Document MMxdmwwV34qoD3bgOxKg6kzVz

f t E A ~ United States ~ Environmental Protection "'' Agency Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 6 Enforcement Division INSPECTION REPORT 3/25/2025 08:42 {CT) Announced: No 3/25/2025 09:45 {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 American Pollution Control Inc. {AMPOL) N/A 575 Hwy 182 East Morgan City, LA 70380 St. Mary Non-generator 562910 American Pollution Control Inc. {AMPOL) decontaminates piping removed from offshore oil and gas exploration. 29.6818, -91.2785 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 Digitally signed by Vincent Damiano Damiano Date: 2025.05.01 16:07:08 -04'00' IVince.Damiano@erg.com Page 1 of 4 American Pollution Control Inc. SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection Inspection Date: 3/25/2025 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 AM POL/Manager Name Vince Damiano John Penland Erin Young-Dahl Janosh Wolters Casey Guidry Email Vince.Damiano@erg.com Penland.John@epa .gov Youngdahl.Erin@epa.gov Janosh .Wolters@erg.com Cguidry@ampol.net Opening Conf. Yes Closing Conf. Yes Yes Yes Yes Yes Yes Yes Yes Yes Page 2 of 4 American Pollution Control Inc. Inspection Date: 3/25/2025 Facility General Description Tenant/Area AMPOL Inspection Date 3/25/25 Process Description AM POL decontaminates piping removed from offshore oil and gas exploration activities. AMPOL is land-based and does not operate under a MARPOL COA. Area of Concern Yes SECTION II-OBSERVATIONS Facility: AM POL Section: 2.1 Date: 3/25/25, 08:42 AM IContains AOC: No Lead Inspector: Vince Damiano Attendees: Casey Guidry (Manager) IContains CBI: No American Pollution Control, Inc. (AMPOL) is located in Morgan City, LA, and conducts decontamination of decommissioned piping and pressure vessels with trace amounts of naturally occurring radioactive material (NORM). Piping from offshore oil and gas exploration is brought to a scrapyard (MARS) and then transported to AM POL for decontamination if it screens positive for NORM . The decontamination process includes an initial NORM level screening, loading the pipe or pressure vessel into a wash bay, pressure washing with recycled water, and retesting. If the material passes, it is considered decontaminated. If the material fails, it is washed again. Solid material collected during the process is placed in drums and disposed of as RCRA nonhazardous waste. This waste is typically sent to Sabine Environmental, R360, EcoServ, or Federal NORM Services. Decontaminated materials are returned to the customer. According to Mr. Guidry, the recycled water and filters used in the wash process are replaced about once a year. This AM POL facility is not registered with the EPA as a hazardous waste generator. Following the opening conference, the inspection team took a visual inspection of AMPOL's used oil storage area and a wash bay. The used oil is generated from maintenance activities at the facility, Mike's Filter will come to the facility and pump out any used oil once enough is accumulated. At the time of the inspection, AM POL was storing four half-full 55-gallon drums of used oil, three of which were not labeled with the words "Used Oil" (see Appendix 1- Photos 1 and 2) [AOC #1 : AM POL did not clearly label containers used to store used oil with the words "Used Oil." -40 CFR 279.22 (c}(l}]. Upon noticing the unlabeled used oil drums, Mr. Guidry immediately labeled the drums properly (see Appendix 1 - Photos 3 to 5). The inspection team then observed an inactive wash bay. The inspection team did not observe other areas of concern (AOCs) at the time of the inspection; however, further EPA review may change or add to these potential AOCs. A closing conference was conducted at approximately 09:45 AM with Mr. Guidry. The AOCs were communicated during the closing. SECTION Ill - RECORDS REVIEW No RCRA-regulated records were reviewed during this focused onsite inspection. Page 3 of 4 American Pollution Control Inc. Inspection Date: 3/25/2025 SECTION IV - AREAS OF CONCERN The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation. Facility: AMPOL AOC #1-AMPOL did not clearly label containers used Citation: 40 CFR 279.45(g)(l) to store used oil with the words "Used Oil." Section: 2.1 SECTION V - FOLLOW UP Not Applicable SECTION VI - LIST OF APPENDICES Appendix 1. Photograph Log Page 4 of 4 APPENDIX 1. PHOTOGRAPH LOG UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: AMPOL City: Morgan City ICounty/Parish: St. Mary IState: Louisiana Photo No.1 Photo File Name: DSCN718 Date of Photo: 3/25/2025 Time of Photo: 0924 hrs. Photographer: Vince Damiano Description: View of four half-full 55-gallon drums storing used oil in the used oil storage area. Three of which were not labeled as used oil. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location : AMPOL City: Morgan City ICounty/Parish: St. Mary IState: Louisiana Photo No. 2 Photo File Name: DSCN719 Date of Photo: 3/25/2025 Time of Photo: 0924 hrs. Photographer: Vince Damiano Description: Another view of four half-full 55-gallon drums storing used oil in the used oil storage area. Three of which were not labeled as used oil. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: AMPOL City: Morgan City ICounty/Parish: St. Mary IState: Louisiana Photo No. 3 Photo File Name: DSCN720 Date of Photo: 3/25/2025 Time of Photo: 0929 hrs. Photographer: Vince Damiano Description: View of the "Used Oil" label Mr. Guidry applied onto a previously unlabeled 55-gallon drum during the inspection. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: AMPOL City: Morgan City ICounty/Parish: St. Mary IState: Louisiana Photo No. 4 Photo File Name: DSCN721 Date of Photo: 3/25/2025 Time of Photo: 0929 hrs. Photographer: Vince Damiano Description: View of the "Used Oil" label Mr. Guidry applied onto a previously unlabeled 55-gallon drum during the inspection. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location : AMPOL City: Morgan City ICounty/Parish: St. Mary IState: Louisiana Photo No. 5 Photo File Name: DSCN722 Date of Photo: 3/25/2025 Time of Photo: 0929 hrs. Photographer: Vince Damiano Description: View of the "Used Oil" label Mr. Guidry applied onto a previously unlabeled 55-gallon drum during the inspection.