Document JNQYea9OLvx33RG9BkX0J75Yr

Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 6 Enforcement Division INSPECTION REPORT 07/16/2024 13:51 (CT) 07/16/2024 14:33 (CT) Announced: No (tenants and related facilities) 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 QSL New Orleans LLC N/A First Street Wharf New Orleans, LA 70115 Orleans Parish N/A 488320 QSL operates as a stevedoring company loading and unloading cargo from vessels. 29.92203, -90.0734 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 10:28:44 -04'00' Vince.Damiano@erg.com (703) 835-6281 Page 1 of 5 QSL New Orleans LLC Inspection Date: 07/16/2024 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 Page 2 of 5 QSL New Orleans LLC Inspection Date: 07/16/2024 Facility General Description Tenant/Area QSL New Orleans LLC Inspection Date 07/16/24 Process Description QSL New Orleans LLC (QSL) operates as a stevedoring company loading and unloading cargo from vessels. The cargo QSL handles mainly consists of metals, bulk materials, and project cargo crates. QSL maintains a MARPOL COA through the Port of New Orleans. Area of Concern Yes Page 3 of 5 QSL New Orleans LLC SECTION II - OBSERVATIONS Inspection Date: 07/16/2024 Tenant: QSL New Orleans LLC Section: 2.1 Date: 07/16/24, 01:51 PM Contains AOC: Yes Lead Inspector: Vince Damiano Attendees: Tony Dow (Manager) Contains CBI: No QSL is located within Port of New Orleans and operates as a stevedoring company loading and unloading cargo from vessels. The cargo QSL handles mainly consists of metals, bulk materials, and project cargo crates. Mr. Dow stated most of their cargo loads are from ships directly onto barges and the cargo is never stored at QSL's warehouse. The cargo that is unloaded off ships, is stored before being shipped off to customers in trucks or rail cars. QSL maintains a MARPOL COA through the Port of New Orleans. Mr. Dow stated they do not remove any waste from ships but will occasionally accept dunnage which is placed in a roll off container for recycling. Mr. Dow stated that third party boats will remove wase from ships docked at QSL, but QSL is not involved in this process and the waste never comes onto QSL property. QSL is not registered with the EPA as a hazardous waste generator. Following the opening conference, the inspection team conducted a visual inspection of QSL's warehouse where their maintenance area is located and their dock area. Inside the maintenance area, the inspection team observed an approximate half-full 275-gal tote used to collect used oil from maintenance activities that did not contain a label with the words "Used Oil" (see Appendix 1 - Photos 1 and 2) [AOC #1: QSL did not clearly label containers used to store used oil with the words "Used Oil." - 40 CFR 279.22 (c)(1)]. Next, the inspection team observed the dock space from a distance because a ship was currently being loaded with toxic lead. Due to an emergency that occurred regarding the shipment, the facility representative had to wrap the inspection up quickly since Mr. Dow was the only representative available to meet with the inspection team. The inspection team did not observe other areas of concern (AOCs) at the time of the inspection; however, further EPA review may change or add to these potential AOCs. A closing conference was conducted at approximately 02:30 PM with QSL personnel. The AOCs were communicated during the closing. Following the inspection, the inspection team inquired about any hazardous waste that may be produced from the handling of the toxic lead material observed during the inspection. Mr. Dow responded on 7/16 stating; "As for the vessel loading lead, all Tyvek suits worn by our employees are placed in drums, locked down, a placard placed on drums and they are shipped by truck back to the customer to incinerate at the mine. The shower water is placed in the last barge to complete and a third party vacuums the water up at their facility and sends it back to the customer facility" (see Appendix 2). Based on the response provided by QSL, it appears a hazardous waste determination would be needed regarding the lead contaminated PPE and shower water [AOC #2 - QSL did not make a hazardous waste determination. - 40 CFR 262.11]. On 7/18, Mr. Dow provided the inspection team with a photograph of the used oil tote properly labeled (see Appendix 3). Page 4 of 5 QSL New Orleans LLC SECTION III - RECORDS REVIEW Inspection Date: 07/16/2024 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. Tenant: QSL New Orleans LLC AOC #1 - QSL did not clearly label containers used to Citation: 40 CFR 279.22 (c)(1) store used oil with the words "Used Oil." Section: 2.1 AOC #2 - QSL did not make a hazardous waste determination. Citation: 40 CFR 262.11 Section: 2.1 SECTION V - FOLLOW UP 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. 07/16/24 QSL email - Mr. Dow sent a follow-up addressing concerns related to the handling of the toxic lead material observed during the inspection. 2. 07/18/24 QSL email - Mr. Dow sent a follow-up photograph of the used oil tote properly labeled. SECTION VI - LIST OF APPENDICES Appendix 1. Photograph Log Appendix 2. QSL 07/16/24 Response Appendix 3. QSL 07/18/24 Response Photograph Page 5 of 5 APPENDIX 1. PHOTOGRAPH LOG UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: QSL New Orleans LLC City: New Orleans Photo No. 1 County/Parish: Orleans State: Louisiana Photo File Name: DSCN6707 Date of Photo: 07/16/2024 Time of Photo: 14:14 hrs. Photographer: Vince Damiano Description: One 275-gallon tote containing used oil that was not labeled found in maintance area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: QSL New Orleans LLC City: New Orleans Photo No. 2 County/Parish: Orleans State: Louisiana Photo File Name: DSCN6708 Date of Photo: 07/16/2024 Time of Photo: 14:15 hrs. Photographer: Vince Damiano Description: Another view of one 275-gal tote containing used oil that was not labeled found in maintance area. APPENDIX 2. QSL 07/16/24 RESPONSE APPENDIX 3. QSL 07/18/24 RESPONSE PHOTOGRAPH On 7/18/2024, QSL provided this photo of the used oil tote properly labled. Appendix 3 Page 1 of 1