Document RjODzLoM6mpwN0oXQ252anKrk

Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 6 Enforcement Division INSPECTION REPORT 04/18/2024 9:15 (CT) 04/18/2024 10:30 (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 Southern Devall N/A 2244 Swisco Rd Sulphur, LA 70665 Calcasieu Parish None N/A Southern Devall provides diesel services for in-house and third-party barges. This location also acts as an administrative building for their entire company. 30.208647, -93.331751 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 22:18:25 -04'00' Digitally signed by Cameron Tanaka 07/24/2024 ERG Cameron.Tanaka@erg.com (703) 633-1632 ext. 11632 Page 1 of 6 Southern Devall 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 6 Southern Devall Inspection Date(s): 04/18/2024 Facility General Description Tenant/Area Southern Devall Inspection Date 04/18/24 Process Description Southern Devall (Devall) has three divisions: marine (providing inland boats and tugboat services), diesel and generator services, and fleeting services. The facility inspected included an administration building and diesel services. Devall services in-house barges and external companies' barges. They perform services including maintenance, engine overhauls, and engine repairs. They do not have a MARPOL COA. Area of Concern Yes Page 3 of 6 Southern Devall Inspection Date(s): 04/18/2024 SECTION II - OBSERVATIONS Tenant: Southern Devall Section: 2.1 Date: 04/18/24, 9:15 AM Contains AOC: Yes Contains CBI: No Lead Inspector: Cameron Tanaka Attendees: Carlin Chapman (EVP-HSSE&C) and David Devall (GM Devall Diesel) Southern Devall (Devall) operates with three divisions: marine, diesel and generators, and fleeting. Their marine division operates 68 vessels and 8 to 9 contract vessels consisting of inland boats and tugboats. This location included Devall's administration building and diesel services building. Their diesel services building services in-house and external companies' vessels. This includes maintenance, engine overhauls, engine repairs, and providing new engines. They have not performed any barge cleaning since 1999. They generate used oil and universal waste such as used antifreeze through these services. These are contained in drums and totes until they are filled. Once filled, these wastes are recycled or sent off site through third party transporters. The inspection team reviewed a used oil bill of lading from Action Oil and found no issues. Devall strips paint during engine overhauls and these waste paints are put into containers. Used batteries and fluorescent lamps are disposed of by a third party. They also operate parts washers with solvents in their diesel services building which are recycled by the solvent vendor. No waste is generated by these parts washers. No waste is taken off ships by Devall. Devall does not have an EPA ID and they follow the MARPOL regulations but do not have a MARPOL COA. The inspection team then performed a walk-through of Devall's diesel services building. The team observed that Devall had two used oil totes labelled as "oil only" and one container of oily rags labelled as "oil rags only" (see Appendix 1 - Photos 1, 2, 5, 6, 9, and 10). [AOC #1 - Devall did not clearly label containers used to store used oil with the words "Used Oil" - 40 CFR 279.22(c)(1)] Mr. Chapman provided a follow-up email on May 2 (see Appendix 2). This follow-up email included updated pictures of these used oil containers (see Appendix 3 - Photos 9, 10, and 11). Devall's used antifreeze tote was labelled as "coolent only" (see Appendix 1 - Photos 3 and 4). [AOC #2 - Devall did not label or mark clearly their used antifreeze with one of the following phrases: "Universal Waste- Antifreeze," or "Waste Antifreeze," or "Used Antifreeze."- La. Admin. Code tit. 33, V-3823 A.8.] Devall's follow-up email included an updated picture of this container (see Appendix 3 - Photo 8). The follow-up email also included a picture of their universal waste battery area (see Appendix 3 - Photo 1) and pictures of their garbage cans with added general waste labels (see Appendix 3 - Photo 2-7). The inspection team also observed a tote for used oil with a drum lid acting as its cap (see Appendix 1 - Photos 7 and 8). The inspection team did not observe other AOCs at the time of the inspection. A closing conference was conducted at approximately 3:45 PM with Devall personnel. The inspection team requested waste manifests for used oil, paint stripped from engines, fluorescent lamps, parts washer fluid, used batteries, and used coolant. The AOCs were communicated during the closing. In their follow-up email (see Appendix 2), Devall personnel followed up with manifests for used oil filters and absorbents, used batteries, parts washer fluids, and fluorescent lamps (see Appendix 4). There were no issues noted related to these manifests. Page 4 of 6 Southern Devall 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: Southern Devall AOC #1 - Devall did not clearly label containers used Citation: 40 CFR 279.22(c)(1) to store used oil with the words "Used Oil." Section: 2.10 AOC #2 - Devall did not label or mark clearly their used antifreeze with one of the following phrases: "Universal Waste- Antifreeze," or "Waste Antifreeze," or "Used Antifreeze." Citation: La. Admin. Code tit. 33, V- Section: 2.10 3823 A.8. SECTION V - CLOSING CONFERENCE AND 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. 05/02/24 Southern Devall email - Carlin Chapman sent an email containing the documents requested during the inspection and several photographs of corrective actions implemented at the site. Page 5 of 6 Southern Devall SECTION VI - LIST OF APPENDICES Appendix 1. Photograph Log Appendix 2. Follow-Up Email from Southern Devall Appendix 3. Follow-Up Photographs from Southern Devall Appendix 4. Southern Devall Waste Manifests Inspection Date(s): 04/18/2024 Page 6 of 6 APPENDIX 1. PHOTOGRAPH LOG UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Southern Devall City: Sulphur Photo No. 1 County/Parish: Calcasieu State: Louisiana Photo File Name: DSCN7183 Date of Photo: 04/18/2024 Time of Photo: 08:53 hrs. Photographer: Anshul Paripati Description: Used oil tote labeled as "oil only" in Devall's diesel services building. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Southern Devall City: Sulphur Photo No. 2 County/Parish: Calcasieu State: Louisiana Photo File Name: DSCN7184 Date of Photo: 04/18/2024 Time of Photo: 08:53 hrs. Photographer: Anshul Paripati Description: Closeup of "oil only" label on used oil tote in Devall's diesel services building. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Southern Devall City: Sulphur Photo No. 3 County/Parish: Calcasieu State: Louisiana Photo File Name: DSCN7185 Date of Photo: 04/18/2024 Time of Photo: 08:56 hrs. Photographer: Anshul Paripati Description: Antifreeze tote labeled as "Coolent only" in Devall's diesel services building. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Southern Devall City: Sulphur Photo No. 4 County/Parish: Calcasieu State: Louisiana Photo File Name: DSCN7186 Date of Photo: 04/18/2024 Time of Photo: 08:56 hrs. Photographer: Anshul Paripati Description: Closeup of "Coolent only" label on used antifreeze tote in Devall's diesel services building. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Southern Devall City: Sulphur Photo No. 5 County/Parish: Calcasieu State: Louisiana Photo File Name: DSCN7187 Date of Photo: 04/18/2024 Time of Photo: 08:57 hrs. Photographer: Anshul Paripati Description: Used oil tote labeled as "oil only" in Devall's diesel services building. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Southern Devall City: Sulphur Photo No. 6 County/Parish: Calcasieu State: Louisiana Photo File Name: DSCN7188 Date of Photo: 04/18/2024 Time of Photo: 08:57 hrs. Photographer: Anshul Paripati Description: Closeup of "oil only" label on a used oil tote in Devall's diesel services building. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Southern Devall City: Sulphur Photo No. 7 County/Parish: Calcasieu State: Louisiana Photo File Name: DSCN7189 Date of Photo: 04/18/2024 Time of Photo: 08:58 hrs. Photographer: Anshul Paripati Description: Overview of tote for waste oil with a drum lid acting as its cap in Devall's diesel services building. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Southern Devall City: Sulphur Photo No. 8 County/Parish: Calcasieu State: Louisiana Photo File Name: DSCN7190 Date of Photo: 04/18/2024 Time of Photo: 08:58 hrs. Photographer: Anshul Paripati Description: Closeup of a drum lid acting as a cap for a tote for waste oil in Devall's diesel services building. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Southern Devall City: Sulphur Photo No. 9 County/Parish: Calcasieu State: Louisiana Photo File Name: DSCN7191 Date of Photo: 04/18/2024 Time of Photo: 09:03 hrs. Photographer: Anshul Paripati Description: Used oil rags container labeled as "oil rags only" in Devall's diesel services building. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Southern Devall City: Sulphur Photo No. 10 County/Parish: Calcasieu State: Louisiana Photo File Name: DSCN7192 Date of Photo: 04/18/2024 Time of Photo: 09:03 hrs. Photographer: Anshul Paripati Description: Closeup of "oil rags only" label on a used oil rags container in Devall's diesel services building. APPENDIX 2. FOLLOW-UP EMAIL FROM SOUTHERN DEVALL Appendix 2 Page 1 of 2 Appendix 2 Page 2 of 2 APPENDIX 3. FOLLOW-UP PHOTOGRAPHS FROM SOUTHERN DEVALL Appendix 3 Page 1 of 11 Appendix 3 Page 2 of 11 Appendix 3 Page 3 of 11 Appendix 3 Page 4 of 11 Appendix 3 Page 5 of 11 Appendix 3 Page 6 of 11 Appendix 3 Page 7 of 11 Appendix 3 Page 8 of 11 Appendix 3 Page 9 of 11 Appendix 3 Page 10 of 11 Appendix 3 Page 11 of 11 APPENDIX 4. SOUTHERN DEVALL WASTE MANIFESTS Appendix 4 Page 1 of 5 Appendix 4 Page 2 of 5 Appendix 4 Page 3 of 5 Appendix 4 Page 4 of 5 Appendix 4 Page 5 of 5