Document Z4QXkZre0wbMjKwZwExMzydQL
Inspection Entry Date/Time
Inspection Exit Date/Time Regulatory Program Type of Inspection
EPA REGION 6 Enforcement Division
INSPECTION REPORT
11/7/2024 08:50 (CT) 11/7/2024 09:40 (CT)
Announced: No (tenants and related facilities) Access: Granted
RCRA Focused Compliance Inspection (FCI)
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 TXR000086666 101 Farm-to-Market Road 365 Port Arthur, TX 77640 Jefferson County Non-generator 562910 American Pollution Control focuses on crude oil tank cleaning, spill response, and the removal of asbestos and mold. 29.92376, -94.01603
Additional Persons Participating in Inspection:
Name
Title
Organization
Angela Hays
Inspector
EPA REGION 6
Sandesh Thapa
Inspector
EPA REGION 6
Jon Herbay
Contractor
Eastern Research Group (ERG)
Email Hays.Angela@epa.gov Thapa.Sandesh@epa.gov Jon.Herbay@erg.com
Phone (214) 665-2285 (214) 665-2265 (412) 780-9931
Lead Inspector: Vince Damiano
Chemical Engineer ERG
Vincent Damiano
Digitally signed by Vincent Damiano Date: 2025.02.06 10:49:16 -05'00'
Vince.Damiano@erg.com
02/06/2025 (703) 633-1732
Page 1 of 4
American Pollution Control
Inspection Date: 11/07/2024
SECTION I - INTRODUCTION
Site Entry and Purpose of the Inspection
The Port of Beaumont 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 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 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
Name
Lead Inspector/ Contractor/ERG
Vince Damiano
Inspector/Enforcement Officer/EPA Region 6
Angela Hays
Inspector/Enforcement Officer/EPA Region 6
Sandesh Thapa
RCRA Inspector/ Contractor/ERG
Jon Herbay
American Pollution Control Lindsey Gothia
American Pollution Control Steven Gill
Phone
Email
(703) 633-1732 Vince.Damiano@erg.com
Opening Conf.
Yes
Closing Conf.
Yes
(214) 665-2285 Hays.Angela@epa.gov Yes
Yes
(214) 665-2265 Thapa.Sandesh@epa.gov Yes
Yes
(412) 780-9931 Jon.Herbay@erg.com Yes
Yes
(409) 728-1992 LGothia@ampol.net
Yes
Yes
(409) 682-3919 SGill@ampol.net
Yes
Yes
Page 2 of 4
American Pollution Control Facility General Description
Inspection Date: 11/07/2024
Tenant/Area American Pollution Control
Inspection Date
11/07/24
Process Description American Pollution Control (AMPOL) cleans crude oil tanks, manages spills, and removes asbestos and mold. The facility is land-based and does not maintain a MARPOL COA.
Area of Concern
Yes
SECTION II - OBSERVATIONS
Tenant: American Pollution Control
Section: 2.1
Date: 11/07/24, 08:50 AM Contains AOC: Yes Contains CBI: No
Lead Inspector: Vince Damiano Attendees: Linsey Gothia (Sales), Steven Gill (Manager)
AMPOL is a remediation and emergency response company specializing in tank cleanings, spill response (both onshore and offshore), asbestos/mold abatement, and site remediation. AMPOL operates using roll-off containers, hydro-excavation trucks, and vacuum trucks. AMPOL does not maintain a MARPOL COA but is registered with the EPA for used oil transporter activities from its spill response operations (TXR000086666). Mr. Gill stated waste is never brought back to the facility and is brought straight to the used oil recycler, either Action Oil (TXR000085911) or EcoWerks (TXR000036277). Third parties always clean vacuum trucks, typically AMPOL uses EcoWerks, KSolv, or Republic. AMPOL is certified to remove waste from ships onto shore but has not conducted this operation yet. Used oil generated from AMPOL operations is sent to be recycled at Action Oil.
Following the opening conference, the inspection team conducted a visual inspection of AMPOL's maintenance area. The inspection team observed one 55-gallon drum of used oil that was labeled "Used Oil" and the drum was closed and in good condition. The used oil was generated from AMPOL operations. AMPOL did not have any other waste-related activities to observe at the time of the inspection. The inspection team did not observe any areas of concern (AOCs) at the time of the inspection; however, further EPA review may add to their potential AOCs. A closing conference was conducted at approximately 9:30 AM with AMPOL.
Following the inspection on 11/19/2024, Mike Watts (AMPOL's Transportation Director) provided the inspection team with two examples of shipping papers related to transporting DOT-regulated hazardous materials (see Appendix 1). In the response, Mr. Watts stated they could not find records related to AMPOL transporting RCRA-regulated waste (see Appendix 2).
Page 3 of 4
American Pollution Control
Inspection Date: 11/07/2024
SECTION III - RECORDS REVIEW No RCRA-regulated records were reviewed during this focused onsite inspection. SECTION IV - AREAS OF CONCERN Not Applicable. SECTION V - FOLLOW UP
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. 11/19/24 AMPOL email - Mike Watts provided examples of shipping papers related to the transportation of DOT-regulated hazardous waste.
SECTION VI - LIST OF APPENDICES Appendix 1. DOT Shipping Paper Examples Appendix 2. AMPOL Response on 11/19/2024
Page 4 of 4
APPENDIX 1. DOT SHIPPING PAPER EXAMPLES
APPENDIX 2. AMPOL RESPONSE ON 11/19/2024