine oil. The inspection team requested a waste determination on all containers observed [AOC #3 - BCMT did not make a hazardous waste determination. - 40 CFR 262.11].
Following the visual inspection, the inspection team conducted a closing conference at approximately 12:30 PM with BCMT personnel. The AOCs were communicated during the closing; however, further EPA review may change or add to their potential AOCs. Following the inspection, Mr. Hannan provided several emails responding to the AOCs found during the inspection (see Appendices 2, 3, and 4).
SECTION III - RECORDS REVIEW No RCRA-regulated records were reviewed during this focused onsite inspection.
Page 3 of 4
Belle Chase Marine Transportation Services
Inspection Date: 07/15/2024
SECTION IV - AREAS OF CONCERN
The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation. Tenant: Belle Chasse Marine Transportation Services
AOC #1 - BCMT did not clearly label containers used Citation: 40 CFR 279.22(c)(1) to store used oil with the words "Used Oil"
Section: 2.1
AOC #2 - BCMT was storing used oil in containers that Citation: 40 CFR 279.22(b)(1) were in poor condition
Section: 2.1
AOC #3 - BCMT did not make a hazardous waste determination
Citation: 40 CFR 262.11
Section: 2.1
SECTION V - FOLLOW UP
Documents or files provided by the facility as follow-up were transmitted via email and included responses to AOCs or provision of documents requested. See Appendices 2 - 4.
Communication Log During and after the inspection, additional information was emailed to EPA including: 1. 07/24/24 BCMT email - Frank Hannan provided the inspection team with manifests from their last used oil disposal, confirmation of no waste removal from vessels, and images of drums and totes labeled as used oil. 2. 07/24/24 BCMT email - Frank Hannan provided the inspection team with manifests and photos of some of the drums and totes sent for disposal. 3. 07/31/24 BCMT email - Frank Hannan provided the inspection team with manifests and photos of the rest of the drums and totes sent for disposal.
SECTION VI - LIST OF APPENDICES Appendix 1. Photograph Log Appendix 2. BCMT 7/24 Email response Appendix 3. BCMT 7/25 Email Response Appendix 4. BCMT 7/31 Email Response
Page 4 of 4
APPENDIX 1. PHOTOGRAPH LOG
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 1
Location: Belle Chasse Marine Transportation Services
City: New Orleans
County/Parish: Orleans
State: Louisiana
Photo File Name: DSCN6687 Date of Photo: 07/15/2024 Time of Photo: 11:59 hrs. Photographer: Vince Damiano Description: View of three 55-gallon drums containing used oil found in front storage area that did not contain a label.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 2
Location: Belle Chasse Marine Transportation Services
City: New Orleans
County/Parish: Orleans
State: Louisiana
Photo File Name: DSCN6688 Date of Photo: 07/15/2024 Time of Photo: 11:59 hrs. Photographer: Vince Damiano Description: View of three 55-gallon drums containing used oil found in front storage area that did not contain a label. The far right drum has a heavily corroded lid.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 3
Location: Belle Chasse Marine Transportation Services
City: New Orleans
County/Parish: Orleans
State: Louisiana
Photo File Name: DSCN6689 Date of Photo: 07/15/2024 Time of Photo: 11:59 hrs. Photographer: Vince Damiano Description: View of three 55-gallon drums containing used oil found in front storage area that did not contain a label.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 4
Location: Belle Chasse Marine Transportation Services
City: New Orleans
County/Parish: Orleans
State: Louisiana
Photo File Name: DSCN6690 Date of Photo: 07/15/2024 Time of Photo: 11:59 hrs. Photographer: Vince Damiano Description: View of three 55-gallon drums containing used oil found in front storage area that did not contain a label.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 5
Location: Belle Chasse Marine Transportation Services
City: New Orleans
County/Parish: Orleans
State: Louisiana
Photo File Name: DSCN6691 Date of Photo: 07/15/2024 Time of Photo: 12:01 hrs. Photographer: Vince Damiano Description: View of one 55-gallon drum containing used oil found in front storage area that did not contain a label. Drum lid is heavily corroded.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 6
Location: Belle Chasse Marine Transportation Services
City: New Orleans
County/Parish: Orleans
State: Louisiana
Photo File Name: DSCN6692 Date of Photo: 07/15/2024 Time of Photo: 12:01 hrs. Photographer: Vince Damiano Description: View of one tote containing used oil found in front storage area that did not contain a label.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 7
Location: Belle Chasse Marine Transportation Services
City: New Orleans
County/Parish: Orleans
State: Louisiana
Photo File Name: DSCN6693 Date of Photo: 07/15/2024 Time of Photo: 12:01 hrs. Photographer: Vince Damiano Description: View of three totes containing used oil found in front storage area that did not contain a label.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 8
Location: Belle Chasse Marine Transportation Services
City: New Orleans
County/Parish: Orleans
State: Louisiana
Photo File Name: DSCN6694 Date of Photo: 07/15/2024 Time of Photo: 12:07 hrs. Photographer: Vince Damiano Description: View of undetermined totes containing liquid found in the storage area.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 9
Location: Belle Chasse Marine Transportation Services
City: New Orleans
County/Parish: Orleans
State: Louisiana
Photo File Name: DSCN6695 Date of Photo: 07/15/2024 Time of Photo: 12:07 hrs. Photographer: Vince Damiano Description: View of undetermined totes containing liquid found in the storage area.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 30
Location: Belle Chasse Marine Transportation Services
City: New Orleans
County/Parish: Orleans
State: Louisiana
Photo File Name: DSCN6696 Date of Photo: 07/15/2024 Time of Photo: 12:07 hrs. Photographer: Vince Damiano Description: View of undetermined totes containing liquid found in the storage area. Top of tote in foreground is cracked and open.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 41
Location: Belle Chasse Marine Transportation Services
City: New Orleans
County/Parish: Orleans
State: Louisiana
Photo File Name: DSCN6697 Date of Photo: 07/15/2024 Time of Photo: 12:12 hrs. Photographer: Vince Damiano Description: View of a tote containing a liquid with a broken top found in the storage area.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 52
Location: Belle Chasse Marine Transportation Services
City: New Orleans
County/Parish: Orleans
State: Louisiana
Photo File Name: DSCN6698 Date of Photo: 07/15/2024 Time of Photo: 12:12 hrs. Photographer: Vince Damiano Description: View of undetermined full 55-gallon containers found in storage area.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 63
Location: Belle Chasse Marine Transportation Services
City: New Orleans
County/Parish: Orleans
State: Louisiana
Photo File Name: DSCN6699 Date of Photo: 07/15/2024 Time of Photo: 12:13 hrs. Photographer: Vince Damiano Description: View of undetermined full 55-gallon containers found in storage area.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 74
Location: Belle Chasse Marine Transportation Services
City: New Orleans
County/Parish: Orleans
State: Louisiana
Photo File Name: DSCN6700 Date of Photo: 07/15/2024 Time of Photo: 12:13 hrs. Photographer: Vince Damiano Description: View of undetermined full 55-gallon containers found in storage area.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 85
Location: Belle Chasse Marine Transportation Services
City: New Orleans
County/Parish: Orleans
State: Louisiana
Photo File Name: DSCN6701 Date of Photo: 07/15/2024 Time of Photo: 12:13 hrs. Photographer: Vince Damiano Description: View of an undetermined full 5-gallon container found in storage area.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 96
Location: Belle Chasse Marine Transportation Services
City: New Orleans
County/Parish: Orleans
State: Louisiana
Photo File Name: DSCN6702 Date of Photo: 07/15/2024 Time of Photo: 12:14 hrs. Photographer: Vince Damiano Description: View of a label on an undetermined drum in storage area; unclear if this is a new tote or reused.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 107
Location: Belle Chasse Marine Transportation Services
City: New Orleans
County/Parish: Orleans
State: Louisiana
Photo File Name: DSCN6703 Date of Photo: 07/15/2024 Time of Photo: 12:15 hrs. Photographer: Vince Damiano Description: View of a label on an undetermined tote in storage area; unclear if this is a new tote or reused.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 118
Location: Belle Chasse Marine Transportation Services
City: New Orleans
County/Parish: Orleans
State: Louisiana
Photo File Name: DSCN6704 Date of Photo: 07/15/2024 Time of Photo: 12:15 hrs. Photographer: Vince Damiano Description: View of a label on an undetermined tote in storage area; unclear if this is a new tote or reused.
APPENDIX 2. BCMT 7/24 EMAIL RESPONSE
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APPENDIX 3. BCMT 7/25 EMAIL RESPONSE
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APPENDIX 4. BCMT 7/31 EMAIL RESPONSE
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