Both in violation of federal and state laws, and the conditions and terms of discharge permits. Lots of violations go unaddressed for whatever reason.
Buckets are overfilled spilling cargo during the transfer, and the lips of the buckets don’t seal allowing cargo to fall into the water during transfer. This is a violation of at least federal permits, regs and laws.
Overfilled, spilling buckets are not lowered as low as possible, not even the minimum of at least 2 feet below the coaming, before being opened. This causes your air discharges onto other people’s property in violation of permit conditions and terms, regs and laws.
Spilled cargo accumulates on the deck of the vessels being loaded/unloaded. Instead of following Best Management Practices as required by at least the VGP and Annex V (shoveling, sweeping, vacuuming and otherwise recovering all spilled cargo and returning it to the hold or properly contained for proper disposal), they sweep/shovel it over the sides. The same goes for the barges being unloaded/loaded.
Yes, there’s a lot of dumping of cargo and/or otherwise garbage at the elevators.