Document Nr2jXRRdjjN4e2q8Q30kz2GR

Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 6 Enforcement Division INSPECTION REPORT 6/5/2024 10:25 AM (CT) 6/5/2024 11:30 AM (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 Holdings, LLC LAR000054148 120 17th St Golden Meadow, LA 70357 Lafourche Parish VSQG 213112 Martin Holdings, LLC operates a cargo terminal at Port Fourchon 29.114936, -90.206714 Additional Persons Participating in Inspection: Name Title Organization Email Phone Joyce Johnson Inspector EPA REGION 6 Johnson.Joyce-r6@epa.gov (214) 665-8548 Dedriel Gardner Inspector EPA REGION 6 Gardner.Dedriel@epa.gov (281) 983-2133 Neil Rapp Contractor Eastern Research Neil.Rapp@erg.com Group (ERG) (480) 450-6517 Lead Inspector: Vince Damiano Vincent Damiano ERG Digitally signed by Vincent Damiano Date: 2024.09.09 17:51:51 -04'00' Vince.Damiano@erg.com (703) 835-6281 1 of 5 Martin Holdings, LLC Inspection Date: 06/05/2024 SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection Type of inspection: Focused Compliance Inspection (FCI) Port Fourchon 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 maintaining 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 verbal or written statements made during or after the on-site inspection, and 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 Name Lead Inspector/ Contactor/ERG RCRA Inspector/ Contractor/ERG Inspector/Enforcement Officer/EPA Region 6 Inspector/Enforcement Officer/EPA Region 6 Vince Damiano Neil Rapp Joyce Johnson Dedriel Gardner Phone Email (703) 835-6281 Vince.Damiano@erg.com Opening Conf. Yes Closing Conf. Yes (480) 450-6517 Neil.Rapp@erg.com Yes Yes (214) 665-8548 Johnson.Joyce-r6@epa.gov Yes Yes (281) 983-2133 Gardner.Dedriel@epa.gov Yes Yes 2 of 5 Martin Holdings, LLC Facility General Description Inspection Date: 06/05/2024 Tenant/Area Martin Holdings, LLC Inspection Date 06/05/24 Process Description Martin Holdings, LLC (Martin) operates a cargo terminal and has six tenants that it services. Martin loads and offloads vessels for tenants and does not allow third parties to use its dock space. Martin offloads waste including hazardous waste from vessels at its docks, but the tenants at the terminal manage the waste after offloading. The company does not store or manage any of the waste removed from vessels. Martin also unloads USDA-regulated (APHIS) waste from vessels, which it places directly into dumpsters. The dumpsters are managed by its tenants and their ship agents. Martin is a very small quantity generator (VSQG) of hazardous waste and maintains a MARPOL COA for Annexes I, II, and V. Areas of Concern No 3 of 5 Martin Holdings, LLC Inspection Date: 06/05/2024 SECTION II - OBSERVATIONS Tenant: Martin Holdings, LLC Section: 2.1 Date: 6/5/2024, 10:25 A.M. Contains AOC: No Contains CBI: No Lead Inspector: Vince Damiano Attendees: Joey Bouziga (General Manager), Matt Labat (QHSE Manager), Brittney Serigney (Environmental Supervisor) Martin personnel provided the inspection team with a summary of operations at the facility. Martin operates a cargo terminal and has six tenants (Talos Energy, Renaissance Offshore, Equinor, Arena Offshore, Enterprise Offshore, and Hilcorp) that it services. Martin mostly loads and offloads supplies and oil field equipment from vessels and trucks for its tenants. The facility does not allow third parties to use its dock space. Martin also offloads waste including hazardous waste from vessels using cranes or forklifts at its docks and immediately moves the waste to the tenants' leased areas, but the tenants at the terminal manage the waste after offloading. Martin stated they will rarely offload waste and the majority of their offloads are supplies and equipment. Martin does not store or manage any of the waste removed from vessels. In addition, Martin unloads APHIS waste from vessels, which it places directly into dumpsters for its tenants. The dumpsters are managed by its tenants and their ship agents. Martin maintains a MARPOL COA for Annexes I, II, and V. Martin is registered with EPA as a transfer facility for used oil (LAR000054163). However, Mr. Bouziga stated that Martin does not act as a used oil transfer facility and that Martin registered with EPA in anticipation of potential future operations. The facility is a VSQG of hazardous waste, mostly generated from day-to-day maintenance operations at the terminal (i.e., paint waste). Martin also generates used oil from equipment maintenance which it disposes of with American Recovery. After the opening conference, the inspection team conducted a visual inspection of the facility's dock space and warehouse. The inspection team also observed the bays on the individual tenants on the dock space where supplies and equipment are offloaded and placed for the tenants to manage. During the visual inspection, the inspection team did not observe any waste in the bays. No areas of concern (AOCs) were identified during the visual inspection; however, further EPA review may change or add to their potential AOCs. A closing conference was conducted at approximately 11:20 AM with Martin personnel. The inspection team requested a copy of the Martin's MARPOL COA, which Ms. Serigney provided on 6/6/2024. The COA can be found in Appendix 1. SECTION III - RECORDS REVIEW No RCRA regulated records were reviewed during this focused onsite inspection besides those mentioned in Section II. SECTION IV - AREA OF CONCERN No apparent AOCs were identified during this inspection. SECTION V -FOLLOW UP Documents or files provided by the facility were transmitted via email. 4 of 5 Martin Holdings, LLC Inspection Date: 06/05/2024 Communication Log After the inspection, additional information was emailed to EPA including: 1. 6/6/2024 GMS email - Brittney Serigney provided a copy of Martin's COA. SECTION VI - LIST OF APPENDICES Appendix 1 - Martin COA 5 of 5 Appendix 1 Martin COA