Document rpxM7bjp0kJKQoa17O0wamo27

i Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 6 Enforcement Division INSPECTION REPORT 05/21/2024 09:20 (CT) Announced: No 05/21/2024 11:45 (CT) Access: Granted RCRA Focused Compliance Inspection (FCI) 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 G&H Towing Company None 1420 Harbor Drive Corpus Christi, TX 78407 Nueces County N/A None G&H Towing Company provides ship docking and tugging of ships in Corpus Christi, operating 12 tugs. 27.811794, -97.408807 Additional Persons Participating in Inspection: Name Title Organization Cameron Tanaka Erin Young-Dahl Contractor Inspector Eastern Research Group (ERG) EPA REGION 6 John Penland Inspector EPA REGION 6 Email Cameron.Tanaka@erg.com YoungDahl.Erin@epa.gov Penland.John@epa.gov Phone (508) 314-6432 (214) 665-3166 (214) 665-9717 Lead Inspector: Brook McKeown ERG Brook.McKeown@erg.com 09/03/2024 (410) 459-5811 Page 1 of 5 G&H Towing Company SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection Inspection Date: 05/21/2024 The Port of Corpus Christi (POCC) 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, 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. Brook McKeown (410) 459-5811 Brook.McKeown@erg.com Yes No Cameron Tanaka (508) 314-6432 Cameron.Tanaka@erg.com Yes No Erin Young-Dahl (214) 665-3166 YoungDahl.Erin@epa.gov Yes Yes John Penland (214) 665-9717 Penland.John@epa.gov Yes Yes Page 2 of 5 G&H Towing Company Inspection Date: 05/21/2024 Facility General Description Tenant/Area G&H Towing Company Inspection Date 05/21/24 Process Description G&H Towing Company (G&H) operates a permanently moored barge to moor tugs. The company provides ship docking and tugging of ships in Corpus Christi, operating 12 tugs. G&H use their tugs to assist vessels, barges, and cargo ships going inbound and outbound of the port waterway. It does not provide any offloading or loading for these boats. G&H generates wastes including spent filters, oily rags, bilge slops, liquid paint waste, used batteries, and empty paint cans. Maintenance on its tugboats generating used oil is performed by a third party. The facility does not maintain a MARPOL COA. Area of Concern Yes Page 3 of 5 G&H Towing Company Inspection Date: 05/21/2024 SECTION II - OBSERVATIONS Tenant: G&H Towing Company Section: 2.1 Date: 05/21/24, 9:20 AM Contains AOC: Yes Contains CBI: No Lead Inspector: Brook McKeown Attendees: Tim Dement (Sr. PE) G&H operates a dock and a permanently moored barge to moor tugs at its property which is leased from the POCC. The company provides ship docking and tugging of ships in Corpus Christi, operating 12 tugs. G&H uses its tugs to assist vessels, barges, and cargo ships going inbound and outbound of the port waterway. The company does not provide any offloading or loading for these boats. Maintenance on its tugboats generating used oil is performed at John Bludworth Shipyard by a third party and G&H does not generate used oil at its Corpus Christi location. G&H generates wastes including spent filters, oily rags, bilge slops, liquid paint waste, used batteries, and empty paint cans at its Corpus Christi site. Gainco, Inc., a third-party vendor, handles and disposes of all of G&H's generated slops, used oil, and paint wastes. Kirby Inland Marine and Southwest Shipyard, third-party vendors, dispose of bilge slops and trash generated by G&H. Spent filters and oily rags are considered non-hazardous wastes. G&H has two containers for paint waste that are removed about every six months, or at most once a year. G&H does not have an EPA ID. G&H did not respond to the inspection team to clarify if they have a MARPOL COA. During the inspection, G&H personnel did not think they had one. During the inspection, the inspection team visually inspected G&H's warehouse and waste area. The warehouse held boat parts and supplies. The waste area contained spent filters, oily rags, bilge slops, used batteries, and liquid paint waste (see Appendix 1 - Photos 1 and 2). The inspection team observed five containers of engine slop/oily rags and one container of waste paint that were partially full and not labeled as to their contents [AOC #1 - G&H did not clearly label containers used to store waste paint with the words "Universal Waste: Paint and Paint Related Waste" - 30 TAC 335.262(c)(2)(F); AOC #2 - G&H did not clearly label containers used to store used oil with the words "Used Oil" - 40 CFR 279.22(c)(1)]. Mr. Dement indicated that when the liquid paint waste containers are about 75% full, a third party takes the container off-site. After the walk through, the inspection team observed G&H's log of wastes coming onsite and going offsite, a Gainco, Inc. oily waste profile from US Ecology, and a non-hazardous paint waste manifest from 2019. The inspection team noted no issues with these documents. A closing conference was conducted at approximately 11:30 AM with G&H personnel. During the closing conference, the inspection team communicated the AOCs and requested the following documents and clarifications: Confirmation on whether G&H has a MARPOL COA and a copy of it, if applicable; Shipping papers or manifests for the last two shipments of waste paint; The waste profile for the paint waste. Mr. Dement sent a follow-up email on 06/07/2024, which only included a non-hazardous waste manifest from May 2024 (see Appendix 2). The inspection team noted no issues with this manifest. Further EPA review may change or add potential AOCs. Page 4 of 5 G&H Towing Company Inspection Date: 05/21/2024 SECTION III - RECORDS REVIEW No RCRA-regulated records were reviewed during this focused onsite inspection. SECTION IV - AREAS OF CONCERN The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation. Tenant: G&H Towing Company AOC #1 - G&H did not clearly label containers used to Citation: 30 TAC 335.262(c)(2)(F) store waste paint with the words "Universal Waste: Paint and Paint Related Waste". Section: 2.1 AOC #2 - G&H did not clearly label containers used to Citation: 40 CFR 279.22(c)(1) 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. 06/07/24 G&H email - Tim Dement sent a non-hazardous waste manifest from May 2024. SECTION VI - LIST OF APPENDICES Appendix 1. Photograph Log Appendix 2. G&H Towing Non-Hazardous Waste Manifest from May 2024 Page 5 of 5 APPENDIX 1. PHOTOGRAPH LOG UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: G&H Towing Company City: Corpus Christi County/Parish: Nueces State: Texas Photo File Name: DSCN1079 Date of Photo: 05/21/2024 Time of Photo: 09:55 hrs. Photographer: Cameron Tanaka Description: Overview of G&H's waste area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: G&H Towing Company City: Corpus Christi County/Parish: Nueces State: Texas Photo File Name: DSCN1080 Date of Photo: 05/21/2024 Time of Photo: 09:55 hrs. Photographer: Cameron Tanaka Description: View of unlabeled container of paint waste in G&H's waste area. APPENDIX 2. G&H TOWING NON-HAZARDOUS WASTE MANIFEST FROM MAY 2024 Appendix 2 Page 1 of 1