Document qmGzE34M6NNDejYRBRMazrenM

Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 6 Enforcement Division INSPECTION REPORT 04/17/2024 10:00 (CT) 04/17/2024 10:45 (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 Harbor Docking & Towing Co, LLC (HD&T) N/A 4957 Big Lake Rd Bldg A Lake Charles, LA 70605 Calcasieu Parish None N/A HD&T is a ship assist company that operates tugs that lead barges through Lake Charles and the surrounding waters. 30.167501, -93.282610 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 22:33:18 -04'00' Digitally signed by Cameron Tanaka 07/24/2024 ERG Cameron.Tanaka@erg.com (703) 633-1632 ext. 11632 Page 1 of 5 Harbor Docking & Towing Co, LLC Inspection Date(s): 04/17/2024 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, 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 5 Harbor Docking & Towing Co, LLC Inspection Date(s): 04/17/2024 Facility General Description Tenant/Area Harbor Docking & Towing Co., LLC Inspection Date 04/17/24 Process Description Harbor Docking & Towing Co., LLC (HD&T) is a ship assist company that operates six tugboats. These tugboats assist barges that come into the river leading into Lake Charles to get through the river into the docks/harbor. Their tugs generate garbage and oily water that is taken directly off the tugboats onto vacuum trucks. They do not have a MARPOL COA. Area of Concern No Page 3 of 5 Harbor Docking & Towing Co, LLC Inspection Date(s): 04/17/2024 SECTION II - OBSERVATIONS Tenant: Harbor Docking & Towing Co, LLC Section: 2.1 Date: 04/17/24, 10:00 AM Contains AOC: No Contains CBI: No Lead Inspector: Cameron Tanaka Attendees: Wesley Dugas (Vice President) and Doug Pierce (Marine Supervisor) Harbor Docking & Towing Co, LLC (HD&T) is a ship assist company that uses their seven tugboats to assist vessels and barges navigate through the rivers surrounding Lake Charles. Ship operators order their tugboats to help navigate under bridges and through shallow water and narrow passages, or to and from docks. For garbage, oily water, and used oil generated by their tugboats, vacuum trucks from Environmental Response Services (ERS) remove and transport the waste directly off the tugboats. They contract ERS for all maintenance related waste, including used oil. They contract ERS for fueling and disposal trucks as needed. They do not generate any universal waste through their operations. HD&T does not own their own dock and does not have a MARPOL COA. They also do not have an EPA ID number. No apparent AOCs were observed by the inspection team during the time of the inspection. A closing conference was conducted at approximately 10:35 AM with HD&T personnel. Page 4 of 5 Harbor Docking & Towing Co, LLC Inspection Date(s): 04/17/2024 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. HD&T did not have any Areas of Concern. 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 from HD&T was not requested. Page 5 of 5