Document 3KxbeONB2odG5YzBEmL8Qx5a

f t E A ~ United States ..~ . Environmental Protection ~, Agency EPA REGION 6 Enforcement Division INSPECTION REPORT Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection 06/18/2025 1:10 PM (CT) Announced: Yes 06/18/2025 1:55 PM (CT) Access: Granted RCRA Compliance Evaluation Inspection (CEI) 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 Bludworth Marine LLC TXR000084316 2599 S. Childers Rd Orange, TX 77630 Orange Not a generator 336611 Bludworth Marine LLC (BM) performs repairs and maintenance on marine vessels. 2946'32.15"N, 95 6'8.72"W Additional Persons Participating in Inspection: Name Title Organization Andrew Swingler Contractor Eastern Research Group (ERG) Email Andrew.Swingler@erg.com Lead Inspector: Janosh Wolters Date: 2025.07.23 20:13:13 -04'00' Digitally signed by Janosh Wolters Janosh Wolters Contractor Eastern Research Group (ERG) Janosh.Wolters@erg.com Page 1 of 4 Bludworth Marine LLC Inspection Date: 06/18/2025 SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection The Port of Orange and surrounding facilities were selected for inspection based on a 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, portrelated facilities, and other 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 Environmental Protection Agency (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 Manager/Bludworth Marine LLC Safety/Bludworth Marine LLC Name Janosh Wolters Andrew Swingler Linwood Boudreaux Moses Garza Opening Conf. Closing Conf. Yes Yes Yes Yes Yes Yes Yes Yes Page 2 of 4 Bludworth Marine LLC Inspection Date: 06/18/2025 Facility General Description Tenant/Area Bludworth Marine LLC Inspection Date Process Description 6/18/2025 BM performs repairs and maintenance on marine vessels. The facility maintains a MARPOL COA but does not transfer or transport wastes off ships. Area of Concern Yes SECTION II - OBSERVATIONS Facility: Bludworth Marine LLC Section: 2.1 Date: 06/18/25, 1:10 PM Contains AOC: Yes Contains CBI: No I I Lead Inspector: Janosh Wolters Attendees: Linwood Boudreaux and Moses Garza BM, located in Orange, TX, conducts repairs and maintenance of marine vessels. The facility operates a dry dock and has travel lift capabilities for vessel repair projects. Mr. Boudreaux stated that the primary waste stream generated at the facility is used oil generated from routine maintenance on BM's equipment. Additionally, Mr. Boudreaux explained that BM occasionally generates paint waste from touch-up painting on vessels. BM was not generating or accumulating paint waste at the time of the inspection. In cases where a vessel requires tank cleaning prior to maintenance, BM performs the cleaning and manages the waste generated during the process. BM primarily cleans out bilges. BM manages waste generated from bilges as used oil. BM does not clean out tanks that generate hazardous wastes as they are not able to manage to manage hazardous waste. BM is registered with the EPA as a non-generator of hazardous waste under EPA ID TXR000084316. The facility maintains a MARPOL COA but does not transfer or transport wastes off ships. After the opening conference, the inspection team observed BM's used oil and waste storage area. The inspection team observed approximately twelve 325-gallon totes accumulating wash water from tank cleaning operations. Mr. Boudreaux stated the facility also stores used oil in this location but did not have any used oil on site at the time of the inspection. The inspection team visually observed one tote labeled as "Used Oil". Mr. Boudreaux stated this was incorrectly labeled and was accumulating dirty wash water. Next, the inspection team observed two lead acid batteries that were being managed as universal waste. The batteries were not labeled and did not have an accumulation start date. (see Appendix 1 - Photo 2) [AOC #1 - BM did not label individual batteries or their containers "Universal Waste-Battery(ies)," or "Waste Battery(ies)," or "Used Battery(ies)"- 40 CFR 273.14(a)] and [AOC #2 - BM did not demonstrate the length of time that the universal waste has been accumulated from the date it becomes waste - 40 CFR 273.15(c)] Next, the inspection team observed the dock space. BM was working on one vessel at the time of the visual inspection. The inspection team did not observe any waste being accumulated at the dock space. Mr. Boudreaux stated that waste that is generated during vessel repairs is brought directly to the waste accumulation area. The areas of concern (AOCs) observed by the inspection team at the time of the inspection are documented above. However, upon further review, EPA may change or add additional AOCs. A closing conference was conducted at approximately 1:55 PM with BM personnel. The AOC was communicated during the closing. Page 3 of 4 Bludworth Marine LLC Inspection Date: 06/18/2025 SECTION III - RECORDS REVIEW No RCRA-regulated records were reviewed during this focused on-site inspection. SECTION IV - AREAS OF CONCERN The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation. Facility: Bludworth Marine LLC AOC #1 - BM did not label individual batteries or their Citation: 40 CFR 273.14(a) containers "Universal Waste-Battery(ies)," or "Waste Battery(ies)," or "Used Battery(ies)." Section: 2.1 AOC #2 - BM did not demonstrate the length of time Citation: 40 CFR 273.15(c) that the universal waste has been accumulated from the date it becomes waste - 40 CFR 273.15(c). 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 the provision of documents requested. Communication Log 24 hours prior to the on-site inspection, Erin Young-Dahl (EPA Region 6) notified the Port of Orange that ERG would be performing on-site inspections throughout the Port area. The Port of Orange notified BM that ERG would be performing at CEI at the facility in the afternoon on 6/18/2025. SECTION VI - LIST OF APPENDICES Appendix 1. Photograph Log Page 4 of 4 APPENDIX 1. PHOTOGRAPH LOG Location: Bludworth Marine LLC City: Baytown County/Parish: Harris State: Texas Photo No. 1 Photo File Name: DSCN8772 Date of Photo: 6/18/2025 Time of Photo: 1330 hrs. Photographer: Janosh Wolters Description: View of the universal waste collected on site in the waste storage area. The batteries were not labeled and did not have an accumulation start date. Location: Bludworth Marine LLC City: Baytown County/Parish: Harris State: Texas Photo No. 2 Photo File Name: DSCN8773 Date of Photo: 6/23/2025 Time of Photo: 1331 hrs. Photographer: Janosh Wolters Description: Overview of waste storage area. Mr. Boudreaux stated all totes are accumulating wash water from washing vessels.