Document LJad6B81V6RpazYpyaQ7xOZ95
Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program
Type of Inspection
EPA REGION 6 Enforcement Division
INSPECTION REPORT
04/18/2024 10:41 (CT) 04/18/2024 11:50 (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
Canal Barge Company, Inc. N/A 1891 Swisco Rd Sulphur, LA 70665 Calcasieu Parish None N/A Canal Barge Company, Inc. transports cargoes between major oil refineries using tugboats and barges 30.209925, -93.338545
Additional Persons Participating in Inspection:
Name
Title
Organization
Elizabeth Pham
Inspector
EPA REGION 6
Sandesh Thapa
Inspector
EPA REGION 6
Anshul Paripati
Contractor
Eastern Research Group (ERG)
Email Pham.elizabeth@epa.gov Thapa.sandesh@epa.gov Anshul.Paripati@erg.com
Phone (214) 665-8354 (214) 665-2265 (571) 535-1503
Lead Inspector: Cameron Tanaka
Cameron Tanaka Date: 2024.07.24 22:24:07 -04'00' Digitally signed by Cameron Tanaka 07/24/2024
ERG
Cameron.Tanaka@erg.com
(703) 633-1632
ext. 11632
Page 1 of 7
Canal Barge Company, Inc.
Inspection Date(s): 04/18/2024
SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection Type of inspection: Focused Compliance Inspection (FCI)
The Port of Lake Charles 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, port related facilities, 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 Inspector/Enforcement Officer/EPA Region 6
Name
Phone
Email
Opening Closing Conf. Conf.
Cameron Tanaka (703) 633-1632 Cameron.Tanaka@erg.com Yes
No
ext. 11632
Anshul Paripati (571) 535-1503 Anshul.Paripati@erg.com Yes
Yes
Elizabeth Pham (214) 665-8354 Pham.elizabeth@epa.gov Yes
Yes
Sandesh Thapa (214) 665-2265 Thapa.sandesh@epa.gov Yes
Yes
Page 2 of 7
Canal Barge Company, Inc.
Inspection Date(s): 04/18/2024
Facility General Description
Tenant/Area Canal Barge Company, Inc.
Inspection Date
04/18/24
Process Description Canal Barge Company, Inc. (Canal Barge) operates tugboats and barges on the waterways near Sulphur/Lake Charles. They transport cargoes between major oil refineries. They load and unload cargo (product) at the ports, such as lube oils and various unused chemicals. The location the inspection team visited is only involved in coordinating cargo transfers. They generally do not receive any waste but occasionally receive old appliances, scrap, used batteries, or damaged goods. They do not have a MARPOL certificate.
Area of Concern
Yes
Page 3 of 7
Canal Barge Company, Inc.
Inspection Date(s): 04/18/2024
SECTION II - OBSERVATIONS
Tenant: Canal Barge Company, Inc.
Section: 2.1
Date: 04/18/24, 10:41 AM Contains AOC: Yes Contains CBI: No
Lead Inspector: Cameron Tanaka
Attendees: Logan Mills (Purchaser/Warehouse Manager) and Derek Adams (Operations Manager)
Canal Barge is a tugboat and barge company that transports cargo between docks with a fleet of 400 barges used to transport materials for major oil and chemical companies. These cargoes include various product chemicals and lube oils. Any spills of these materials are the major oil or chemical company's responsibility. For spills, third party spill response companies are contacted to clean the spill with help from the responsible company. Waste generated from their vessels, including used oil, bilge, and slops, are removed via Stone Fuel barges, a third-party fueling company. Their physical location that the team inspected is just for cargo transfers and coordinating transportation. They generally do not bring any waste onto their site except for household garbage, occasional e-waste, broken dryers, stoves, icemakers, fridges, and used batteries. These wastes are transported to VLS in Hackberry, LA. Freight trucks transport cargoes and waste materials to and from their physical location. For broken appliances that are brought on-site, Canal Barge will attempt to repair the appliances first. If they cannot repair the appliances, the appliance will be sent back to the company that originally owned it or the broken appliance will be scrapped. Used batteries are sent back for their cores to the battery supplier and swapped with new ones. Occasionally, Canal Barge's freight trucks will deliver damaged good with leaks, including paint cans. These are moved to a secure location and taken to VLS in Hackberry. Canal Barge does not have an EPA ID or a MARPOL COA.
After the opening meeting, the inspection team performed a walk-through inspection of the facility's warehouse and yard area outside the warehouse. No AOCs were observed inside the warehouse.
Yard Area Outside Warehouse
In the yard area, the inspection team observed a barrel of synthetic lubricant with some remaining material on a pallet (see Appendix 1 - Photos 1 and 2). Mr. Mills explained that the drum was returned with very little liquid left and that he was unsure if the material was used or not. In a follow-up email from May 18, Mr. Adams explained that "The partial barrel of lubricant has been removed from the property by an approved disposal facility (Environmental Resource Services, Inc.)" (see Appendix 2). The inspection team also viewed a pallet of used batteries that were not labeled or dated (see Appendix 1 - Photos 3 and 4). [AOC #1 - Canal Barge did not label or mark clearly their used batteries with any one of the following phrases: "Universal Waste-Battery(ies)," or "Waste Battery(ies)," or "Used Battery(ies)." - 40 CFR 273.14(a); AOC #2 - Canal Barge did not provide a demonstration of the length of time that the universal waste has been accumulated from the date it becomes a waste or is received. - 40 CFR 273.15(c)] In the follow-up email, Mr. Adams explained that "The used batteries have been labeled and dated, until we can have them exchanged as cores with our vendor or properly disposed of." (see Appendix 2).
Waste Lot
The inspection team also viewed a small, expired paint can that was mostly full and a chemical container that was about half full of unknown material located next to their broken appliances in their waste lot (see Appendix 1 - Photos 5 and 6). [AOC #3 - Canal Barge did not make an accurate determination as to whether their waste is a hazardous waste in order to ensure wastes are properly managed according to applicable RCRA regulations. - 40 CFR 262.11] In the follow-up email, Mr. Adams explained that "These items have been removed from the property by an approved disposal facility (Vessel Cleaning, LLC)." (see Appendix 2).
Page 4 of 7
Canal Barge Company, Inc.
Inspection Date(s): 04/18/2024
The inspection team did not observe other AOCs at the time of the inspection. A closing conference was conducted at approximately 11:40 AM with Canal Barge personnel. The AOCs were communicated during the closing.
Page 5 of 7
Canal Barge Company, Inc.
Inspection Date(s): 04/18/2024
SECTION III - RECORDS REVIEW
No RCRA regulated records reviewed during this focused onsite inspection.
SECTION IV - APPARENT AREAS OF CONCERN
The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation. Tenant: Canal Barge Company, Inc.
AOC #17 - Canal Barge did not label or mark clearly their used batteries with any one of the following phrases: "Universal Waste-Battery(ies)," or "Waste Battery(ies)," or "Used Battery(ies)."
Citation: 40 CFR 273.14(a)
Section: 2.1
AOC #2 - Canal Barge did not provide a demonstration Citation: 40 CFR 273.15(c) of the length of time that the universal waste has been accumulated from the date it becomes a waste or is received.
Section: 2.1
AOC #3 - Canal Barge did not make an accurate determination as to whether their waste is a hazardous waste in order to ensure wastes are properly managed according to applicable RCRA regulations.
Citation: 40 CFR 262.11
Section: 2.1
SECTION V - FOLLOW UP
Follow-Up Any facility follow-up items are as discussed in each facility's observations in Section II. Documents or files provided by the facilities were transmitted via email and included responses to areas of concern or provision of documents requested.
Communication Log
During and after the inspection, additional information was emailed to EPA including: 1. 05/08/24 Canal Barge email - Derek Adams sent an email with a photograph and several descriptions of corrective actions implemented at the site.
Page 6 of 7
Canal Barge Company, Inc.
SECTION VI - LIST OF APPENDICES Appendix 1. Photograph Log Appendix 2. Follow-Up Email and Photograph from Canal Barge
Inspection Date(s): 04/18/2024
Page 7 of 7
APPENDIX 1. PHOTOGRAPH LOG
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 1
Location: Canal Barge Company, Inc.
City: Sulphur
County/Parish: Calcasieu
State: Louisiana
Photo File Name: DSCN7193 Date of Photo: 04/18/2024 Time of Photo: 10:27 hrs. Photographer: Anshul Paripati Description: A barrel of synthetic lubricant with some remaining material on a pallet in Canal Barge's yard area outside their warehouse.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 2
Location: Canal Barge Company, Inc.
City: Sulphur
County/Parish: Calcasieu
State: Louisiana
Photo File Name: DSCN7194 Date of Photo: 04/18/2024 Time of Photo: 10:27 hrs. Photographer: Anshul Paripati Description: Closeup of a barrel of synthetic lubricant with some remaining material on a pallet in Canal Barge's yard area outside their warehouse.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 3
Location: Canal Barge Company, Inc.
City: Sulphur
County/Parish: Calcasieu
State: Louisiana
Photo File Name: DSCN7195 Date of Photo: 04/18/2024 Time of Photo: 10:29 hrs. Photographer: Anshul Paripati Description: Overview of a pallet of used batteries that were not labeled in Canal Barge's yard area outside their warehouse.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 4
Location: Canal Barge Company, Inc.
City: Sulphur
County/Parish: Calcasieu
State: Louisiana
Photo File Name: DSCN7196 Date of Photo: 04/18/2024 Time of Photo: 10:29 hrs. Photographer: Anshul Paripati Description: Close up view of a pallet of used batteries that were not labeled in Canal Barge's yard area outside their warehouse.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 5
Location: Canal Barge Company, Inc.
City: Sulphur
County/Parish: Calcasieu
State: Louisiana
Photo File Name: DSCN7197 Date of Photo: 04/18/2024 Time of Photo: 10:36 hrs. Photographer: Anshul Paripati Description: View of an expired paint can and a chemical container with unknown material in it in Canal Barge's waste lot.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 6
Location: Canal Barge Company, Inc.
City: Sulphur
County/Parish: Calcasieu
State: Louisiana
Photo File Name: DSCN7198 Date of Photo: 04/18/2024 Time of Photo: 10:36 hrs. Photographer: Anshul Paripati Description: Closeup view of an expired paint can and a chemical container with unknown material in it in Canal Barge's waste lot.
APPENDIX 2. FOLLOW-UP EMAIL AND PHOTOGRAPH FROM CANAL BARGE
Appendix 2 Page 1 of 4
Appendix 2 Page 2 of 4
Appendix 2 Page 3 of 4
Appendix 2 Page 4 of 4