Document 5b2R6kN7E3aEYQzydy7d7ov9R

f t E A ~ United States .._~ Environmen tal Pro tection ,., Age ncy Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 6 Enforcement Division INSPECTION REPORT 3/26/2025 14:40 (CT) Announced: No 3/26/2025 15:40 (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 United Mobility Systems DBA American Vacuum LAR000053033 1232 Siracusa Rd. Morgan City, LA 70380 St. Mary Non-generator 48411 American Vacuum (AV) is a used oil transporter and transfer facility that picks up used oil waste from barges, boats, and other facilities. 29.68976, -91.15636 Additional Persons Participating in Inspection: Name Title Organization John Penland Inspector EPA REGION 6 Erin Young-Dahl Inspector EPA REGION 6 Janosh Wolters Contractor Eastern Research Group (ERG) Email Penland.John@epa.gov Youngdahl.Erin@epa.gov Janosh.Wolters@erg.com Lead Inspector: Vince Damiano ERG Vincent Damiano Digitally signed by Vincent Damiano Date: 2025.05.01 16:03:30 -04'00' IVince.Damiano@erg.com Page 1 of 4 American Vacuum SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection Inspection Date: 3/26/2025 The Port of Morgan City 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, port related facilities, and other 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 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 Inspector/Enforcement Officer/EPA Region 6 Inspector/Enforcement Officer/EPA Region 6 RCRA Inspector/ Contractor/ERG American Vacuum/Owner American Vacuum/Foreman Name Vince Damiano John Penland Erin Young-Dahl Janosh Wolters Rob Guarisco Larry Guillory Sr. Email Vince.Damiano@erg.com Penland.John@epa.gov Youngdahl.Erin@epa.gov Janosh.Wolters@erg.com Americanvacuum1@gmail.com Americanvacuum1@gmail.com Opening Conf. Closing Conf. Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Page 2 of 4 American Vacuum Facility General Description Inspection Date: 3/26/2025 Tenant/Area American Vacuum Inspection Date Process Description 3/26/2025 AVis a used oil transporter and transfer facility that collects used oil waste from customers. American Vacuum does not operate under a MARPOL COA. Area of Concern Yes SECTION II - OBSERVATIONS Facility: American Vacuum Section: 2.1 Date: 3/26/2025, 14:40 Contains AOC: Yes Contains CBI: No I I Lead Inspector: Vince Damiano Attendees: Larry Guillory Sr. (Foreman) and Rob Guarisco (Manager / Owner) American Vacuum (AV), located in Morgan City, LA, operates as a used oil transporter and transfer facility. AV has three vacuum trucks, one 130-barrel and two 110-barrel, where employees collect waste oil, bilge water, and used oil from customers before bringing it back to the facility for storage. The used oil is consolidated into tanks at AV and then transported to Clean Harbors in White Castle for disposal. AV has 10 storage tanks ranging in capacity from 7,000 gallons to 20,000 gallons. AV will also store fuel for customers. AV is registered with the EPA as a used oil transporter and used oil transfer facility under EPA ID LAR000053033. After the opening conference, the inspection team observed AV's used oil storage operations. The inspection team first observed AV's used oil storage tanks. At the time of the inspection, Tank 1 (Appendix 1 - Photo 1, left) was storing 7,000 gallons of used oil; Tank 2 (Appendix 1 - Photo 1, right) was storing 4,000 gallons of used oil; Tank 3 (Appendix 1 - Photo 2, middle) was storing 3,000 gallons of used oil; Tank 4 (Appendix 1 - Photo 2, left) was empty; Tank 5 (Appendix 1 - Photo 3, middle) was empty; and Tank 6 (Appendix 1 - Photo 3, left) was storing 3,000 gallons of used oil. All of the used oil tanks were labeled as used oil, but the labels had faded and were not clearly visible [AOC #1 - AV did not clearly label containers and aboveground tanks used to store used oil with the words "Used Oil" - 40 CFR 279.45(g)(1)]. Next to the used oil tank farm, AV had a 20,000-gallon frac tank, which was storing 6,000 gallons of used oil (see Appendix 1 - Photo 4). The frac tank was unlabeled and was not in a form of secondary containment, a requirement for used oil transfer facilities [AOC #2 - AV did have a secondary containment system for containers and an aboveground tank used to store oil at a transfer facility - 40 CFR 279.45(f)] and [AOC #1]. The inspection team observed fifteen full 55-gallon drums containing used oil-contaminated filters and PPE to the right of the tank farm (see Appendix 1 - Photos 5 to 7). Mr. Guillory stated the drums have been on site for 30 days. The drums were not labeled as used oil and were not in secondary containment [see AOC #1 and AOC #2]. Next, the inspection team observed two 20,000-gallon frac tanks that were storing diesel fuel for an AV customer (see Appendix 1 - Photos 8 to 11). The inspection team noticed the secondary containment wall for the tank farm was slightly damaged, and Mr. Guarisco stated that a truck damaged the wall on 3/25/2025, and there are repairs scheduled for 3/28/2025 (see Appendix 1 - Photo 12). Inside the AV maintenance shop, the inspection team observed 11 universal waste batteries that were not properly labeled, but Mr. Guillory stated these batteries have recently gone out of service (see Appendix 1 - Photos 13 and 14) [AOC #3 - AV did not label universal waste batteries (i.e., each battery), or a container in which the batteries are contained, with any one of the following phrases: "Universal Waste--Battery(ies)," or "Waste Battery(ies)," or "Used Battery(ies);" - 40 CFR 273.14(a)]. Page 3 of 4 American Vacuum Inspection Date: 3/26/2025 The inspection team did not observe other 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 3:40 PM with AV personnel. The AOCs were communicated during the closing. Following the inspection on 4/11/2025, Mr. Guarisco sent a follow-up email in response to the AOCs observed during the inspection, including: Photos of the tanks labeled as used oil, a receipt for the shipment of universal waste batteries, and secondary containment for the 55-gallon drums of used oil (Appendix 2) SECTION III - RECORDS REVIEW No RCRA-regulated records were reviewed during this focused onsite inspection. SECTION IV - AREAS OF CONCERN The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation. Facility: American Vacuum AOC #1 - AV did not clearly label containers and aboveground tanks used to store used oil with the words "Used Oil." Citation: 40 CFR 279.45(g)(1) Section: 2.1 AOC #2 - AV did have a secondary containment system for containers and an aboveground tank used to store oil at a transfer facility. Citation: 40 CFR 279.45(f) Section: 2.1 AOC #3 - AV did not label universal waste batteries (i.e., each battery), or a container in which the batteries are contained, with any one of the following phrases: "Universal Waste--Battery(ies)," or "Waste Battery(ies)," or "Used Battery(ies)." Citation: 40 CFR 273.14(a) 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 provision of documents requested. Communication Log During and after the inspection, additional information was emailed to EPA including: 1. 4/11/25 AV email - Mr. Guarisco provided the inspection team with photos of attempted corrections made towards AOCs observed. SECTION VI - LIST OF APPENDICES Appendix 1. Photograph Log Appendix 2. AV Response on 4/11/2025 Page 4 of 4 APPENDIX 1. PHOTOGRAPH LOG UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log ILocation: American Vacuum City: Morgan City - County/Parish: St. Mary State: Louisiana I I _J Photo No. 1 Photo File Name: DSCN7889 Date of Photo: 3/26/2025 Time of Photo: 1515 hrs. Photographer: Vince Damiano Description: View of used oil storage Tank #1 (left, holding 7,000 gallons) and used oil storage Tank #2 (right, holding 4,000 gallons) in the tank farm; neither tank is labeled. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: American Vacuum City: Morgan City County/Parish: St. Mary State: Louisiana Photo No. 2 Photo File Name: DSCN7890 Date of Photo: 3/26/2025 Time of Photo: 1516 hrs. Photographer: Vince Damiano Description: View of used oil storage Tank #3 (middle left, holding 3,000 gallons) and used oil storage Tank #4 (middle right, empty) in the tank farm; neither tank is labeled. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: American Vacuum City: Morgan City County/Parish: St. Mary State: Louisiana Photo No. 3 Photo File Name: DSCN7891 Date of Photo: 3/26/2025 Time of Photo: 1516 hrs. Photographer: Vince Damiano Description: View of used oil storage Tank #5 (left, empty) and used oil storage Tank #6 (right, holding 3,000 gallons) in the tank farm; neither is labeled. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: American Vacuum City: Morgan City County/Parish: St. Mary State: Louisiana Photo No. 4 Photo File Name: DSCN7892 Date of Photo: 3/26/2025 Time of Photo: 1516 hrs. Photographer: Vince Damiano Description: View used oil frac tank storing 6,000 gallons of used oil; the tank is unlabeled and not in a secondary containment system. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: American Vacuum City: Morgan City County/Parish: St. Mary I State: Louisiana I J 03 . 26 . 2025 Photo No. 5 Photo File Name: DSCN7893 Date of Photo: 3/26/2025 Time of Photo: 1517 hrs. Photographer: Vince Damiano Description: View of three of the fifteen 55-gallon drums storing used oil-contaminated solids that were unlabeled and not in a secondary containment system, observed to the right of the tank farm. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: American Vacuum City: Morgan City County/Parish: St. Mary I State: Louisiana I 15 : 17 Photo No. 6 Photo File Name: DSCN7894 Date of Photo: 3/26/2025 Time of Photo: 1517 hrs. Photographer: Vince Damiano Description: View of three more of the fifteen 55-gallon drums storing used oil-contaminated solids that were unlabeled and not in a secondary containment system, observed to the right of the tank farm. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: American Vacuum City: Morgan City County/Parish: St. Mary State: Louisiana Photo No. 7 Photo File Name: DSCN7895 Date of Photo: 3/26/2025 Time of Photo: 1517 hrs. Photographer: Vince Damiano Description: View of tarp covering the other nine of the fifteen 55-gallon drums storing used oilcontaminated solids that were unlabeled and not in a secondary containment system, observed to the right of the tank farm. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: American Vacuum City: Morgan City County/Parish: St. Mary State: Louisiana Photo No. 8 Photo File Name: DSCN7896 Date of Photo: 3/26/2025 Time of Photo: 1519 hrs. Photographer: Vince Damiano Description: View of a 20,000-gallon frac tank storing diesel fuel located in the front of the property. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: American Vacuum City: Morgan City County/Parish: St. Mary I IState: Louisiana Photo No. 9 Photo File Name: DSCN7897 Date of Photo: 3/26/2025 Time of Photo: 1519 hrs. Photographer: Vince Damiano Description: View of the second 20,000-gallon frac tank storing diesel fuel located in front of the property. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: American Vacuum City: Morgan City County/Parish: St. Mary State: Louisiana Photo No. 10 Photo File Name: DSCN7898 Date of Photo: 3/26/2025 Time of Photo: 1519 hrs. Photographer: Vince Damiano Description: View of both 20,000-gallon frac tanks storing diesel fuel located in the front of the property. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: American Vacuum City: Morgan City County/Parish: St. Mary State: Louisiana Photo No. 11 Photo File Name: DSCN7899 Date of Photo: 3/26/2025 Time of Photo: 1519 hrs. Photographer: Vince Damiano Description: View of both 20,000-gallon frac tanks storing diesel fuel located in the front of the property. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: American Vacuum City: Morgan City County/Parish: St. Mary State: Louisiana Photo No. 12 Photo File Name: DSCN7900 Date of Photo: 3/26/2025 Time of Photo: 1522 hrs. Photographer: Vince Damiano Description: View of damage sustained to the tank farm secondary containment wall. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: American Vacuum City: Morgan City County/Parish: St. Mary State: Louisiana Photo No. 13 Photo File Name: DSCN7901 Date of Photo: 3/26/2025 Time of Photo: 1526 hrs. Photographer: Vince Damiano Description: View of 11 universal waste batteries located in the maintenance area that were not labeled. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: American Vacuum City: Morgan City County/Parish: St. Mary State: Louisiana Photo No. 14 Photo File Name: DSCN7902 Date of Photo: 3/26/2025 Time of Photo: 1526 hrs. Photographer: Vince Damiano Description: View of 11 universal waste batteries located in the maintenance area that were not labeled. APPENDIX 2. AV RESPONSE ON 4/11/2025  Outlook Re: Follow-Up from EPA Inspection on 3/26/2025 From Linda Thibodeaux <americanvacuum1@gmail.com> Date Fri 4/11/2025 5:55 PM To Vince Damiano <Vince.Damiano@erg.com> @5 attachments (1,018 KB) IMG_9070Jpeg; IMG_9089Jpeg; IMG_9088.jpeg; IMG_9069Jpeg; IMG_9090Jpeg; CAUTION : Don't open links or attachments unless you recognize the sender and know they are safe. Vince, We completed the list of changes you requested. I attached 5 pies of the changes. Thanks, Rob Guarisco American Vacuum 985-397-6404 Cell 985-384-6400 Phone 985-385-1888 Fax On Wed, Mar 26, 2025 at 5:16 PM Vince Damiano <Vince.Damiano@erg.com > wrote: Hello Rob, I am following up with a list of items and notes from our inspection today. Below are initial Areas of Concern and items requested; you may follow up with pictures, write-ups, sample results, or however you see fit : Unlabeled used oil storage tanks and frac tank Unlabeled used oil 55-gallon drums (these are the oily waste solids that contain used oil) As a used oil transfer facility, no secondary containment for a used oil frac tank and 55-gallon drums Universal waste batteries were not labeled and had no accumulation start date Again, thank you for taking the time out of your day to meet with us. Please let us know if you have any questions or concerns. Thanks, Vince Vince Damiano &11dd.a.'u1.C, SCRAP METAL RECYCLING Studdard Scrap Metal 531 H1gl1way 182 East Morgan C,ty, LA 70380 Purchase Ticket #33652 I PAID Operator; Time of Arrival PAID: Customer; Addres ; Llcene Plate: Drivers Llcenae #: Payment Type, mt1ch 11.51 AM. 0Jfl71Wi5 11.53 AM, 03rl71W25 LARRY GUILLORY 136 SHADY GROVE PATTERSON. LA 70392-00ool 006340334 Cash ... NOTES Materials G T Ad) 1 . BATTERY ($0.100/LBS) 650 0 Tdtal 650 0 Truck Total 0 0 Not Valuo 660 $65.00 650 $65,00 0 A ccepted Discla,m er I 11t \l')tllt., t1< ,.._.,11o:,,.,,,_,.,r<:,{litf11K1a;,.n,'10I 4Selc:,t,tit IIO. ~ ,..,_ IU.lf I w,..,.,,c...i1,11ta1 .,,, . , ... 1,.. .. ~~a,,.... t>,.,,, "' . . . . . _ 1 1 1 ' 11111,..WII M>'UA, HlUAVIAIII 1'1.1 ~ I c.ur,..,Rl.lf-(,,t,:,.l,..... f,e- , .. F "'ll, f'A,HR&~b.it,j=:.~ ,,. ~