Document 2Rr6Vnk04N89DgDdyZjwY5ooN
Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection
EPA REGION 6 Enforcement Division INSPECTION REPORT 04/19/2024 9:30 (CT) 04/19/2024 10:09 (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
Martin Energy Services LAR000067165 821 Henry Pugh Blvd Lake Charles, LA 70605 Calcasieu Parish Very Small Quantity Generator (VSQG) 42471 Martin Energy Services provides oil fueling and used oil reception services for barges and tugs on their docks. 30.10554, -93.304878
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 22:43:19 -04'00' Digitally signed by Cameron Tanaka
ERG
Cameron.Tanaka@erg.com
07/24/2024
(703) 633-1632 ext. 11632
Page 1 of 6
Martin Energy Services
Inspection Date(s): 04/19/2024
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
Martin Energy Services
Inspection Date(s): 04/19/2024
Facility General Description
Tenant/Area Martin Energy Services
Inspection Date
04/19/24
Process Description Martin Energy Services (Martin) provides oil fueling and used oil reception for barges and tugs on their docks. They operate storage tanks that either pump lube oil and diesel fuel to these vessels or receive used oil from the barges. They do not take any other materials/waste off boats besides general trash. They generate used oil, used oil filters, and oily rags. They do not have a MARPOL certificate.
Area of Concern
No
Page 3 of 6
Martin Energy Services
Inspection Date(s): 04/19/2024
SECTION II - OBSERVATIONS
Tenant: Martin Energy Services
Section: 2.1
Date: 04/19/24, 9:30 AM Contains AOC: No Contains CBI: No
Lead Inspector: Cameron Tanaka
Attendees: Charles Benoit (PIC)
Martin Energy Services (Martin) pumps lube oil and diesel fuel to barges, tugboats, and other vessels from their storage tanks through pipes and hoses. They also take used oil, oily debris, and general household trash off these vessels. Used oil from vessels is held in a used oil tank in the same area as their fuel storage tanks. They do not store used oil in drums. Used oil is transported off site by Holcomb Environmental Oil Services, LLC in Houston, TX or another third-party transporter using vacuum trucks approximately once a week. Martin also hires third-party mechanics to perform oil changes. These mechanics put the used oil in the same used oil storage tank. Martin stores oily debris and product material in drums. General household trash is disposed of in municipal dumpsters. Used batteries are returned to the supplier for their cores. Martin is classified as a used oil transfer, transporter, and a VSQG with EPA ID LAR000067165. They do not have a MARPOL COA.
Oil and Used Oil Storage Area
The inspection team then performed a walk-through of Martin's oil and used oil storage area. The team observed the facility's two used oil tanks which contained 4,789 and 1,953 gallons of used oil (see Appendix 1 - Photos 1 and 2). Each tank has a maximum capacity of 8,000 gallons. The team also observed the facility's 13 used oil filter drums (see Appendix 1 - Photos 3 and 4).
No apparent AOCs were observed by the inspection team during the time of the inspection. A closing conference was conducted at approximately 10:00 AM with Mr. Benoit. The inspection team requested the facility's EPA ID and confirmation that they do not have a MARPOL COA.
In their follow-up email (see Appendix 2), Mr. Benoit provided the facility's EPA ID and confirmed that they do not have a MARPOL COA.
Page 4 of 6
Martin Energy Services
Inspection Date(s): 04/19/2024
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. Martin 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 was emailed to EPA including: 1. 05/01/24 Martin email - Charles Benoit sent an email containing confirmation that Martin does not have a MARPOL COA and their EPA ID.
Page 5 of 6
Martin Energy Services
SECTION VI - LIST OF APPENDICES Appendix 1. Photograph Log Appendix 2. Follow-Up Email from Martin Energy Services
Inspection Date(s): 04/19/2024
Page 6 of 6
APPENDIX 1. PHOTOGRAPH LOG
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 1
Location: Martin Energy Services
City: Lake Charles
County/Parish: Calcasieu
State: Louisiana
Photo File Name: DSCN7203 Date of Photo: 04/19/2024 Time of Photo: 09:01 hrs. Photographer: Anshul Paripati Description: Overview of two used oil tanks in Martin's oil and used oil storage area.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 2
Location: Martin Energy Services
City: Lake Charles
County/Parish: Calcasieu
State: Louisiana
Photo File Name: DSCN7204 Date of Photo: 04/19/2024 Time of Photo: 09:01 hrs. Photographer: Anshul Paripati Description: Closeup view of a label on one of the two used oil tanks in Martin's oil and used oil storage area.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 3
Location: Martin Energy Services
City: Lake Charles
County/Parish: Calcasieu
State: Louisiana
Photo File Name: DSCN7205 Date of Photo: 04/19/2024 Time of Photo: 09:03 hrs. Photographer: Anshul Paripati Description: Overview of used oil filter drums in Martin's oil and used oil storage area.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 4
Location: Martin Energy Services
City: Lake Charles
County/Parish: Calcasieu
State: Louisiana
Photo File Name: DSCN7206 Date of Photo: 04/19/2024 Time of Photo: 09:03 hrs. Photographer: Anshul Paripati Description: Closeup view of one of the used oil filter drums in Martin's oil and used oil storage area.
APPENDIX 2. FOLLOW-UP EMAIL FROM MARTIN ENERGY SERVICES
Appendix 2 Page 1 of 1