Document MM98p89BdBgN7Q5XNaazqD35j

Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 6 Enforcement Division INSPECTION REPORT 04/15/2024 10:00 (CT) 04/15/2024 11:10 (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 Logistec Terminals N/A 150 Marine St Bldg 200 C Lake Charles, LA 70601 Calcasieu Parish None N/A Logistec Terminals unloads cargo including lumber and rice from vessels. 30.217528, -93.251604 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 22:38:01 -04'00' Digitally signed by Cameron Tanaka 07/24/2024 ERG Cameron.Tanaka@erg.com (703) 633-1632 ext. 11632 Page 1 of 6 Logistec Terminals Inspection Date(s): 04/15/2024 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 6 Logistec Terminals Inspection Date(s): 04/15/2024 Facility General Description Tenant/Area Logistec Terminals Inspection Date 04/15/24 Process Description Logistec Terminals (Logistec) unloads materials including lumber and rice from vessels. They do not load or unload any hazardous waste or waste in general. They mostly generate waste such as dunnage and general trash, used oil, used oil filters, and bilge water in their mechanic shop. They do not have their own MARPOL COA, as it is handled by the Port of Lake Charles (POLC) Area of Concern Yes Page 3 of 6 Logistec Terminals Inspection Date(s): 04/15/2024 SECTION II - OBSERVATIONS Tenant: Logistec Terminals Section: 2.1 Date: 04/15/24, 10:00 AM Contains AOC: Yes Contains CBI: No Lead Inspector: Cameron Tanaka Attendees: Jeffery Swan (Terminal Superintendent) Logistec is located on City Docks, which is owned by POLC. Logistec unloads materials including lumber and rice from vessels. They do not load or unload any hazardous waste or waste in general. They primarily generate waste such as dunnage and general trash, which are disposed of in the port's dumpsters. They also generate used oil, used oil filters, and oily water in their mechanic shop. Their used oil is generated through maintenance on their forklifts and the oily water is generated from their mechanics power washing their forklifts. These materials are held in plastic totes and are all taken off-site by a third-party transporter. According to Mr. Swan, their used oil, bilge water, and used oil filter containers are filled up then shipped off about once per year. They also generate used batteries which are sent back to the battery manufacturer. Logistec does not have a MARPOL COA from the USCG as the POLC holds the COA that covers the whole port. They also do not have an EPA ID number. During the inspection, the inspection team visually inspected Logistec's maintenance warehouse where used oil and other wastes are stored. The inspection team viewed Logistec's used oil filter drum (see Appendix 1 - Photo 1). The inspection team also viewed the facility's used oil and bilge water totes (see Appendix 1 - Photo 2). The inspection team viewed one of their used oil filter containers without secondary containment (see Appendix 1 - Photo 3). In a follow-up email from Mr. Swan (see Appendix 2), a photo was provided showing that secondary containment was added to this used oil filter drum (see Appendix 3 - Photo 1). The inspection team noted that their used batteries were not dated and labeled as "bad" rather than as "used batteries" (see Appendix 1 - Photos 4 and 5) [AOC #1 - Logistec 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 - Logistec 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)]. Logistec personnel immediately added labels to their batteries (see Appendix 1 - Photo 6). In a follow-up email from Mr. Swan (see Appendix 2), a photo was provided showing that these labels and dates were added to all of these batteries (see Appendix 3- Photo 2). The inspection team did not observe any other AOCs at the time of the inspection. A closing conference was conducted at approximately 11:00 AM with Mr. Swan. The inspection team departed at 11:10 AM. Page 4 of 6 Logistec Terminals Inspection Date(s): 04/15/2024 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: Logistec Terminals AOC #1 - Logistec 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: 2.2 AOC #2 - Logistec 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. Citation: 40 CFR 273.15(c) Section 2.2 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. 05/28/24 Logistec email - Jeffery Swan sent an email with photographs of corrective actions implemented at the site. Page 5 of 6 Logistec Terminals SECTION VI - LIST OF APPENDICES Appendix 1. Photograph Log Appendix 2. Follow-Up Email from Logistec Terminals Appendix 3. Follow-Up Photographs from Logistec Terminals Inspection Date(s): 04/15/2024 Page 6 of 6 APPENDIX 1. PHOTOGRAPH LOG UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Logistec Terminals City: Lake Charles Photo No. 1 County/Parish: Calcasieu State: Louisiana Photo File Name: DSCN7167 Date of Photo: 04/15/2024 Time of Photo: 10:34 hrs. Photographer: Anshul Paripati Description: View of Logistec's used oil filter drum in their maintenance shop. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Logistec Terminals City: Lake Charles Photo No. 2 County/Parish: Calcasieu State: Louisiana Photo File Name: DSCN7168 Date of Photo: 04/15/2024 Time of Photo: 10:35 hrs. Photographer: Anshul Paripati Description: View of Logistec's used oil and oily water totes in their maintenance shop. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Logistec Terminals City: Lake Charles Photo No. 3 County/Parish: Calcasieu State: Louisiana Photo File Name: DSCN7169 Date of Photo: 04/15/2024 Time of Photo: 10:36 hrs. Photographer: Anshul Paripati Description: View of Logistec's used oil filter drum without secondary containment in their maintenance shop. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Logistec Terminals City: Lake Charles Photo No. 4 County/Parish: Calcasieu State: Louisiana Photo File Name: DSCN7170 Date of Photo: 04/15/2024 Time of Photo: 10:43 hrs. Photographer: Anshul Paripati Description: View of Logistec's used batteries labeled as "bad" in their maintenance shop. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Logistec Terminals City: Lake Charles Photo No. 5 County/Parish: Calcasieu State: Louisiana Photo File Name: DSCN7171 Date of Photo: 04/15/2024 Time of Photo: 10:47 hrs. Photographer: Anshul Paripati Description: Another view of Logistec's used batteries labeled "bad" in their maintenance shop. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Logistec Terminals City: Lake Charles Photo No. 6 County/Parish: Calcasieu State: Louisiana Photo File Name: DSCN7172 Date of Photo: 04/15/2024 Time of Photo: 10:54 hrs. Photographer: Anshul Paripati Description: View of Logistec's used batteries with added dates in their maintenance shop. APPENDIX 2. FOLLOW-UP EMAIL FROM LOGISTEC TERMINALS Appendix 2 Page 1 of 3 Appendix 2 Page 2 of 3 Appendix 2 Page 3 of 3 APPENDIX 3. FOLLOW-UP PHOTOGRAPHS FROM LOGISTEC TERMINALS Appendix 3 Page 1 of 2 Appendix 3 Page 2 of 2