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04/23/1985 |
Compliance Evaluation Inspection |
Downloaded From Rcris On 18-Oct-96 Downloaded From Rcris On 18-Oct-96 |
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04/12/1989 |
Compliance Evaluation Inspection |
Downloaded From Rcris On 18-Oct-96 Downloaded From Rcris On 18-Oct-96 |
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08/15/1989 |
Compliance Evaluation Inspection |
Downloaded From Rcris On 18-Oct-96 Downloaded From Rcris On 18-Oct-96 |
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09/18/1989 |
Compliance Evaluation Inspection |
Downloaded From Rcris On 18-Oct-96 Downloaded From Rcris On 18-Oct-96 |
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10/09/1989 |
Compliance Evaluation Inspection |
Downloaded From Rcris On 18-Oct-96 Downloaded From Rcris On 18-Oct-96 |
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11/20/1989 |
Compliance Evaluation Inspection |
Downloaded From Rcris On 18-Oct-96 Downloaded From Rcris On 18-Oct-96 |
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12/30/1989 |
Other Inspection |
Downloaded From Rcris On 18-Oct-96 Downloaded From Rcris On 18-Oct-96 |
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04/25/1990 |
Legacy Site Inspection |
Downloaded From Rcris On 18-Oct-96 Downloaded From Rcris On 18-Oct-96 |
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12/11/1990 |
Consent Order Executed |
Downloaded From Rcris On 18-Oct-96 Downloaded From Rcris On 18-Oct-96 |
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05/24/2004 |
Compliance Evaluation Inspection |
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05/24/2004 |
Project Closed Letter |
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05/10/2010 |
Site Inspection |
Routine; Non-Handler - Routine; Hazardous Waste Transporter - Routine; Used Oil Transporter Csx Transportation (Csx T) Was Inspected On May 10, 2010, As An Announced Hazardous Waste Compliance Evaluation Inspection. A Follow-Up Visit Was Made To The Facility On June 8, 2010. Csx T Was Last Inspected By The Dep On 5/24/04, When It Was Operating As A Hazardous Waste And Used Oil Transporter. The Facility Is Still Operating As Both A Hazardous Waste And A Used Oil Transporter; However, The Facility Is Not Currently Registered In Florida To Transport Either Waste Stream.
Csx T Is A Wholly-Owned Subsidiary Of Csx Corporation. Csx T Serves The Eastern U.S., And Maintains A 21,000 Route Mile Rail Network. Csx T Currently Operates 3,800 Locomotives, Which Are Used To Transport A Wide Variety Of Commodities. The Facility At 500 Water Street In Jacksonville, Is The Headquarters For Csx T And Contains Only Offices. Mr. Romano De Simone, Director Of Hazardous Material Systems, Was Present During The Initial Inspection On 5/10/10. Mr. Michael Lunsford, Director Of Chemical Safety, Was Present During The Follow-Up Visit On 6/8/10.
| Hazardous Waste Transportation
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As A Hazardous Waste Rail Transporter, Csx T Should Meet All Applicable Requirements Relating To The Transportation Of Hazardous Waste. According To Mr. Lunsford, Csx T Transports 1500-2000 Car Loads Of Hazardous Waste Per Year Nationally.
As Of The Day Of The Initial Inspection, Csx T Had Only Transported One Rail Car Of Hazardous Waste In Florida In All Of 2010. This Shipment Took Place Between January 11 And January 14, When Clean Harbors Fl (Fld980729610) Shipped 21,996 Gallons Of D001/D004/D005/D006/D007/D008 Hazardous Waste. Transporter 1 Was Listed As Clean Harbors (Non-Rail Transporter), Transporter 2 Was Csx T, Transporter 3 Was Toledo, Peoria, & Western Railway (Ilt180012098), And The Destination Facility Was Essroc Materials Inc (Ind005081542).
According To Mr. De Simone, Csx T Did Not Ship Any Hazardous Waste In Florida In 2009. In 2008, Csx T Had One Shipment Totaling 23,465 Gallons Of D001/D004/D005/D006/D007/D009 Hazardous Waste From Clean Harbors Fl To Essroc Materials Inc.
As Of The Date Of The Initial Inspection, Csx T Was Not Registered To Transport Hazardous Waste In Florida [Section 62-730.170(2)(E), Fac]. Registration Is Required Annually, And The Facility'S Last Registration Expired On May 28, 2009. The Facility Is Self-Insured.
Used Oil Transportation
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All Commodities Are Given Code Numbers Under The Standard Transportation Commodities Code (Stcc) For Railways. For The Purposes Of This Inspection, Mr. Lunsford Pulled Computer Records For "Waste Oil" That Had The Stcc Code Number 4025198. Mr. Lunsford Stated That It Was Possible That Used Oil Could Be Classified Under A Different Stcc Code Number; However, He Wasn'T Sure Which Numbers Could Be Used. Mr. Lunsford Also Stated That Acceptance And Delivery Records Were Not Kept On-Site, Since, According To Policy, Non-Hazardous Loads Do Not Require Manifests. Records Are Kept In The Computer Database And Are Searchable According To Stcc Codes And Other Information.
Mr. Lunsford Provided A List Of All Of The Used Oil Shipments Originating In Or Destined For Florida In The Past Year, Under The Stcc Code For Waste Oil. Since 5/17/09, Csx T Has Handled 16 Shipments Of Used Oil, Mostly From Cliff Berry Inc. Mr. Lunsford Stated That Csx T May Or May Not Document The Weight Of The Used Oil Being Transported, According To The Contract That Csx T Has With The Provider.
The Facility'S Records Do Not Include The Following Required Information: The Epa Id Number Of The Oil Provider, The Epa Id Number Of The Receiving Facility, The Quantity Of Oil Shipped, The Signature Of The Generator, And The Signature Of The Receiving Facility [40 Cfr 279.46]. In Addition, The Records Do Not List The Type Of Oil And Desination Or End Use [Rule 62-710.510(C) And (E), Fac]. The Facility Does Not Keep Re |
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07/01/2010 |
Issue Non-Compliance Letter |
Sent for Issue Non-Compliance Letter-07/01/2010 ; Finished-07/06/2010 |
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08/12/2010 |
Meeting |
Finished-08/12/2010 |
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12/15/2010 |
Submittal Received By Department |
Received for SUBMITTAL RECEIVED BY DEPARTMENT-09/15/2010 ; Finished-12/15/2010 |
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12/15/2010 |
Letter |
Finished-12/15/2010 ; Sent for LETTER-12/15/2010 |
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05/08/2014 |
Site Inspection |
Routine; CESQG (<100 kg/month) - Routine; Hazardous Waste Transporter - Routine; Used Oil Transporter - Routine; VSQG (<100 kg/month) Csx Transportation (Csxt) Was Inspected On May 8, 2014, As An Announced Hazardous Waste Compliance Evaluation Inspection. A Follow-Up Visit Was Made To The Facility On May 20, 2014. Csxt Was Last Inspected By The Dep On May 10, 2010, When It Was Operating As A Hazardous Waste And Used Oil Transporter. The Facility Is Still Operating As Both A Hazardous Waste And A Used Oil Transporter.
Csxt Is A Wholly-Owned Subsidiary Of Csx Corporation. Csxt Serves The Eastern U.S. And Maintains A 21,000 Route Mile Rail Network. Csxt Currently Operates 3,800 Locomotives, Which Are Used To Transport A Wide Variety Of Commodities. The Facility At 500 Water Street In Jacksonville, Is The Headquarters For Csxt And Contains Mostly Offices. Mr. Michael Lunsford, Director Of Environmental Field Services, Was Present During The Initial Inspection On May 8, 2014. Kimberly Vaughn, Environmental Programs Manager; Brian Booth, North Florida Field Manager; Ramano Desimone, Hazardous Materials Manager; And Kate Barney, Public Safety And Health Manager, Were Present During The Follow-Up Visit On May 20, 2014. | During Both Visits, A Walk Through Of The Basement Was Performed. Maintenance, Parts Storage, And Other Building Support Activities Are Located In The Basement. The Facility Operates A Bead Blast Machine, Which According To Brian Booth, Is New And No Waste Has Been Disposed Of To Date. The Facility Should Perform A Hazardous Waste Determination According To 40 Cfr 262.11 On This Waste Stream When Spent. One Aerosol Puncture System Is Located Next To The Blast Machine. This Container Was Properly Labeled And Closed (Photo 1). Occasionally, The Facility Will Generate Waste Paint From Maintenance Activities And/Or A Cleanup. When This Occurs, Facility Personnel Perform A Hazardous Waste Determination On The Waste Containers And Dispose Of Them Properly. The Last Hazardous Waste Cleanout Was 30 Pounds Of D001/D039 Hazardous Waste On August 14, 2013.
Used Oil From The Servicing Of The Facility'S On-Site Generators Is Collected In 55-Gallon Drums Located On Spill Pallets (Photo 2). Spent Mercury Containing Lamps Are Stored In Boxes That Were Not Closed And Secure (Photo 3) [40 Cfr 273.13(D)]. This Was Corrected By The Time Of The Follow Up Inspection.
During The Follow Up Inspection On May 20, 2014, Used Oil And Hazardous Waste Transporter Records Were Reviewed.
Hazardous Waste Transportation
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As A Hazardous Waste Rail Transporter, Csxt Should Meet All Applicable Requirements Relating To The Transportation Of Hazardous Waste. From January 1, 2014, To March 30, 2014, The Facility Transported Three Railcars From Clean Harbors (Fld980729610) In Tampa, Florida, To Clean Harbors (Txd055141378) In La Porte, Texas. During That Same Timeframe, Csxt Transported Fifteen Railcars From Gerdau Ameristeel (Fld083812537) In Baldwin, Florida, To Steel Dust Recycling (Alr000042754) In Millport, Alabama. These Manifests Were Provided And Appeared To Be In Order.
The Facility'S Annual Registration And Proof Of Insurance Was Up To Date.
Used Oil Transportation
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A Used Oil Transporter Is Defined In 62-710.201(5), Fac, As "Any Person Who Transports Used Oil Over Public Highways." Csxt Does Not Transport Used Oil Over Public Highways, But Rather Over Rail And Does Not Meet The Florida Definition Of A Used Oil Transporter. However, Csx Still Complies With The Notification And Insurance Requirements In Florida'S Used Oil Transporter Rules. These Records Were Reviewed And Were In Order.
The Federal Regulations For Management Of Used Oil Define The Term "Used Oil Transporter" More Broadly. Despite The Inapplicability Of The State Regulations To Transportation Of Used Oil By Railroad, Csxt Should Ensure That It Is In Compliance With The Federal Used Oil Transporter Rules. Epa Inspectors Regularly Visit Florida To Determine Facility Compliance Wi |
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07/15/2014 |
Informal Verbal Enforcement |
Compliance Assistance Correspondence for Informal Verbal Enforcement-05/20/2014 ; Finished-07/15/2014 |
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05/03/2018 |
Site Inspection |
Routine; CESQG (<100 kg/month) - Routine; Hazardous Waste Transporter - Routine; Used Oil Transporter - Routine; VSQG (<100 kg/month) Csx Transportation (Csxt) Was Inspected On May 3, 2018. This Facility Notified The Department As A Very Small Quantity Generator (Vsqg) Of Hazardous Waste, A Hazardous Waste Transporter And A Self-Transporter Of Used Oil In September 2017. Csxt Was Last Inspected By The Department'S Hazardous Waste Program On May 8, 2014. Csxt Is A Wholly-Owned Subsidiary Of Csx Corporation. Csxt Serves The Eastern U.S. And Maintains A 21,000-Mile Railroad Network. Csxt Currently Operates 2,400 Locomotives That Transport A Wide Variety Of Commodities. This Facility Is The Headquarters For Csxt And Contains Mostly Offices. This Facility Is Connected To City Sewer And Water And Has Been At This Location Since The 1960s. Mr. Mark Mullis, Director Of Environmental Field Services, Was Present Throughout The Inspection.
| Maintenance Area And Satellite Accumulation Area
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Maintenance, Parts Storage, And Other Building Support Activities Are Located In The Basement Of This Office Building. Minor Equipment Maintenance Is Performed By A Csxt Crew Of Three People. Large Projects And Major Maintenance And Electrical Work Are Performed By Outside Contractors.
In The Parts Storage Area Is An Aerosol Can Puncture System That Is Attached To The Top Of A 55-Gallon Satellite Accumulation Drum. The Liquid That Accumulates In The Drum Is Managed As D001 Hazardous Waste, And The Empty Cans Are Recycled As Scrap Metal. One 55-Gallon Drum Was Accumulating. The Drum Was Closed And Properly Labeled (Photo 1). A Plastic-Media Glove Box Was Also Located In This Area But Was Not Connected To A Power Source And, According To Maintenance Personnel, Had Not Been Used And No Waste Has Been Disposed Of To Date. The Facility Is Aware That It Should Perform A Hazardous Waste Determination In Accordance With 40 Cfr 262.11 On This Waste Stream When Spent.
Spent Mercury Containing Lamps Are Collected In Boxes In A Designated Location In The Basement. At The Time Of The Inspection, There Were Two Boxes Of Spent Lamps Accumulating (Photo 2). The Containers Were Closed, Properly Labeled And Had Been Accumulating For Less Than One Year.
Hazardous Waste Transportation
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Csxt Provides Hazardous Waste Transporter Services Via Rail. Over The Previous Six Years, Csxt Has Only Transported Hazardous Waste In Railcars For Two Customers, Clean Harbors (Fld 980 729 610) And Gerdau Ameristeel (Fld 083 812 537).
Used Oil Transportation
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Csxt Only Collects Used Oil From Maintenance Of Csxt-Owned Equipment In Its Own Fleet Of Trucks. The Used Oil Is Delivered To One Of Four Csxt Bulk Oil Storage Facilities In The State Depending Upon The Maintenance Location. Those Facilities Are Located In Jacksonville, Lakeland, Tampa And Wildwood. Used Oil At Those Facilities Is Managed By Noble Oil Services (Ncd 986 172 476) Who Is Registered As A Used Oil Transporter In Florida.
Record Review
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Csxt Is Currently Operating As A Very Small Quantity Generator Of Hazardous Waste, A Hazardous Waste Transporter, And A Self-Transporter Of Used Oil.
On Its Most Recent Annual Transporter Notification Form, Csxt Provided Notification That It Is An Annual Episodic Small Quantity Generator (Sqg) Of Hazardous Waste. The Episodic Event Is Due To Generation Of Waste Paint From Annual Maintenance Activities And Purging Its Hazardous Materials Inventory. When This Occurs, Facility Personnel Perform A Hazardous Waste Determination On The Waste Containers And Dispose Of Them Properly. The Last Shipment Of Hazardous Waste, Resulting From A Hazardous Materials Inventory Cleanout, Was For 338 Pounds Of Hazardous Waste On February 23, 2017, And Was Managed By Hulls’S Environmental Service (Flr 000 195 826).
A Re |
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04/13/2022 |
Site Inspection |
Routine; CESQG (<100 kg/month) - Routine; Hazardous Waste Transporter - Routine; Used Oil Transporter - Routine; VSQG (<100 kg/month) Csx Transportation (Csxt, The Facility) Was Inspected On April 13, 2022. Csxt Submitted Its Notification To The Department As A Hazardous Waste Transporter, Used Oil Transporter, And A Very Small Quantity Generator (Vsqg) Of Hazardous Waste In April 2022. Csxt Was Last Inspected By The Department'S Hazardous Waste Program On May 3, 2018. Csxt Representatives Present During The Inbrief And Overview Of Csxt Operations Included Raghu Chatrathi, Sam Ross, Chris Machenberg, Kim Vaughn, Mark Mullis, Brian Zacker, Todd Hagen. Mr. Zacker And Mr. Hagen Participated During The Inspection Of The Building Areas, Described Below. Ms. Vaughn And Mr. Mullis Participated During The Records Review.
Csxt Is A Wholly-Owned Subsidiary Of Csx Corporation. Csxt Serves The Eastern U.S. And Maintains A 21,000-Mile Railroad Network. Csxt Currently Operates 2,400 Locomotives That Transport A Wide Variety Of Commodities. This Facility Is The Headquarters For Csxt And Contains Mostly Offices. The Facility Is Connected To City Sewer And Water And Has Been At This Location Since The 1960s. The Areas Inspected Are Described Below.
| Maintenance And Storage Area
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Minor Maintenance, Parts Storage, And Other Building Support Activities Are Located In The Basement Of This Office Building. Minor Equipment Maintenance Is Performed By Csxt Technicians. Large Projects And Major Maintenance Are Performed By Outside Contractors Under Individual Contracts.
Universal Waste Lamps Are Collected In Boxes In A Designated Location In The Basement. At The Time Of The Inspection, There Was One Box Of Spent Lamps Accumulating. The Container Was Closed, Properly Labeled And Dated.
Shipping Area
Universal Waste Batteries Are Accumulated In A Poly Container Located Inside The Shipping Area Adjacent To The Basement Area. At The Time Of The Inspection There Were Rechargeable And Alkaline Batteries Accumulating. The Container Was Closed, Properly Labeled And Dated.
Outside Shipping Area
In A Mechanical Room Outside The Shipping Area Is A Drum-Top Aerosol Can Puncture System That Is Attached To The Top Of A 55-Gallon Drum. The Liquid That Accumulates In The Drum Is Managed As Hazardous Waste And The Empty Cans Are Recycled As Scrap Metal. The Drum Was Closed And Properly Labeled, And The Area Had All The Required Equipment.
Hazardous Waste Transportation
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Csxt Provides Hazardous Waste Transporter Services Via Rail. Csxt Primarily Transports Hazardous Waste In Railcars For Two Customers: Clean Harbors (Fld980729610) And Cmc Steel Us (Fka Gerdau Ameristeel) (Fld083812537).
Used Oil Transportation
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Csxt Collects Used Oil From Maintenance Of Csxt-Owned Equipment In Its Own Fleet Of Trucks. The Used Oil Is Delivered To One Of Three Csxt Bulk Oil Storage Facilities In The State Depending Upon The Maintenance Location. Those Facilities Are Located In Jacksonville, Lakeland, And Tampa. Used Oil At Those Facilities Is Managed By One Of Several Used Oil Transporters Depending Upon A Rotating Service Contract. Typically, Noble Oil Services (Ncd986172476), Synergy Recycling (Gar000048009), Universal Environmental Services (Gar000020131), And Safety-Kleen (Txr000081205) Manage Csxt’S Used Oil From The Bulk Storage Facilities Described Above.
Csxt Also Provides Used Oil Transporter Services Via Rail For Customers As Either An Initial Or Intermediate Transporter. Florida Regulations In 62-710.201(5), Fac, Define A Used Oil Transporter As "Any Person Who Transports Used Oil Over Public Highways." Even Though Csxt Transports Customer-Generated Used Oil Via Rail, Csxt Complies With Florida’S Notification, Registration And Insurance Requirements For Used Oil Transporters.
Records Review
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