Document n99obprLJjr3B9bDj1r3yyN22

f t E A ~ United States ..~ . Environmental Protection ~, Agency EPA REGION 6 Enforcement Division INSPECTION REPORT Inspection Entry Date/Time 6/19/2025 09:50 AM (CT) Inspection Exit Date/Time 6/19/2025 10:40 AM (CT) Regulatory Program Type of Inspection RCRA Compliance Evaluation Inspection (CEI) Announced: Yes (tenants and related facilities) 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 Crossroad Carries (dba Cedar Marine Terminals) TXR000062273 200 Atlantic Pipeline Road Baytown, TX 77523 Chambers County Non-generator, Transporter only 48422 Cedar Marine Terminals (CMT) accepts used oil from various vendors. Before transport via barge, CMT stores the used oil in aboveground storage tanks. 29.6712, -94.9264 Additional Persons Participating in Inspection: Name Title Organization Andrew Swingler Contractor Eastern Research Group (ERG) Email Andrew.Swingler@erg.com Phone (717) 357-6661 Lead Inspector: Janosh Wolters Janosh ERG Ite rs W O Digitally signed by Janosh Wolters Date: 2025.07.23 20:12:19 -04'00' IJanosh.Wolters@erg.com (484) 678-8675 Page 1 of 4 Cedar Marine Terminals Inspection Date: 6/19/2025 SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection The Port of Cedar Bayou 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 Chemical Engineer/ Contractor/ERG Cedar Marine Terminals/Director of Regulatory Affairs Cedar Marine Terminals/Operations Supervisor Cedar Marine Terminals/Terminal Manager Name Janosh Wolters Andrew Swingler Scott Ehrlich Mark Hallmark Neil Ligertwood Opening Conf. Closing Conf. Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Page 2 of 4 Cedar Marine Terminals Inspection Date: 6/19/2025 Facility General Description Tenant/Area Cedar Marine Terminals Inspection Date Process Description 6/19/2025 CMT collects used oil from various vendors and stores used oil in aboveground storage tanks prior to transport via barge to their facility in Marrero, Louisiana. The facility does not maintain a MARPOL COA. Area of Concern No SECTION II - OBSERVATIONS Facility: Cedar Marine Terminals Section: 2.1 Date: 6/19/2025, 09:50 AM Contains AOC: No Contains CBI: No I I Lead Inspector: Janosh Wolters Attendees: Scott Ehrlich (Director of Regulatory Affairs), Mark Hallmark (Operations Supervisor), and Neil Ligertwood (Terminal Manager) CMT, located in Baytown, TX operates a marine terminal that collects used oil from various vendors. CMT receives used oil by truck and transfers the used oil to Marerro, LA, owned by the same parent company, by private barge. CMT operates as a transfer facility of used oil collecting and accumulating from various customers. All used oil on site in above-ground storage tanks. The facility has four tanks with a capacity to hold 13,000 barrels each, two tanks with a capacity of 10,000 barrels each, and two tanks with a capacity of 2,000 barrels each. CMT/Crossroad Carries is owned by parent company Vertex Energy Inc. and does business as CMT. CMT stores used oil in tanks prior to transferring the used oil by barge to a separate Vertex Energy Inc. facility in Marrero, Louisiana where the used oil is re-refined. CMT uses MPX-420 and MPX-429 barges in conjunction with either the Brendon Livingston or Brendon Crystal tugboats. CMT operates one dock space, approximately 300 feet in length, for their barges (see Appendix 1, Photo 1). CMT does not allow other vessels to use the dock space. It is exclusively used for CMT's barges for the transportation of used oil. CMT does not generate or accumulate any other RCRA-regulated waste on site. CMT is registered with the EPA as a transporter of hazardous waste and a transporter of used oil under EPA ID TXR000062273. After the opening conference, the inspection team observed CMT's used oil tanks. All used oil tanks were labeled "Used Oil" and had adequate secondary containment (see Appendix 1, Photo 2). Additionally, the inspection team observed a 300-foot dock (see Appendix 1, Photo 1). The used oil is pumped via direct piping from used oil tanks onto the barge's tanks. All used oil shipments are tracked using internal tracking software. Mr. Ehrlich explained that used oil is not stored on site longer than 30 days. The inspection team viewed the tracking software on site and observed that the throughput of inbound vs outbound shipments usually show used oil is not stored on site longer than two weeks. The total amount of used oil being stored on site at the time of the inspection was 24,000 barrels. The inspection team did not observe any areas of concern (AOCs) at the time of the inspection. However, further EPA review may change or add to their potential AOCs. A closing conference was conducted at approximately 10:40 AM with CMT personnel. Page 3 of 4 Cedar Marine Terminals Inspection Date: 6/19/2025 SECTION III - RECORDS REVIEW No RCRA-regulated records were reviewed during this focused on-site inspection. SECTION IV - AREAS OF CONCERN No AOCs were identified at the time of the inspection. SECTION IV - FOLLOW UP Not Applicable Communication Log 24 hours prior to the on-site inspection, Erin Young-Dahl from EPA Region 6 notified the facility that ERG would be performing a CEI on 6/19/2025. SECTION VI - LIST OF APPENDICES Appendix 1. Photograph Log Page 4 of 4 APPENDIX 1. PHOTOGRAPH LOG UNITED STATES ENVIRONMENTAL PROTECTI ON AGENCY Photograph Log Location: Cedar Marine Terminals City: Baytown ICounty/Parish: Chambers County State: Texas I Photo No. 1 Photo File Name: DSCN8775.JPG Date of Photo: 6/19/2025 Time of Photo: 1023 hrs. Photographer: Janosh Wolters Description: View of SMT's 300-foot dock used to for used oil transport services. UNITED STATES ENVIRONMENTAL PROTECTI ON AGENCY Photograph Log Location: Cedar Marine Terminals City: Baytown County/Parish: Chambers County I State: Texas I Photo No. 2 Photo File Name: DSCN8776.JPG Date of Photo: 6/19/2025 Time of Photo: 1026 hrs. Photographer: Janosh Wolters Description: View of a 13,000-barrel tank accumulating used oil. This was taken as an example of how used oil tanks were observed during the visual inspection. All tanks were labeled with the words "Used Oil" and had adequate secondary containment.