Document J3bEE8ywQQrrb5LXKaKONr6ne

Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 6 Enforcement Division INSPECTION REPORT 6/6/2024 2:10 PM (CT) 6/6/2024 3:30 PM (CT) RCRA Focused Compliance Inspection (FCI) Announced: No 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 C-Port, LLC LAR000051672 106 9th St Golden Meadow, LA 70357 Lafourche Parish Very Small Quantity Generator (VSQG) 213112 C-Port, LLC operates a cargo terminal at Port Fourchon 29.129525, -90.215618 Additional Persons Participating in Inspection: Name Title Organization Email Phone Joyce Johnson Inspector EPA REGION 6 Johnson.Joyce-r6@epa.gov (214) 665-8548 Dedriel Gardner Inspector EPA REGION 6 Gardner.Dedriel@epa.gov (281) 983-2133 Neil Rapp Contractor Eastern Research Neil.Rapp@erg.com Group (ERG) (480) 450-6517 Lead Inspector: Vince Damiano Vincent Damiano ERG Digitally signed by Vincent Damiano Date: 2024.09.09 17:49:01 -04'00' Vince.Damiano@erg.com (703) 835-6281 1 of 6 C-Port, LLC Inspection Date: 06/06/2024 SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection Type of inspection: Focused Compliance Inspection (FCI) Port Fourchon 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 maintaining 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 records including verbal or written statements made during or after the on-site inspection, and 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 Name Lead Inspector/ Contactor/ERG RCRA Inspector/ Contractor/ERG Inspector/Enforcement Officer/EPA Region 6 Inspector/Enforcement Officer/EPA Region 6 Vince Damiano Neil Rapp Joyce Johnson Dedriel Gardner Phone Email (703) 835-6281 Vince.Damiano@erg.com Opening Conf. Yes Closing Conf. Yes (480) 450-6517 Neil.Rapp@erg.com Yes Yes (214) 665-8548 Johnson.Joyce-r6@epa.gov Yes Yes (281) 983-2133 Gardner.Dedriel@epa.gov Yes Yes 2 of 6 C-Port, LLC Inspection Date: 06/06/2024 Facility General Description Tenant/Area C-Port, LLC Inspection Date 06/06/24 Process Description C-Port, LLC (CP) operates nine slips and has six tenants that it services. CP loads and offloads vessels for tenants and does not allow third parties to use its dock space. It also conducts bulk fluid transfers providing diesel to vessels at the terminal. CP offloads waste from vessels at its slips, but the clients at the terminal manage the waste after offloading. CP does not store or manage any of the waste removed from vessels. CP does unload MARPOL waste (USDA-regulated [APHIS] waste) from vessels, which it directly loads into dumpsters. The dumpsters are managed by its tenants and their ship agents. CP is a VSQG of hazardous waste and maintains a MARPOL COA for Annexes I and V. Areas of Concern Yes 3 of 6 C-Port, LLC Inspection Date: 06/06/2024 SECTION II - OBSERVATIONS Tenant: C-Port, LLC Section: 2.1 Date: 6/6/2024, 2:10 P.M. Contains AOC: Yes Contains CBI: No Lead Inspector: Vince Damiano Attendees: James Guidry (General Manager), Matt Labat (QHSE Manager), Brittney Serigney (Environmental Supervisor) CP personnel provided the inspection team with a summary of operations at the facility. CP operates a cargo terminal with nine slips and has six tenants (Halliburton, MI Swaco, Baker Houghes, Champion X, Cantium, and Occidental/Anadarko) that it services. CP loads and offloads supplies and equipment from vessels and trucks for its tenants. In addition, CP conducts bulk fluid transfers providing diesel to tenants' and third-party vessels at the terminal. CP also offloads waste including hazardous waste from tenants' vessels at its slips, but the tenants manage the waste at the terminal after offloading. The company does not store or manage any of the waste removed from vessels. CP unloads APHIS waste from vessels as well, which it places directly into dumpsters for its tenants. The dumpsters are managed by its tenants and their ship agents. CP maintains a MARPOL COA for Annexes I and V. CP is registered with EPA as a transfer facility for used oil (LAR000051672). However, Mr. Guidry stated that CP does not act as a used oil transfer facility and that CP registered with EPA in anticipation of potential future operations. The facility is a VSQG of hazardous waste, mostly generated from day-to-day maintenance operations at the terminal (i.e., paint waste). CP also generates used oil from equipment maintenance which it disposes of with American Recovery. After the opening conference, the inspection team conducted a visual inspection of the facility's dock space and warehouse. No areas of concern (AOCs) were identified during the initial visual inspection; however, further EPA review may change or add to their potential AOCs. A closing conference was conducted at approximately 3:20 PM with CP personnel. The inspection team requested a copy of the CP's MARPOL COA. At the time of writing this report, the inspection team had not received the requested documentation from CP. After concluding its inspection of CP, the inspection team conducted a separate inspection of Anadarko Petroleum Company, a wholly owned subsidiary of Occidental (Anadarko). Anadarko is a tenant of CP and rents dock space from it including Slip 6. While inspecting Slip 6 with Anadarko personnel, the inspection team observed spilled material and stains on the concrete and gravel near the edge of the slip and behind a small building referred to as the fuel shack. Anadarko personnel indicated that the spills and stains were related to CP's fueling activities at the slip. The inspection team identified two spills at Slip 6. One along the edge of the slip which was approximately 50 ft x 3 ft in size, and a second which was about 4 ft in diameter (see Appendix 1 - Photos 1 to 5). [AOC #1 - CP did not make a hazardous waste determination for the spilled material at Slip 6. - 40 CFR 262.11]. The inspection team contacted CP in a follow-up email and requested a hazardous waste determination for the spill material. Mr. Labat provided a response on 6/13/2024, which has been included in this report as Appendix 2. SECTION III - RECORDS REVIEW No RCRA regulated records were reviewed during this focused onsite inspection besides those mentioned in Section II. SECTION IV - AREA OF CONCERN The presentation of AOCs does not constitute a formal compliance determination or violation. 4 of 6 C-Port, LLC Inspection Date: 06/06/2024 Tenant: C-Port, LLC AOC #1 - CP did not make a Citation: 40 CFR 262.11 hazardous waste determination for the spilled material at Slip 6. Section: 2.1 SECTION V -FOLLOW UP Documents or files provided by the facility were transmitted via email. 5 of 6 C-Port, LLC Inspection Date: 06/06/2024 Communication Log After the inspection, additional information was emailed to EPA including: 1. 6/13/2024 CP email - Matt Labat provided a response to the AOC identified during the inspection. SECTION VI - LIST OF APPENDICES Appendix 1 - Photograph Log Appendix 2 C-Port Response to AOC 6 of 6 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Appendix 1 Photograph Log UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: C-Port, LLC City: Golden Meadow Photo No. 1 County/Parish: Lafourche State: Louisiana Photo File Name: DSCN7337 Date of Photo: 6/06/2024 Time of Photo: 16:36 CST Photographer: Vince Damiano Description: View of spilled material along the edge of Slip 6. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: C-Port, LLC City: Golden Meadow Photo No. 2 County/Parish: Lafourche State: Louisiana Photo File Name: DSCN7338 Date of Photo: 6/06/2024 Time of Photo: 16:36 CST Photographer: Vince Damiano Description: View of spilled material along the edge of Slip 6. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: C-Port, LLC City: Golden Meadow Photo No. 3 County/Parish: Lafourche State: Louisiana Photo File Name: DSCN7339 Date of Photo: 6/06/2024 Time of Photo: 16:36 CST Photographer: Vince Damiano Description: View of spilled material along the edge of Slip 6. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: C-Port, LLC City: Golden Meadow Photo No. 4 County/Parish: Lafourche State: Louisiana Photo File Name: DSCN7340 Date of Photo: 6/06/2024 Time of Photo: 16:36 CST Photographer: Vince Damiano Description: View of spilled material by fuel shack at Slip 6. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: C-Port, LLC City: Golden Meadow Photo No. 5 County/Parish: Lafourche State: Louisiana Photo File Name: DSCN7341 Date of Photo: 6/06/2024 Time of Photo: 16:36 CST Photographer: Vince Damiano Description: View of spilled material by fuel shack at Slip 6. Appendix 2 C-Port Response to AOC C-Port 1 Audit date: 06/07/2024 Audit report Environmental Inspection Planned date 06/07/2024 Audit location C-Port 1 Assisting auditor Matt Labat, Brittney Serigny, James Guidry Audit author Matt Labat/ECO Comments EPA conducted a RCRA compliance inspection at C-Port 1. Company EPA Auditor's ref. no. Findings # Finding Type 001 Non-Conformity 002 Non-Conformity Title Stained Pavers Stained Limestone Responsible Matt Labat/ECO Matt Labat/ECO Cajun Iron Workers Closed CP1/2024/001 Auditor Vince Damiano Limit date 06/21/2024 06/21/2024 Status Closed Closed References Type Attachment Title C PORT EPA SIGN IN.pdf Number N/A Exported by: Matt Labat/ECO @2024-06-13T15:28:08.450-05:00 C-Port 1 Author: Matt Labat Audit date 06/07/2024 Finding 001 - Non-Conformity Responsible Matt Labat/ECO Due Date 06/21/2024 Title Stained Pavers Description Stained pavers located in slip 6 Auditor's Comments Stained pavers indicate a potential release of product Rules & Regulations Analysis Type of contact or near contact with energy or substance Analysis Comments Immediate Causes Cajun Iron Workers Closed Environmental Inspection + ' ' + CP1/2024/001 Basic/Underlying Causes Analysis of risk potential HAZARD SEVERITY OUTCOME [A] People [B] Assets [C] Environmental PROBABILITY [D] Reputation Never Heard of in has Happens Incident Happens heard of in the occurred several several marine in the times per times per the marine industry company year at the year on a industry last 10 last 10 company location or years years vessel Slight Injury FA/Personal Impact Slight damage $1 - $1,000 Slight impact less than 20 gallons Slight Impact A1 B1 C1 D1 E1 1 Impact $1,000 1 barrel Minor Injury FA/Limited Personal Minor damage more than Minor impact between 20 gallons and Limited Impact A2 B2 C2 D2 E2 2 Impact $10,000 and and 5 barrels Impact LTA/REC/ Considerable Personal Localized damage more than Localized impact between 1 barrel Considerable A3 B3 C3 D3 E3 3 Impact $100,000 100 barrels Impact Single Fatality/Major Personal Major damage more than Major impact between 5 barrels and National A4 B4 C4 D4 E4 4 Personal Impact $1,000,000 barrels Impact Multiple Fatalities/Catastrophic Extensive damage more than Massive impact more than 100 International A5 B5 C5 D5 E5 5 A B C D E Workflow Responsible Planned Corrective Action Pavers were pressure washed Corrective Actions Taken Pavers were pressure washed Resp. sign. Matt Labat, 06/13/2024 Actions to Prevent Reoccurrence Nothing at this time Auditor closing Auditor Follow-Up/Effectiveness of Corrective Action(s) Pavers were pressure washed and any recovered product was placed in a DOT drum. A forklift operator had knocked over a drum containing used oil filters and pads. The area was cleaned appropriately. Signature Matt Labat, 06/13/2024 References Type Attachment Title Photo Page.pdf Number N/A Exported by: Matt Labat/ECO @2024-06-13T15:28:10.965-05:00 Owner Approved By QHSE Manager Ma Labat Printed copy. For the latest revisions, check UniSea IMS. QHSE Dept. Forms Miscellaneous Photo Page Cajun Iron Workers Approved QHSE/F/MI/1660 Revision Last Revision Date 1 9/12/19 Date: 06/13/24 Photographer: Ma Labat Descrip on: Stained pavers Date: 06/13/24 Photographer: Ma Labat Descrip on: Stained pavers Name completed le in the format of: "Photo Page [date]" - Ex. Photo Page 9.12.19 t t t t t t t ti i fi C-Port 1 Author: Matt Labat Audit date 06/07/2024 Finding 002 - Non-Conformity Responsible Matt Labat/ECO Due Date 06/21/2024 Title Stained Limestone Description Stained limestone was observed throughout the facility Auditor's Comments Stained limestone indicates a potential release of product Rules & Regulations Analysis Type of contact or near contact with energy or substance Analysis Comments Immediate Causes Cajun Iron Workers Closed Environmental Inspection + ' ' + CP1/2024/001 Basic/Underlying Causes Analysis of risk potential HAZARD SEVERITY OUTCOME [A] People [B] Assets [C] Environmental PROBABILITY [D] Reputation Never Heard of in has Happens Incident Happens heard of in the occurred several several marine in the times per times per the marine industry company year at the year on a industry last 10 last 10 company location or years years vessel Slight Injury FA/Personal Impact Slight damage $1 - $1,000 Slight impact less than 20 gallons Slight Impact A1 B1 C1 D1 E1 1 Impact $1,000 1 barrel Minor Injury FA/Limited Personal Minor damage more than Minor impact between 20 gallons and Limited Impact A2 B2 C2 D2 E2 2 Impact $10,000 and and 5 barrels Impact LTA/REC/ Considerable Personal Localized damage more than Localized impact between 1 barrel Considerable A3 B3 C3 D3 E3 3 Impact $100,000 100 barrels Impact Single Fatality/Major Personal Major damage more than Major impact between 5 barrels and National A4 B4 C4 D4 E4 4 Personal Impact $1,000,000 barrels Impact Multiple Fatalities/Catastrophic Extensive damage more than Massive impact more than 100 International A5 B5 C5 D5 E5 5 A B C D E Workflow Responsible Planned Corrective Action Recover limestone if needed Corrective Actions Taken Areas were flushed with water to determine if there was a released product causing the staining the the lime stone. There was no evidence of active spills or sheen from the limestone when areas were flushed with water. No further action taken. Actions to Prevent Reoccurrence Auditor closing Auditor Follow-Up/Effectiveness of Corrective Action(s) Areas were flushed with water to determine if there was a released product causing the staining the the lime stone. There was no evidence of active spills or sheen from the limestone when areas were flushed with water. No further action taken. Signature Matt Labat, 06/13/2024 References No references Exported by: Matt Labat/ECO @2024-06-13T15:28:11.106-05:00