Document Lp8ERn2ogj0w0MKZyyE2X5LqQ

f t E A ~ United States .._~ Environmen tal Pro tection ,., Agency Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 6 Enforcement Division INSPECTION REPORT 3/24/2025 12:45 (CT) Announced: No 3/24/2025 14:35 (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 Coral Marine Services LLC LAD985206960 887 Degravelle Rd. Amelia, LA 70340 St. Mary VSQG 336611 Coral Marine Services LLC (CMS) conducts tank cleanings of boats, vessels, and barges, along with performing repairs and maintenance on boats in their marine division. 29.6634, -91.1276 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 15:57:04 -04'00' IVince.Damiano@erg.com Page 1 of 4 Coral Marine Services LLC SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection Inspection Date: 3/24/2025 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 Name Email Lead Inspector/ Contractor/ERG Vince Damiano Vince.Damiano@erg.com Inspector/Enforcement John Penland Penland.John@epa.gov Officer/EPA Region 6 Inspector/Enforcement Erin YoungOfficer/EPA Region 6 Dahl Youngdahl.Erin@epa.gov RCRA Inspector/ Contractor/ERG Janosh Wolters Janosh.Wolters@erg.com Coral Marine Services/Manager Sean Carpenter scarpenter@coralmarineservices.net Opening Conf. Yes Closing Conf. Yes Yes Yes Yes Yes Yes Yes Yes Yes Page 2 of 4 Coral Marine Services LLC Inspection Date: 3/24/2025 Facility General Description Tenant/Area Coral Marine Services LLC Inspection Date 3/24/25 Process Description CMS conducts tank cleanings of boats, vessels, and barges, along with performing repairs and maintenance on boats in their marine division. CMS transports and stores used oil from their tank cleanings at their facility. CMS does not operate under a MARPOL COA. Area of Concern Yes SECTION II - OBSERVATIONS Facility: Coral Marine Services LLC Section: 2.1 Date: 3/24/25, 12:45 AM Contains AOC: Yes Contains CBI: No I I Lead Inspector: Vince Damiano Attendees: Sean Carpenter (Manager) and Charles Simmons (Manager) Coral Marine Services LLC (CMS), located in Amelia, LA, consists of two main operations: tank cleaning and marine vessel maintenance. Tank cleanings are performed on boats, vessels, and barges, with 95 percent of cleanings conducted off site and 5 percent on site, according to Mr. Carpenter. CMS only cleans tanks that store used oil, such as bilges. A degreaser and water are used for cleaning, and one of six 5,000-gallon vacuum trucks is used to remove the oily water, which is transported back to CMS for storage. CMS has 26 storage tanks ranging from 6,000 to 260,000 gallons. Some tanks are designated for used oil storage based on demand, while others are used for water or fuel. Used oil is either recycled or sent to Clean Harbors in White Castle for disposal. Mr. Carpenter stated that used oil is never stored on site for longer than two weeks. CMS will sometimes collect empty paint cans from vessels, which are sent to the River Birch landfill. CMS also performs maintenance and repairs on marine vessels. The company is registered with the EPA as a Very Small Quantity Generator (VSQG) of hazardous waste, used oil transporter, and used oil transfer facility under EPA ID LAD985206960. After the opening conference, the inspection team observed CMS's used oil storage operations. All of the used oil storage tanks were in a tank farm with a secondary containment surrounding the unit. At the time of the inspection, there were only three 20,000-gallon frac tanks storing used oil. The other tanks were either empty, storing water, or storing fuel. Frack tank #3 was full, frack tank #4 was full, and frack tank #5 was full; none were labeled as used oil tanks (see Appendix 1 - Photos 1 to 4) [AOC#1 - CMS did not clearly label aboveground ranks used to store used oil with the words "Used Oil" - 40 CFR 279.45(g)(1)]. The inspection team did not observe other AOCs at the time of the inspection. However, further EPA review may change or add to the list of potential AOCs. A closing conference was conducted at approximately 2:30 PM with CMS personnel. The AOCs were communicated during the closing. Following the inspection on 3/26/2025, Mr. Carpenter sent a follow-up email, including photos of any tanks currently or may store used oil properly labeled (see Appendix 2). SECTION III - RECORDS REVIEW No RCRA-regulated records were reviewed during this focused onsite inspection. Page 3 of 4 Coral Marine Services LLC Inspection Date: 3/24/2025 SECTION IV - AREAS OF CONCERN The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation. Facility: Coral Marine Services LLC AOC #1 - CMS did not clearly label aboveground tanks Citation: 40 CFR 279.45(g)(1) used to store used oil with the words "Used Oil." Section: 2.1 SECTION V - 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. 3/26/25 CMS email - Mr. Carpenter provided the inspection team with photos of the used oil tanks properly labeled. SECTION VI - LIST OF APPENDICES Appendix 1. Photograph Log Appendix 2. Photos from CMS 3/26 Response Page 4 of 4 APPENDIX 1. PHOTOGRAPH LOG UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Coral Marine Services LLC City: Amelia County/Parish: St. Mary I State: Louisiana I Photo No. 1 Photo File Name: DSCN7709 Date of Photo: 3/24/2025 Time of Photo: 1416 hrs. Photographer: Vince Damiano Description: View of a full frack tank (#3) storing used oil in the CMS tank farm that was not labeled as used oil. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Coral Marine Services LLC City: Amelia County/Parish: St. Mary I IState: Louisiana Photo No. 2 Photo File Name: DSCN7710 Date of Photo: 3/24/2025 Time of Photo: 1417 hrs. Photographer: Vince Damiano Description: View of a full frack tank (#4) and a full frac tank (#5) storing used oil in the CMS tank farm that were not labeled as used oil. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Coral Marine Services LLC City: Amelia County/Parish: St. Mary State: Louisiana Photo No. 3 Photo File Name: DSCN7711 Date of Photo: 3/24/2025 Time of Photo: 1417 hrs. Photographer: Vince Damiano Description: View of a full frack tank (#4) storing used oil in the CMS tank farm that was not labeled as used oil. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Coral Marine Services LLC City: Amelia County/Parish: St. Mary State: Louisiana Photo No. 4 Photo File Name: DSCN7712 Date of Photo: 3/24/2025 Time of Photo: 1417 hrs. Photographer: Vince Damiano Description: View of a full frack tank (#3) storing used oil in the CMS tank farm that was not labeled as used oil. APPENDIX 2. PHOTOS FROM CMS 3/26 RESPONSE  Outlook RE: Follow-up from EPA Inspection on 3/24/25 From scarpenter@coralmarineservices.net <scarpenter@coralmarineservices.net> Date Wed 3/26/2025 11:10 AM To Vince Damiano <Vince.Damiano@erg.com> Cc Janosh Wolters <janosh.wolters@erg.com>; 'Young-Dahl, Erin' <YoungDahl.Erin@epa.gov>; 'Penland, John' <Penland.John@epa.gov>; Jackie Cheramie <jcheramie@coralmarineservices.net> @7 attachments (12 MB) IMG_20250326_093417 (1).heic; IMG_20250326_093417 (2).heic; IMG_20250326_093417 (3).heic; IMG_20250326_093417 (4).heic; IMG_20250326_093417 (5).heic; IMG_20250326_093417.heic; IMG_20250326_093418.heic; Vince, CAUTION : Don't open links or attachments unless you recognize the sender and know they are safe. Please find attached photos showing that all the tankage that is/ or may be used for "Used Oil" have been labeled as such. We have magnetic signs that will be put in use for the future, they should be in next week. We do not have a MARPOL COA Regards, Sean Carpenter General Manager Coral Marine Services, LLC (C) 985-312-6444 scarpenter@coralmarineservices.net From: Vince Damiano <Vince.Damiano@erg.com> Sent: Monday, March 24, 2025 4:55 PM To: scarpenter@coralmarineservices.net Cc: Janosh Wolters <janosh.wolters@erg.com>; Young-Dahl, Erin <YoungDahl.Erin@epa.gov>; Penland, John <Penland.John@epa.gov> Subject: Follow-up from EPA Inspection on 3/24/25 Hello Sean, I am following up with a list of items and notes from our inspection today. Below are initial Areas of Concern and items requested; you may follow up with pictures, write-ups, sample results, or however you see fit: Unlabeled used oil frac tanks If applicable, a copy of your MARPOL COA Again, thank you for taking the time out of your day to meet with us. Please let us know if you have any questions or concerns. 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