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01/05/1984 |
Compliance Evaluation Inspection |
Downloaded From Rcris On 18-Oct-96 Downloaded From Rcris On 18-Oct-96 |
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12/16/1987 |
Compliance Evaluation Inspection |
Downloaded From Rcris On 18-Oct-96 Downloaded From Rcris On 18-Oct-96 |
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06/14/1990 |
Compliance Evaluation Inspection |
Downloaded From Rcris On 18-Oct-96 Downloaded From Rcris On 18-Oct-96 |
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04/27/1993 |
Legacy Site Inspection |
Downloaded From Rcris On 18-Oct-96 Downloaded From Rcris On 18-Oct-96 |
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06/11/1993 |
Warning Letter Issued |
Downloaded From Rcris On 18-Oct-96 Downloaded From Rcris On 18-Oct-96 |
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07/29/1993 |
Enforcement Meeting |
Downloaded From Rcris On 18-Oct-96 Downloaded From Rcris On 18-Oct-96 |
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08/18/1993 |
File Review |
Downloaded From Rcris On 18-Oct-96 Downloaded From Rcris On 18-Oct-96 |
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08/18/1993 |
Warning Letter Issued |
Downloaded From Rcris On 18-Oct-96 Downloaded From Rcris On 18-Oct-96 |
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06/27/1996 |
Compliance Evaluation Inspection |
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07/15/1996 |
No Further Action |
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08/19/1997 |
Meeting |
Pre-Permit Meeting To See Secondary Containment. Pre-Permit Meeting To See Secondary Containment. |
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05/11/1998 |
Legacy Site Inspection |
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05/11/1998 |
Informal Verbal Enforcement |
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05/11/1998 |
File Review |
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08/10/1998 |
Compliance W/O Formal Enforcement Action |
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08/10/1998 |
Project Closed Letter |
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05/20/1999 |
Compliance Evaluation Inspection |
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06/21/1999 |
Project Closed Letter |
No Violations No Violations |
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09/28/2000 |
Compliance Evaluation Inspection |
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11/27/2000 |
Project Closed Letter |
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09/19/2001 |
Compliance Evaluation Inspection |
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11/20/2001 |
Project Closed Letter |
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07/30/2002 |
Legacy Site Inspection |
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07/30/2002 |
Informal Verbal Enforcement |
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08/05/2002 |
File Review |
Rtc Info Rtc Info |
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08/05/2002 |
Return To Compliance Letter |
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10/08/2002 |
Compliance W/O Formal Enforcement Action |
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10/08/2002 |
Project Closed Letter |
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10/25/2004 |
Compliance Evaluation Inspection |
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09/02/2005 |
Project Closed Letter |
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11/20/2009 |
Site Inspection |
Routine; Hazardous Waste Transporter - Routine; Used Oil Generator Moran Environmental Recovery (Mer) Was Inspected On November 20, 2009, As An Unannounced Hazardous Waste Compliance Evaluation Inspection. The Facility Was Last Inspected On 10/25/04, When It Was Operating As A Conditionally Exempt Small Quantity Generator (Cesqg) Of Hazardous Waste. The Facility Is Currently Operating As A Hazardous Waste Transporter And Used Oil Filter Transporter.
Mer Is An Environmental Services Company Which Offers Industrial And Marine Services, Site Remediation, Decontamination And Abatement Services, And Emergency Spill Response. Ms. Maria Taylor, Quality Director, Was Present For The Inspection. The Facility Consists Of Offices, A Maintenance Shop, A Wash Pad, And A Pole Barn. | Maintenance Shop
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Mer Has 25 Trucks In Service. General Maintenance And Repair Of Those Trucks Is Performed In The Maintenance Shop.
The Facility Operates One Parts Washer, Which An Area Technician Stated Has Not Generated Any Waste For Four To Five Years. The Same Technician Stated That This Parts Washer Generates Only A Filter, Which Is Placed Into A Used Oil Filter Drum For Disposal Once Changed. The Facility Had A Record Of Analysis For This Filter That Showed It To Be Non-Hazardous.
The Facility Has One Mobile Used Oil Cart And One Black Drain Pan For Draining Used Oil. At The Time Of The Inspection, Neither Container Was Properly Labeled; However, Only The Mobile Used Oil Cart Contained Any Used Oil (Photo 1) [40 Cfr 279.22(C)(1) - Corrected 12/7/09].
There Was One 300-Gallon Tote Containing Used Oil In This Shop As Well. The Tote Was Properly Labeled And Was On A Plastic Secondary Containment Pallet (Photo 2). The Capacity Of The Secondary Containment Pallet Could Not Be Determined During The Inspection. After The Inspection, On 12/7/09, The Facility Submitted Documentation Stating That The Pallet'S Capacity Is 106 Gallons, Which Is Not Sufficient To Hold 110% Of The Contents Of The Tote [Rule 62-710.401(6), Fac - Corrected 12/7/09]. In The Same Letter, Mer Stated That It Was Now Using Drums To Accumulate Its Used Oil.
Used Oil Filters Are Collected In A 55-Gallon Drum, Which Was Not Properly Labeled (Photo 3) [Rule 62-710.850(5)(A), Fac - Corrected 12/22/09]. Spent Batteries Are Taken To Napa For Disposal.
Wash Pad
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This Area Is Used To Wash Out Old, Empty Used Oil And Used Oil Filter Drums. Wash Water Is Drained Into An Industrial Wastewater Tank.
This Area Also Serves As A Storage Area For Used Oil Filter Drums That Were Picked Up From Customers. At The Time Of The Inspection, There Were Numerous Drums Of Used Oil Filters On-Site (Photo 4). All Of The Drums Were Labeled And Closed.
Pole Barn
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This Area Is Located At The Back Of The Facility And Is Sometimes, Though Rarely, Used To Perform Pipe Cleaning With Acids For The Navy. According To Mr. Israel Perez, Yard Manager, Any Waste From This Process Is Neutralized Prior To Disposal. Ms. Taylor Stated In An E-Mail On 1/15/10, That All Rinseate From This Process Is Collected, Profiled, And Disposed Of As Appropriate. Ms. Taylor Also Stated That This Service Has Not Been Performed On-Site For Well Over A Year.
Also In The Area Were Two 55-Gallon Drums And Several Smaller Containers (Photos 5 And 6). Mr. Perez Stated That These Containers Came From Tecnico Corporation At 490 Levy Road, Which Closed Approximately One Month Prior To The Mer Inspection. One Of The Drums Had A Hazardous Waste Label Which Read "Waste Solids Containing Flammable Liquids (Toluene, Mek)," And Had The Hazardous Waste Codes D001/D005/D006/ D007/D008/D035/F003/F005 Listed On The Label. This Drum Was Closed. The Second Drum Contained Paint Waste; However, Mr. Perez Was Unsure What Kind Of Waste Paint It Held. It Could Not Be Determined During The Inspection What Waste The Smaller Containers Held. Mr. Perez Stated That These Wastes Had Been Removed From Tecnico By Mer And Placed In The Pole Barn At |
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02/05/2010 |
Submittal Received By Department |
Received for SUBMITTAL RECEIVED BY DEPARTMENT-12/09/2009 ; Finished-02/05/2010 |
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02/05/2010 |
Submittal Received By Department |
Received for SUBMITTAL RECEIVED BY DEPARTMENT-12/22/2009 ; Finished-02/05/2010 |
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02/05/2010 |
Informal Verbal Enforcement |
Closed for Informal Verbal Enforcement-01/21/2010 ; Finished-02/05/2010 |
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10/16/2013 |
Site Inspection |
Routine; Hazardous Waste Transporter - Routine; Used Oil Transporter - Routine; Used Oil Generator Moran Environmental Recovery (Mer) Was Inspected On October 16, 2013, As An Unannounced Hazardous Waste Compliance Inspection. The Facility Was Last Inspected On 11/20/09, When It Was Operating As A Hazardous Waste Transporter And Used Oil/Used Oil Filter Transporter. At The Time Of The Inspection, The Facility Was Still Operating As A Hazardous Waste, Used Oil, And Used Oil Filter Transporter.
Mer Is An Environmental Services Company Which Offers Industrial And Marine Services, Site Remediation, Decontamination And Abatement Services, And Emergency Spill Response. Mr. Ryan Harris, Program Manager, Was Present For The Inspection. The Facility Consists Of Offices, A Maintenance Shop, A Wash Pad, And A Pole Barn. | Maintenance Shop:
Mer Has Several Trucks And Vehicles In Service. General Maintenance And Repair Of Those Trucks Is Performed In The Maintenance Shop.
The Facility Operates One Parts Washer, Which An Area Technician Stated Has Not Generated Any Waste For Several Years. Once Spent, Proper A Hazardous Waste Determination Should Be Performed On This Parts Washer Waste. Used Oil Is Collected In Three 55-Gallon Drums Located Inside The Shop, Which Were Properly Labeled And On A Containment Pallet (Photo 1). The Facility Should Ensure That This Containment Pallet Can Hold At Least 110% Of The Largest Used Oil Container On The Pallet. Used Oil Filters Are Collected In A 55-Gallon Drum, Which Was Properly Labeled. Spent Antifreeze Is Also Collected In This Area In A 55-Gallon Drum.
Universal Waste Area:
The Facility Collects E-Waste And Universal Waste Lamps In The Corner Of The Maintenance Shop. At The Time Of The Inspection, The Facility Had Several Dozen Lamps That Were Not In Containers (Photo 2). The Facility Should Store Spent Universal Waste Lamps In Containers That Are Closed, Secure, And Labeled "Universal Waste Lamps" [40 Cfr 273.13(D) And 273.14(E)].
Wash Pad:
A Large Concrete Pad Located In The Rear Of The Facility Is Used To Park Full Tanker Trucks And To Wash Them Out. If Mer Picks Up A Load Of Oily Water From A Customer, And Is Not Immediately Able To Transport It To Water Recovery Llc (Wri) For Processing, The Truck Is Parked On The Pad And Then Taken To Wri The Next Morning. The Facility Also Washes Out The Insides Of Their Skids/Tanker Trucks Onto The Pad. This Wastewater Is Allowed To Drain Into A Sump, And It'S Either Pumped Directly Into Another Tanker Truck To Be Hauled To Wri, Or It Is Pumped Into A Wastewater Tank Located On The Pad (Photo 3).
Some Parts Of The Pad Contained Cracks That Appeared To Have Been Resealed. This Is An Area Of Concern. Due To The Potential For Oily Water To Sit On This Pad And Potentially Migrate Through The Cracks Into The Soil Beneath The Pad, The Facility Should Inspect This Pad On A Regular Basis And Follow Best Management Practices To Reseal The Pad And Routinely Check For New Cracks As Needed.
Pole Barn:
The Pole Barn Contains Two Conex Boxes Full Of Spill Control Material And Equipment. Large Hoses And Other Parts And Equipment Are Stored In This Area. Also In This Area Is A Secondary Containment Pad That Had A Couple Of 55-Gallon Containers Of Product Chemicals In One Corner. In Another Corner Of The Pad Were Nine Small Buckets That Were That Were Labeled "Pending Analysis." Just Next To These Closed Buckets Was An Unlabeled 55-Gallon Poly Drum That Was Full. Mr. Harris Was Unaware Of The Contents Of These Containers. Subsequent To The Inspection, The Facility Identified Eight Of These Buckets As Either A Product Or A Non-Hazardous Waste. The 55-Gallon Poly Drum Was Tested And Determined To Be A D002 Hazardous Waste. This Drum Has Been Labeled And Dated, And Is Currently Awaiting Disposal.
Record Review:
Mer Is Currently Operating As A Hazardous Waste Transporter And Used Oil/Used Oil Filter Transporter. According To Mr. Harris, Even Though It Is Registered As A Hazardous Waste Transporter, Mer Does Not Routinely Tr |
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12/11/2013 |
Informal Verbal Enforcement |
Finished-12/11/2013 ; Closed for Informal Verbal Enforcement-12/11/2013 |
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09/06/2017 |
Site Inspection |
Routine; Non-Handler - Routine; Hazardous Waste Transporter - Routine; Used Oil Transporter - Routine; Universal Waste Transporter - Routine; Used Oil Generator Moran Environmental Recovery, Llc (Mer) Was Inspected On September 6, 2017. The Facility Was Last Inspected By The Department'S Hazardous Waste Program On October 16, 2013. The Facility Is A Registered Hazardous Waste Transporter, Used Oil And Used Oil Filter Transporter, Universal Waste Transporter And A Non-Handler Of Hazardous Waste. Mer Has Approximately 20 Employees, Is Connected To City Water And Sewer And Has Operated At This Location Since 2001. Mr. Ryan Harris, Mer Business Manager, Was Present Throughout The Inspection. Mer Has Been Assigned Epa Id Number Fld 092 718 576. Please Use This Number On All Hazardous Waste Related Correspondence With The Department.
| Mer Is An Environmental Services Company That Offers Industrial And Marine Services, Site Remediation, Decontamination And Abatement Services, And Emergency Spill Response. The Facility Consists Of The Main Building With Administrative Offices And A Maintenance Shop, An Outside Wash Pad And A Pole Barn.
Summary Of Mer'S Registered Transporter Activities.
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Hazardous Waste Transporter: According To Mr. Harris, Even Though It Is Registered As A Hazardous Waste Transporter, Mer Does Not Routinely Transport Hazardous Waste. Mer Maintains Its Status As A Hazardous Waste Transporter In Case Of Emergency, But Mer Usually Contracts-Out This Activity. Mer Has Not Transported Any Hazardous Waste In The Last Three Years.
Used Oil And Used Oil Filter Transporter: The Majority Of Mer'S Transportation Operations Consist Of Used Oil, Used Oil Filters, Bilge Water And Oily Waste Water. These Waste Streams Are Generally Transported To Water Recovery, Inc. (Flr 000 069 062) For Processing.
Universal Waste Transporter: Mer Maintains Its Status As A Universal Waste Transporter In Case Of Emergency, But Mer Does Not Routinely Transport Universal Wastes. Mer Has Not Transported Any Universal Waste In The Last Three Years.
Summary Of Facility Areas Inspected.
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Maintenance Shop
Mer Has One Vacuum Truck, One Combination Blower/Vacuum Truck, One 3,500-Gallon Tanker Trailer, One 5,000-Gallon Tanker Trailer And One Stakebed Truck In Service. Vehicles Are Parked Behind The Main Office Building And Adjacent To The Facility'S Maintenance Shop Area (Photos 1 And 2). Mer Can Also Use Additional Trucks Via A Cooperative Service Agreement It Maintains With Jacksonville Spillage Control. General Maintenance Of Vehicles Is Performed In The Maintenance Shop Area (Photo 3). The Facility Operates One Aqueous Parts Washer That An Area Technician Stated Has Not Generated Any Waste For Several Years. A Waste Determination Was Previously Performed On The Parts Washer Liquid Waste And The Filter. Both Were Determined To Be Non-Hazardous. Used Oil And Used Oil Filters Are Collected In 55-Gallon Drums Located Inside The Shop. The Drums Were Properly Closed And Labeled And On A Containment Pallet. At The Time Of The Inspection, There Were Numerous Oil Filters Staged On Top Of Threaded Drain Pains That Were Attached To The Top Of Each Used Oil Drum. This Is An Area Of Concern. The Facility Should Ensure Timely Containerization Of The Drained Used Oil Filters. Spent Antifreeze Is Also Collected In This Area In A 55-Gallon Drum.
Universal Waste Area
The Facility Stages Electronic Waste And Universal Waste In The Corner Of The Maintenance Shop (Photo 4). At The Time Of The Inspection, There Were Three Containers Of Universal Waste Mercury-Containing Lamps In The Area That Mer Generated. The Containers Were Closed, Labeled And Had Been Accumulating For Less Than A Year. There Were No Containers Of Customer-Generated Universal Waste In The Area At The Time Of The Inspection.
Wash Pad
A Large Concrete Pad Located In The Rear Of The Facility Is Used To Temporarily Park Tanker Trucks Of Used Oil And Oily Water And As A W |
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12/20/2017 |
Issue Non-Compliance Letter |
Compliance Assistance Offer Written-12/06/2017 ; Finished-12/20/2017 |
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07/22/2021 |
Site Inspection |
Routine; CESQG (<100 kg/month) - Routine; Hazardous Waste Transporter - Routine; Used Oil Transporter - Routine; Used Oil Generator - Routine; VSQG (<100 kg/month) Moran Environmental Recovery, Llc (Mer) Was Inspected On July 22, 2021. The Facility Was Last Inspected By The Department'S Hazardous Waste Program On September 6, 2017. The Facility Is A Registered Hazardous Waste Transporter, Used Oil And Used Oil Filter Transporter, Universal Waste Transporter, Petroleum Contact Water (Pcw) Transporter, And A Very Small Quantity Generator (Vsqg) Of Hazardous Waste. Mer'S Mr. Ryan Harris (Business Manager), Ryan Hopkins (Esh), And Keith Harmon (Logistics) Were Present During The Inspection.
Mer Is An Environmental Services Company That Offers Industrial And Marine Services, Site Remediation, Decontamination And Abatement Services, And Emergency Spill Response. Mer Has Approximately 20 Employees And Operates Monday Through Friday From 8:00 Am To 5:00 Pm And Is On-Call 24/7 To Perform Emergency Response Services. Mer Has Operated At This Location Since 2001 And The Facility Is Connected To City Water And Sewer. The Facility Consists Of The Main Building With Administrative Offices And A Maintenance Shop, A Wash Pad And Tank Farm, And A Pole Barn.
Hazardous Waste Transporter: Mer Typically Transports Hazardous Waste In Florida From Three To Five Routine Customers; However, Mer’S Epa Id#Fld092718576 Is Used To Transport Hazardous Waste In Other States. Universal Waste Transporter: Mer Maintains Its Status As A Universal Waste Transporter In Case Of Emergency, But Mer Does Not Routinely Transport Universal Wastes. Used Oil And Used Oil Filter Transporter, And Pcw Transporter: The Majority Of Mer'S Transportation Operations Consist Of Used Oil, Used Oil Filters, Bilge Water, Oily Waste Water And Pcw. These Wastestreams Are Generally Transported To Water Recovery, Llc (Water Recovery, Flr000069062) For Processing.
| Maintenance Shop And Warehouse
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Mer Operates Two 3,000-Gallon Vacuum Trucks, One Combination Blower/Vacuum Truck, One 3,500-Gallon Tanker Trailer, One 5,000-Gallon Tanker Trailer, One Stakebed/Lift Gate Truck And Several Service Pickup Trucks. Vehicles Are Parked Behind The Main Office Building And Adjacent To The Facility'S Maintenance Shop Area (Photo 1). General Maintenance Of Vehicles Is Performed In The Maintenance Shop Area. Used Oil And Used Oil Filters Are Collected In 55-Gallon Drums Located Inside The Shop (Photo 2). The Drums Were Closed, Properly Labeled And Located On A Containment Pallet Inside The Warehouse. The Facility Operates One Aqueous Parts Washer That An Area Technician Stated Has Not Generated Any Waste In The Previous Three Years. A Waste Determination Previously Performed Several Years Ago Indicated The Spent Solvent Was Non-Hazardous. The Facility Is Reminded That A Waste Determination Should Be Performed Prior To Disposal. Spent Antifreeze Is Collected In A 55-Gallon Drum And Analyzed Prior To Disposal. Technicians Use Aerosol Lubricants And Penetrants On Shop Rags That Are Collected And Disposed Along With Absorbents In A Dumpster Located Adjacent To The Shop And Described Further Below. Aerosol Cans Are Punctured In A Drum-Top Puncturer Attached To A 55-Gallon Satellite Drum (Photo 3). The Drum Was Closed And Properly Labeled. Aerosol Can Puncturing Is A New Process And No Waste Has Been Disposed. The Facility Is Reminded That A Waste Determination Should Be Performed Prior To Disposal By Either Sampling The Waste Or Maintaining An Inventory Log Of All Aerosol Cans Punctured.
Oily Rags, Absorbents And Spill Clean-Up Debris Generated From Vehicle Maintenance Activities At The Facility And During Mer’S Used Oil Transportation Activities Are Collected In A Solid Waste Dumpster Located Outside The Maintenance Shop And Disposed At Chesser Island Landfill In Folkston, Ga. Mer Manages Its Transportation-Related Waste As Non-Hazardous Waste, But It Has Not Made A Hazardous Waste Determination On This Wastestream By Having The Waste Analyzed For Hazard |
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10/21/2021 |
Issue Non-Compliance Letter |
Sent-10/21/2021 ; Return to Compliance Letter Sent (RCL)-01/24/2022 ; Finished-01/24/2022 |
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03/19/2025 |
Site Inspection |
Routine; CESQG (<100 kg/month) - Routine; Hazardous Waste Transporter - Routine; Used Oil Transporter - Routine; Used Oil Generator - Routine; VSQG (<100 kg/month) |
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