Document zJwbDkd2BXb9K6nBmDYw2bXR

Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 6 Enforcement Division INSPECTION REPORT 07/18/2024 14:10 (CT) 07/18/2024 15:30 (CT) Announced: No (tenants and related facilities) 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 Gulf Gateway Terminal LLC N/A 7500 Terminal Rd New Orleans, LA 70126 Orleans Parish N/A 424480 Gulf Gateway Terminal stores renewable diesel fuels for customers and ships them out via rail. 30.0012, -89.9938 Additional Persons Participating in Inspection: Name Title Organization Dedriel Gardner Inspector EPA REGION 6 Joe Watson Contractor Eastern Research Group (ERG) Email Gardner.Dedriel@epa.gov Joe.Watson@erg.com Phone (281) 983-2133 (215) 891-6615 Lead Inspector: Vince Damiano Vincent Damiano ERG Digitally signed by Vincent Damiano Date: 2024.10.03 10:15:51 -04'00' Vince.Damiano@erg.com (703) 835-6281 Page 1 of 3 Gulf Gateway Terminal LLC Inspection Date: 07/18/2024 SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection The Port of New Orleans 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 Name Vince Damiano Phone Email (703) 835-6281 Vince.Damiano@erg.com Opening Conf. Yes Closing Conf. Yes Joe Watson (215) 891-6615 Joe.Watson@erg.com Yes Yes Dedriel Gardner (281) 983-2133 Gardner.Dedriel@epa.gov Yes Yes Facility General Description Tenant/Area Gulf Gateway Terminal LLC Inspection Date 07/18/24 Process Description Gulf Gateway Terminal (GGT) operates as a terminal and storage facility for renewable diesel fuels. The fuel arrives in barges and is offloaded into the GGT 115,000-barrel tank. From the storage tank, the fuels are hard piped to loading arms at the GGT rail stop and loaded into rail cars to be delivered to customers across the country. GGT operates under the Port of New Orleans' MARPOL COA. Area of Concern No Page 2 of 3 SECTION II - OBSERVATIONS Tenant: Gulf Gateway Terminal LLC Section: 2.1 Date: 07/18/24, 02:10 PM Contains AOC: No Contains CBI: No Lead Inspector: Vince Damiano Attendees: Brent Robertson (Manager) and Michael Wasgespack (Environmental Consultant) GGT is a tenant of the Port of New Orleans and operates as a terminal and storage facility for renewable diesel fuels. The fuel arrives in barges and is offloaded into the GGT 115,000-barrel tank. From the storage tank, the fuels are hard piped to loading arms at the GGT rail stop and loaded into rail cars to be delivered to customers across the country. GGT operates under the Port of New Orleans' MARPOL COA. GGT does not maintain an EPA ID as they do not generate or handle any regulated wastes. Mr. Robertson explained since GGT switched to handling only renewable diesel products made from soybean oil around 2021, the site only generates non-hazardous waste. Mr. Robertson informed the inspection team that GGT's storage tank was damaged in 2020 and all diesel products inside the tank had to be moved to barges for the tank to be repaired. When asked if any hazardous waste was generated from the tank repairs, Mr. Robertson said all waste was non-hazardous as the material the tank was holding at the time was sweet crude oil. Mr. Robertson said almost all the crude oil was able to be saved as product with the remainder of the waste generated from the incident was determined to be non-hazardous oil contaminated solids such as absorbents and soil. GGT had no storage areas. The inspection team did observe GGT's dock space from a distance as there was thunderstorms during the inspection and found no areas of concern (AOCs); however, further EPA review may change or add to their potential AOCs. A closing conference was conducted at approximately 3:30 PM with GGT personnel. SECTION III - RECORDS REVIEW No RCRA-regulated records were reviewed during this focused onsite inspection. SECTION IV - AREAS OF CONCERN Not Applicable SECTION V - FOLLOW UP No follow-up requested. Page 3 of 3