04/16/1990 |
Legacy Site Inspection |
Downloaded From Rcris On 18-Oct-96 Downloaded From Rcris On 18-Oct-96 |
|
09/21/1990 |
Warning Letter Issued |
Downloaded From Rcris On 18-Oct-96 Downloaded From Rcris On 18-Oct-96 |
|
10/16/1990 |
File Review |
Downloaded From Rcris On 18-Oct-96 Downloaded From Rcris On 18-Oct-96 |
|
10/25/1990 |
Other Inspection |
Downloaded From Rcris On 18-Oct-96 Downloaded From Rcris On 18-Oct-96 |
|
08/06/1991 |
Notice Of Violation Issued |
Downloaded From Rcris On 18-Oct-96 Downloaded From Rcris On 18-Oct-96 |
|
06/19/1992 |
Consent Order Executed |
Downloaded From Rcris On 18-Oct-96 Downloaded From Rcris On 18-Oct-96 |
|
02/19/1993 |
Legacy Site Inspection |
Downloaded From Rcris On 18-Oct-96 Downloaded From Rcris On 18-Oct-96 |
|
04/12/1993 |
Warning Letter Issued |
Downloaded From Rcris On 18-Oct-96 Downloaded From Rcris On 18-Oct-96 |
|
04/21/1993 |
Sampling Inspection |
Downloaded From Rcris On 18-Oct-96 Downloaded From Rcris On 18-Oct-96 |
|
11/04/1993 |
Contamination Assessment Plan |
Cap/Qapp Add. Submitted Cap/Qapp Add. Submitted |
|
11/05/1993 |
Letter |
Response To Dept. Settlement Offer Due | Expect Response On Settlement Offer From Howco Atty. Response To Dept. Settlement Offer Due | Expect Response On Settlement Offer From Howco Atty. |
|
11/08/1993 |
Contamination Assessment Plan |
Cap Add. Submitted To Tally For Review | Cap Add. Review Recvd From Tally-Approved Cap Add. Submitted To Tally For Review | Cap Add. Review Recvd From Tally-Approved |
|
11/08/1993 |
Quality Assurance Project Plan |
Qapp Add. #2 Submitted To Tally For Review | Returned W/ Revisions Required Qapp Add. #2 Submitted To Tally For Review | Returned W/ Revisions Required |
|
12/03/1993 |
Telephone Conversation |
Counter Offer From Joseph Mcnabb Due Counter Offer From Joseph Mcnabb Due |
|
01/27/1994 |
Letter |
Settlement Offer To L. Lockett-Response Due | J. Mcnabb Scheduled Meeting To Discuss Case Settlement Offer To L. Lockett-Response Due | J. Mcnabb Scheduled Meeting To Discuss Case |
|
03/09/1994 |
Enforcement Meeting |
B. Knauss To Make Decision On Further Enforcement Actions | Case Closed-Outstanding Issues Addressed In Subsequent Inspections B. Knauss To Make Decision On Further Enforcement Actions | Case Closed-Outstanding Issues Addressed In Subsequent Inspections |
|
03/15/1994 |
Legacy Site Inspection |
Wl Issuance Due Wl Issuance Due |
|
03/31/1994 |
Quality Assurance Project Plan |
Qapp Revisions Due/Dep Ltr. Also Incl. Notice Of Cap Approval Qapp Revisions Due/Dep Ltr. Also Incl. Notice Of Cap Approval |
|
05/25/1994 |
Quality Assurance Project Plan |
Qapp Review Due From Tally | Qapp Approved-D. Adams Qapp Review Due From Tally | Qapp Approved-D. Adams |
|
05/31/1994 |
Warning Letter Issued |
Response To Wl Due | B. Knauss To Schedule Meeting Upon Receipt Of Sampling Guidelines Response To Wl Due | B. Knauss To Schedule Meeting Upon Receipt Of Sampling Guidelines |
|
07/26/1994 |
Permit Condition Or Consent Order/Response Due |
Notice To Implement Cap-First Monthly Progress Report Due | Site Health&Safety Plan Prepared/Well Survey Begun Notice To Implement Cap-First Monthly Progress Report Due | Site Health&Safety Plan Prepared/Well Survey Begun |
|
10/04/1994 |
Contamination Assessment Plan |
2nd Monthly Progress Report Due 2nd Monthly Progress Report Due |
|
11/03/1994 |
Contamination Assessment Plan |
3rd Monthly Progress Report Due 3rd Monthly Progress Report Due |
|
12/01/1994 |
Contamination Assessment Plan |
4th Monthly Progress Report Due 4th Monthly Progress Report Due |
|
12/28/1994 |
Contamination Assessment Plan |
Monthly Progress Report Due Monthly Progress Report Due |
|
02/02/1995 |
Contamination Assessment Plan |
Monthly Progress Report Due | No Progress Reported In Progress Report-Notified Consultant Will Be Proceeding W/ Enf. Action Against Howco To Implement Cap Monthly Progress Report Due | No Progress Reported In Progress Report-Notified Consultant Will Be Proceeding W/ Enf. Action Against Howco To Implement Cap |
|
03/03/1995 |
Contamination Assessment Plan |
Recvd. Progress Report-Will Install 6 Mw'S On 3/13 & 3/14 Recvd. Progress Report-Will Install 6 Mw'S On 3/13 & 3/14 |
|
04/05/1995 |
Contamination Assessment Plan |
Monthly Progress Report Due-Wells To Have Been Installed And Sampled In March Monthly Progress Report Due-Wells To Have Been Installed And Sampled In March |
|
04/14/1995 |
Permit Condition Or Consent Order/Response Due |
Status Report Due-Initial Gw Sampling Results From 6 Wells | Gw Sampling Results Indicate Heavy Cont.-Supplemental Work Proposed Status Report Due-Initial Gw Sampling Results From 6 Wells | Gw Sampling Results Indicate Heavy Cont.-Supplemental Work Proposed |
|
05/04/1995 |
Permit Condition Or Consent Order/Response Due |
Monthly Status Report Recvd.-Preparing Proposal For Further Work Monthly Status Report Recvd.-Preparing Proposal For Further Work |
|
06/06/1995 |
Permit Condition Or Consent Order/Response Due |
Monthly Status Report Due W/ Proposal For Further Work Monthly Status Report Due W/ Proposal For Further Work |
|
06/26/1995 |
Letter |
Settlement Offer To T. Hagan/Tastemaker Case Also-Response Due | L. Lockett-Agree To Offer If Can Drop Part A Permit Settlement Offer To T. Hagan/Tastemaker Case Also-Response Due | L. Lockett-Agree To Offer If Can Drop Part A Permit |
|
07/03/1995 |
Permit Condition Or Consent Order/Response Due |
Monthly Status Report Due Monthly Status Report Due |
|
07/07/1995 |
Permit Condition Or Consent Order/Response Due |
June Status Report Promised Further Scope Of Work Submittal | Supplemental Scope Of Work Submitted June Status Report Promised Further Scope Of Work Submittal | Supplemental Scope Of Work Submitted |
|
08/04/1995 |
Permit Condition Or Consent Order/Response Due |
Monthly Status Report Due Monthly Status Report Due |
|
08/24/1995 |
Contamination Assessment Plan |
Fgs Proposal For Further Work To J. Armstrong 7/13-Review Due | Recvd. Comments-Further Soil Confirm. Samples Needed Otherwise Ok Fgs Proposal For Further Work To J. Armstrong 7/13-Review Due | Recvd. Comments-Further Soil Confirm. Samples Needed Otherwise Ok |
|
09/05/1995 |
Permit Condition Or Consent Order/Response Due |
Monthly Status Report Due | Further Work To Be Implemented Upon Receipt Of J. Armstrong'S Comments Monthly Status Report Due | Further Work To Be Implemented Upon Receipt Of J. Armstrong'S Comments |
|
10/10/1995 |
Permit Condition Or Consent Order/Response Due |
Status Report Due On Implementation Of Further Work-Review To Fgs 9/6 | Fgs Reports Supplemental Work To Be Implemented 10/95 Status Report Due On Implementation Of Further Work-Review To Fgs 9/6 | Fgs Reports Supplemental Work To Be Implemented 10/95 |
|
10/31/1995 |
Permit Condition Or Consent Order/Response Due |
Apply For Permit Renewal Apply For Permit Renewal |
|
11/07/1995 |
Permit Condition Or Consent Order/Response Due |
Monthly Status Report Due-Fgs Implementing Supp. Work | Soil Sampling & Wells Installed Between 10/24-11/3 Monthly Status Report Due-Fgs Implementing Supp. Work | Soil Sampling & Wells Installed Between 10/24-11/3 |
|
12/04/1995 |
Permit Condition Or Consent Order/Response Due |
Monthly Status Report Due | Car Draft To Be Submitted To Howco 12/95 Monthly Status Report Due | Car Draft To Be Submitted To Howco 12/95 |
|
12/29/1995 |
Permit Condition Or Consent Order/Response Due |
Monthly Status Report & Car Due Per 12/1 Status Report | Still Working On Car-Telecon W/ Maura Clark 1/11-Payment Problems, Have Suspended Work Monthly Status Report & Car Due Per 12/1 Status Report | Still Working On Car-Telecon W/ Maura Clark 1/11-Payment Problems, Have Suspended Work |
|
01/11/1996 |
Telephone Conversation |
Maura Clark Says Fgs Pres. To Meet W/ T. Hagan Over Payment Problems-Will Notify Me Of Results | February Report Says 5 Areas Of Site Are Atrp-Eligible, Will Be Meeting With Tally Personnel Over Reimbursement Issues Maura Clark Says Fgs Pres. To Meet W/ T. Hagan Over Payment Problems-Will Notify Me Of Results | February Report Says 5 Areas Of Site Are Atrp-Eligible, Will Be Meeting With Tally Personnel Over Reimbursement Issues |
|
02/01/1996 |
Permit Condition Or Consent Order/Response Due |
Monthly Status Report Due | Car In Preparation-5 Areas Of Site Atrp Eligible Monthly Status Report Due | Car In Preparation-5 Areas Of Site Atrp Eligible |
|
03/04/1996 |
Permit Condition Or Consent Order/Response Due |
February Report-Car 95% Done-Will Submit By End Of March February Report-Car 95% Done-Will Submit By End Of March |
|
04/04/1996 |
Permit Condition Or Consent Order/Response Due |
Monthly Report And Car Due | Recvd. Status Report Promising Car By 4/12 Monthly Report And Car Due | Recvd. Status Report Promising Car By 4/12 |
|
04/19/1996 |
Contamination Assessment Report |
Recvd. In Swd 4/19-Forwarded To Bwc 4/23-Review Due | Recvd. Car Review From J. Armstrong Recvd. In Swd 4/19-Forwarded To Bwc 4/23-Review Due | Recvd. Car Review From J. Armstrong |
|
05/03/1996 |
Permit Condition Or Consent Order/Response Due |
Submittal Of April Status Report Submittal Of April Status Report |
|
06/01/1996 |
Permit Condition Or Consent Order/Response Due |
May Status Report Due May Status Report Due |
|
07/05/1996 |
Permit Condition Or Consent Order/Response Due |
June Status Report Due June Status Report Due |
|
07/09/1996 |
Contamination Assessment Report |
Car Review Comments To Howco-Phase Ii Cap Due | Meeting Held 8/12-Howco Will Do No Further Work Until Site Is Ranked For Atrp Funding Car Review Comments To Howco-Phase Ii Cap Due | Meeting Held 8/12-Howco Will Do No Further Work Until Site Is Ranked For Atrp Funding |
|
08/05/1996 |
Permit Condition Or Consent Order/Response Due |
Monthly Status Report Recvd. Monthly Status Report Recvd. |
|
09/06/1996 |
Permit Condition Or Consent Order/Response Due |
Monthly Status Report Recvd.-No Further Work Will Be Done Until Site Is Ranked For Atrp Funding Monthly Status Report Recvd.-No Further Work Will Be Done Until Site Is Ranked For Atrp Funding |
|
10/06/1996 |
Case Closed By District |
Site Atrp Eligible & Ranked Below Level To Require Further Assess Site Atrp Eligible & Ranked Below Level To Require Further Assess |
|
10/16/1996 |
Legacy Site Inspection |
Inspection Report Due | Option 1 Wl Issued Inspection Report Due | Option 1 Wl Issued |
|
10/16/1996 |
Case Closed By District |
Violation Addressed As Part Of 10/16/96 Cei Violation Addressed As Part Of 10/16/96 Cei |
|
04/02/1997 |
Significant Non-Complier - Yes |
|
|
04/11/1997 |
Warning Letter Issued |
Response To Wl Due | L. Lockett Left Message 5/2: Will Send Written Response 2 Weeks Response To Wl Due | L. Lockett Left Message 5/2: Will Send Written Response 2 Weeks |
|
04/11/1997 |
Civil Penalty Authorization Memo |
Pa To Tally 4/11 - Review Due | Pa Approved Pa To Tally 4/11 - Review Due | Pa Approved |
|
07/16/1997 |
Enforcement Meeting |
Position Letter To Howco Due Position Letter To Howco Due |
|
09/08/1997 |
Letter |
Settlement Offer To L. Lockett 9/8-Response Due | Letter From L. Lockett-Going On Vacation, Will Respond After 9/25 Settlement Offer To L. Lockett 9/8-Response Due | Letter From L. Lockett-Going On Vacation, Will Respond After 9/25 |
|
09/16/1997 |
Letter |
Settle Offer Due From L. Lockett Settle Offer Due From L. Lockett |
|
12/16/1997 |
Letter |
Settlement Offer To L. Lockett 12/16 - Response Due | First Detailed Written Response To Wl Ever Received Settlement Offer To L. Lockett 12/16 - Response Due | First Detailed Written Response To Wl Ever Received |
|
03/06/1998 |
Letter |
Response To Settlement Offer Due Response To Settlement Offer Due |
|
03/11/1998 |
Draft Consent Order Issued |
|
|
09/14/1998 |
Telephone Conversation |
Telecon W/ Hagan - Co Due Or Issue Nov Telecon W/ Hagan - Co Due Or Issue Nov |
|
09/29/1998 |
Legacy Site Inspection |
Inspection Report Due Inspection Report Due |
|
01/07/1999 |
Draft Consent Order Issued |
Latest Draft Issued - Response Due Latest Draft Issued - Response Due |
|
04/28/1999 |
Draft Consent Order Issued |
Final Draft Mailed 4/28 - Return Of Signed Order Due Final Draft Mailed 4/28 - Return Of Signed Order Due |
|
05/03/1999 |
Submittal Received By Department |
Response To 5th Nod Response To 5th Nod |
|
05/11/1999 |
Submittal Received By Department |
Response To 5th Nod (Statistical Sampling Plan) Response To 5th Nod (Statistical Sampling Plan) |
|
06/08/1999 |
Legacy Site Inspection |
Completed Review Of Responses To 5th Nod, Inadequate Completed Review Of Responses To 5th Nod, Inadequate |
|
06/10/1999 |
Warning Letter Issued |
Penalty Assessed For 6th Nod Penalty Assessed For 6th Nod |
|
06/16/1999 |
Consent Order Executed |
Co Includes Penalties, 2nd Contain Upgrades And Waste Determ Co Includes Penalties, 2nd Contain Upgrades And Waste Determ |
|
06/16/1999 |
Significant Non-Complier - No |
Facility Rtc W/ Execution Of Co 6/16/99 Facility Rtc W/ Execution Of Co 6/16/99 |
|
07/06/1999 |
Permit Condition Or Consent Order/Response Due |
1 Of 12 $1762.50 Payment Due 1 Of 12 $1762.50 Payment Due |
|
07/12/1999 |
Permit Condition Or Consent Order/Response Due |
Tclp Sampling Of Wwts And Oes Done 7/12 - Results Due Tclp Sampling Of Wwts And Oes Done 7/12 - Results Due |
|
07/19/1999 |
Permit Condition Or Consent Order/Response Due |
Proof Of Publication Due Proof Of Publication Due |
|
07/21/1999 |
Permit Condition Or Consent Order/Response Due |
Pressure Test On All Underground Piping Due | Testing Performed 7/21 - Results Recvd Swd 8/25 - All Pass Pressure Test On All Underground Piping Due | Testing Performed 7/21 - Results Recvd Swd 8/25 - All Pass |
|
07/21/1999 |
Enforcement Meeting |
|
|
07/30/1999 |
Letter |
Response To 6th Nod Due 30 Days After Dep Response Response To 6th Nod Due 30 Days After Dep Response |
|
08/24/1999 |
Permit Condition Or Consent Order/Response Due |
2 Of 12 $1762.50 Payment Due 2 Of 12 $1762.50 Payment Due |
|
08/27/1999 |
Letter |
Written Response Concerning Dep'S Position Written Response Concerning Dep'S Position |
|
09/16/1999 |
Permit Condition Or Consent Order/Response Due |
Notification Of Piping Upgrade Due | Facility Declined P2 Credit For Piping Upgrade-Paid Addtl $5000 Notification Of Piping Upgrade Due | Facility Declined P2 Credit For Piping Upgrade-Paid Addtl $5000 |
|
09/16/1999 |
Permit Condition Or Consent Order/Response Due |
$5000 Payment Due - Did Not Elect To Upgrade Piping W/ 2nd Containment $5000 Payment Due - Did Not Elect To Upgrade Piping W/ 2nd Containment |
|
09/17/1999 |
Compliance Evaluation Inspection |
Inspection Report Completed And Sent Out Inspection Report Completed And Sent Out |
|
09/24/1999 |
Permit Condition Or Consent Order/Response Due |
3 Of 12 $1762.50 Paement Due 3 Of 12 $1762.50 Paement Due |
|
09/24/1999 |
Letter |
Solid Waste Permitting Comments, Including Asking For $2000 Fee Solid Waste Permitting Comments, Including Asking For $2000 Fee |
|
09/28/1999 |
Project Closed Letter |
In-Compliance Letter Sent Out In-Compliance Letter Sent Out |
|
10/11/1999 |
Permit Condition Or Consent Order/Response Due |
2 Of 4 Tclp Sampling Of Wwts And Oes Due | Sample Failed For Benzene - Next 2 Batches To Be Sampled 2 Of 4 Tclp Sampling Of Wwts And Oes Due | Sample Failed For Benzene - Next 2 Batches To Be Sampled |
|
10/27/1999 |
Submittal Received By Department |
Official Response To 6th Nod Official Response To 6th Nod |
|
10/29/1999 |
Permit Condition Or Consent Order/Response Due |
4 Of 12 $1762.50 Payment Due 4 Of 12 $1762.50 Payment Due |
|
11/19/1999 |
Letter |
Howco Respond By 12/3 On What Their Position On Sampling & Analysis Of Outbound Oil Howco Respond By 12/3 On What Their Position On Sampling & Analysis Of Outbound Oil |
|
11/22/1999 |
Permit Condition Or Consent Order/Response Due |
Wwt Sludge Sampled - Results Due | 3 Additional Batches Sampled- 1st Failed, Nest Two Passed Wwt Sludge Sampled - Results Due | 3 Additional Batches Sampled- 1st Failed, Nest Two Passed |
|
11/29/1999 |
Permit Condition Or Consent Order/Response Due |
5 Of 12 $1762.50 Payment Due 5 Of 12 $1762.50 Payment Due |
|
11/30/1999 |
Permit Condition Or Consent Order/Response Due |
Wwt Sludge Sampled - Results Due Wwt Sludge Sampled - Results Due |
|
12/03/1999 |
File Review |
No Response From Howco; Application Determined To Be Complete No Response From Howco; Application Determined To Be Complete |
|
12/10/1999 |
Permit Condition Or Consent Order/Response Due |
Pe Cert Due Of Completion Of Uo Container Storage Area Upgrades Pe Cert Due Of Completion Of Uo Container Storage Area Upgrades |
|
12/10/1999 |
Permit Condition Or Consent Order/Response Due |
Pe Cert Due Of Completion Of South Contain #2 Upgrade Pe Cert Due Of Completion Of South Contain #2 Upgrade |
|
12/10/1999 |
Permit Condition Or Consent Order/Response Due |
Pe Cert Due Of Contain For Tank #110 & #111 Pe Cert Due Of Contain For Tank #110 & #111 |
|
12/10/1999 |
Permit Condition Or Consent Order/Response Due |
Completion Of Application Of Impervious Coating To Contain #2 Completion Of Application Of Impervious Coating To Contain #2 |
|
01/19/2000 |
Permit Condition Or Consent Order/Response Due |
3 Of 4 Tclp Sampling Of Wwts And Oes Due | Took Split Samples W/ Howco 3 Of 4 Tclp Sampling Of Wwts And Oes Due | Took Split Samples W/ Howco |
|
01/19/2000 |
Letter |
D. Roehm Ltr W/ Sludge Tclp Results - 90-Day Time Limit For Shipment Of Hw Sludge D. Roehm Ltr W/ Sludge Tclp Results - 90-Day Time Limit For Shipment Of Hw Sludge |
|
01/19/2000 |
Interdepartmental Memo |
Took Split Samples W/ Howco - Results Due Took Split Samples W/ Howco - Results Due |
|
01/28/2000 |
Letter |
Response Due - Contain#1 Certification & Dec And Jan Payments Response Due - Contain#1 Certification & Dec And Jan Payments |
|
09/19/2000 |
Legacy Site Inspection |
Inspection Report Being Drafted. Inspection Report Being Drafted. |
|
03/20/2001 |
Enforcement Project Initiated |
|
|
03/21/2001 |
Warning Letter Issued |
Awaiting Response From Generator. Meeting Scheduled For April 19th. Awaiting Response From Generator. Meeting Scheduled For April 19th. |
|
03/21/2001 |
Significant Non-Complier - Yes |
|
|
04/19/2001 |
Enforcement Meeting |
Howco Will Provide Counteroffer Within One Week. Howco Will Provide Counteroffer Within One Week. |
|
04/20/2001 |
Meeting |
Visited Site To Check Corrected Violations. Visited Site To Check Corrected Violations. |
|
04/23/2001 |
Letter |
Extension For Reply To Wl Approved Until 23 May 2001. Extension For Reply To Wl Approved Until 23 May 2001. |
|
05/04/2001 |
Submittal Received By Department |
Counter Offer Received. Offer $200.00. Rejected. Counter Offer Received. Offer $200.00. Rejected. |
|
05/08/2001 |
Meeting |
Discuss Format For Wl Response And Hw Used Oil Problem. Discuss Format For Wl Response And Hw Used Oil Problem. |
|
05/18/2001 |
Letter |
Rejection Of Howco Penalty Counteroffer. Draft Sco Submitted. Rejection Of Howco Penalty Counteroffer. Draft Sco Submitted. |
|
05/29/2001 |
Submittal Received By Department |
Counteroffer Of $500 Received From Howco. Unacceptable. Drafting Case Report For Ogc. Counteroffer Of $500 Received From Howco. Unacceptable. Drafting Case Report For Ogc. |
|
08/14/2001 |
Legacy Site Inspection |
|
|
08/14/2001 |
Significant Non-Complier - Yes |
|
|
08/16/2001 |
File Review |
Data Cleanup - Permit Has Been Issued, Case Closed Data Cleanup - Permit Has Been Issued, Case Closed |
|
08/16/2001 |
Compliance W/O Formal Enforcement Action |
|
|
08/16/2001 |
Case Closed By District |
|
|
08/31/2001 |
Case Referred To Ogc |
|
|
10/05/2001 |
Enforcement Meeting |
Teleconference-Hagan/Lockett/Dempsey/Tam/Gephart/Dregne. Teleconference-Hagan/Lockett/Dempsey/Tam/Gephart/Dregne. |
|
10/10/2001 |
Short Form Consent Order Issued |
Order Signed By Hagan. Order Signed By Hagan. |
|
10/26/2001 |
Short Form Consent Order Executed |
First Payment Due In 90 Days> First Payment Due In 90 Days> |
|
10/26/2001 |
Significant Non-Complier - No |
|
|
10/26/2001 |
Return To Compliance From Formal Enforcement |
|
|
11/05/2001 |
Warning Letter Issued |
Suspense Nov 20, 2001. Suspense Nov 20, 2001. |
|
12/04/2001 |
Enforcement Meeting |
Will Come Back With Counter Offer In Thirty Days. Will Come Back With Counter Offer In Thirty Days. |
|
12/14/2001 |
Permit Condition Or Consent Order/Response Due |
First Payment Received. Second Payment Due 10 Feb 02. Ogc#01-1496c. First Payment Received. Second Payment Due 10 Feb 02. Ogc#01-1496c. |
|
01/04/2002 |
Submittal Received By Department |
Counter Offer Received, $1898.00. Under Review. Counter Offer Received, $1898.00. Under Review. |
|
02/04/2002 |
Permit Condition Or Consent Order/Response Due |
Second Payment Received. Third Payment Due 10 March 2001. $1000. Second Payment Received. Third Payment Due 10 March 2001. $1000. |
|
02/27/2002 |
Letter |
Howco Counteroffer Rejected. New Offer Proposed Using Elra. $10,000. Howco Counteroffer Rejected. New Offer Proposed Using Elra. $10,000. |
|
02/28/2002 |
Letter |
Elra Counteroffer Letter. Elra Counteroffer Letter. |
|
03/18/2002 |
Submittal Received By Department |
Department Offer Accepted. Waiting For Financial Assurance Submission To Solid Waste. Cost Estimate Approved. Department Offer Accepted. Waiting For Financial Assurance Submission To Solid Waste. Cost Estimate Approved. |
|
04/18/2002 |
Permit Condition Or Consent Order/Response Due |
Third Payment Received, Fourth Payment Due. $1000. Third Payment Received, Fourth Payment Due. $1000. |
|
04/25/2002 |
Telephone Conversation |
Company Using Fictitious Name, Must Change Permit Name To Real Name Before Solid Waste Division Will Process Financial Assurance. Company Using Fictitious Name, Must Change Permit Name To Real Name Before Solid Waste Division Will Process Financial Assurance. |
|
04/29/2002 |
Permit Condition Or Consent Order/Response Due |
Final Payment Received. $1000.00. Final Payment Received. $1000.00. |
|
05/08/2002 |
Project Closed Letter |
|
|
05/08/2002 |
Case Closed By District |
|
|
06/14/2002 |
Letter |
E-Mail From Howco. All Required Financial Assurance Documents Filed. E-Mail From Howco. All Required Financial Assurance Documents Filed. |
|
07/03/2002 |
Letter |
Confirmation From Sw That All Financial Assurance Documents In Order. Confirmation From Sw That All Financial Assurance Documents In Order. |
|
07/08/2002 |
Short Form Consent Order Issued |
Suspense July 25, 2002. Suspense July 25, 2002. |
|
07/24/2002 |
Legacy Site Inspection |
Preparing Draft Of Cei Report Preparing Draft Of Cei Report |
|
07/26/2002 |
Short Form Consent Order Executed |
|
|
07/26/2002 |
Significant Non-Complier - No |
|
|
07/26/2002 |
Return To Compliance From Formal Enforcement |
|
|
07/26/2002 |
Return To Compliance Letter |
|
|
08/15/2002 |
Penalty Received |
First Payment Received. Second Payment Due Sep 5 2002. First Payment Received. Second Payment Due Sep 5 2002. |
|
09/17/2002 |
Penalty Received |
Second Payment Received. Third Payment Due Oct 5, 2002. Second Payment Received. Third Payment Due Oct 5, 2002. |
|
10/11/2002 |
Penalty Received |
Third Payment Received. Fourth Payment Due November 5, 2002. Third Payment Received. Fourth Payment Due November 5, 2002. |
|
11/12/2002 |
Penalty Received |
Fourth Payment Received. Fifth Payment Due December 5, 2002. Fourth Payment Received. Fifth Payment Due December 5, 2002. |
|
11/18/2002 |
Warning Letter Issued |
Facility To Schedule Meeting With Dep Within 15 Days Of Receipt Of Wl Facility To Schedule Meeting With Dep Within 15 Days Of Receipt Of Wl |
|
12/09/2002 |
Penalty Received |
Fifth Payment Received. 1010.00. Sixth Payment Due Jan 5, 2003. Fifth Payment Received. 1010.00. Sixth Payment Due Jan 5, 2003. |
|
12/11/2002 |
Enforcement Meeting |
Meeting With Facility Personnel To Review Alleged Vciolations | Outcome Of Meeting - Issue Short Form Co For Penalties Assessed Meeting With Facility Personnel To Review Alleged Vciolations | Outcome Of Meeting - Issue Short Form Co For Penalties Assessed |
|
12/19/2002 |
Draft Consent Order Issued |
Facility Is To Sign Draft Co And Return By 1/13/03 Facility Is To Sign Draft Co And Return By 1/13/03 |
|
01/15/2003 |
Penalty Received |
Sixth Payment Received. Seventh Payment Due 5 Feb. $1,010.00. Sixth Payment Received. Seventh Payment Due 5 Feb. $1,010.00. |
|
01/27/2003 |
Penalty Received |
1st Payment Of Five Received For $1,020 1st Payment Of Five Received For $1,020 |
|
01/28/2003 |
Short Form Consent Order Executed |
Facility Is To Make 5 Monthly Payments Of $1020 To Satisfy Consent Order Facility Is To Make 5 Monthly Payments Of $1020 To Satisfy Consent Order |
|
02/10/2003 |
Penalty Received |
Seventh Payment Received. Eighth Payment Due 5 Mar. 1010.00. Seventh Payment Received. Eighth Payment Due 5 Mar. 1010.00. |
|
02/26/2003 |
Penalty Received |
2nd Payment Received Of 5 Payments Due 2nd Payment Received Of 5 Payments Due |
|
03/11/2003 |
Penalty Received |
Eighth Payment Received. Nineth Payment Due 5 April. $1010.00. Eighth Payment Received. Nineth Payment Due 5 April. $1010.00. |
|
03/24/2003 |
Penalty Received |
3rd Of 5 Payments To Satisfy Enforcement Penalty 3rd Of 5 Payments To Satisfy Enforcement Penalty |
|
04/04/2003 |
Penalty Received |
Ninth Payment Received. Final Payment Due 5 May. $1010.00. Ninth Payment Received. Final Payment Due 5 May. $1010.00. |
|
04/21/2003 |
Penalty Received |
Fourth Payment Of Five Due At $1020.00 Each Fourth Payment Of Five Due At $1020.00 Each |
|
05/12/2003 |
Penalty Received |
Final Payment Received. $1010.00. Final Payment Received. $1010.00. |
|
05/28/2003 |
Penalty Received |
Fith And Last Payment Of $1,020 Fith And Last Payment Of $1,020 |
|
06/04/2003 |
Project Closed Letter |
Total Of 5 Penalty Payments Made For A Total Of $5,100 Have Been Received And Case Closed Total Of 5 Penalty Payments Made For A Total Of $5,100 Have Been Received And Case Closed |
|
06/04/2003 |
Case Closed By District |
|
|
06/04/2003 |
Project Closed Letter |
|
|
06/04/2003 |
Case Closed By District |
|
|
06/24/2003 |
Legacy Site Inspection |
|
|
11/04/2003 |
Warning Letter Issued |
|
|
12/12/2003 |
Meeting |
|
|
01/12/2004 |
Short Form Consent Order Executed |
|
|
01/12/2004 |
Return To Compliance From Formal Enforcement |
|
|
02/18/2004 |
Case Closed By District |
|
|
02/18/2004 |
Project Closed Letter |
|
|
03/04/2004 |
Legacy Site Inspection |
Compliance Activity Related To Used Oil Processing, Used Oil Transporter And Solid Waste Processing Rules Compliance Activity Related To Used Oil Processing, Used Oil Transporter And Solid Waste Processing Rules |
|
03/04/2004 |
Enforcement Project Initiated |
|
|
03/05/2004 |
Compliance Evaluation Inspection |
Inspection Report Beintg Drafted. Inspection Report Beintg Drafted. |
|
07/15/2004 |
Warning Letter Issued |
|
|
07/15/2004 |
File Review |
This Project Combined With Project #276795. Enforcement Case Initiated Under Warning Letter #276795 Dated July 15, 2004. This Project Combined With Project #276795. Enforcement Case Initiated Under Warning Letter #276795 Dated July 15, 2004. |
|
07/19/2004 |
Case Closed By District |
Enforcement Action Pursued Under Project #276795. Enforcement Action Pursued Under Project #276795. |
|
08/06/2004 |
File Review |
Facility Called To State It Has Returned To Compliance, There Is No Need For An Enforcement Meeting Just Issue Sfco Facility Called To State It Has Returned To Compliance, There Is No Need For An Enforcement Meeting Just Issue Sfco |
|
08/11/2004 |
Short Form Consent Order Issued |
Facility Is To Return Signed Sfco By 8/27/04 Facility Is To Return Signed Sfco By 8/27/04 |
|
09/10/2004 |
Short Form Consent Order Executed |
Cannot Close Until Howco Pays Penalty In Three Installments Cannot Close Until Howco Pays Penalty In Three Installments |
|
09/22/2004 |
Penalty Received |
First Of Three Monthly Payments First Of Three Monthly Payments |
|
10/12/2004 |
Penalty Received |
Second Of Three Payments Second Of Three Payments |
|
11/19/2004 |
Penalty Received |
Third And Last Payment For This Project Third And Last Payment For This Project |
|
11/29/2004 |
File Review |
|
|
11/29/2004 |
Case Closed By District |
|
|
11/30/2004 |
Project Closed Letter |
|
|
11/30/2004 |
Case Closed By District |
|
|
01/27/2005 |
Legacy Site Inspection |
Drafting Inspection Report / Warning Letter Drafting Inspection Report / Warning Letter |
|
01/27/2005 |
Enforcement Project Initiated |
|
|
03/01/2005 |
File Review |
In Process Of Drafting Warning Letter In Process Of Drafting Warning Letter |
|
03/11/2005 |
Warning Letter Issued |
03/28/05 Due Date For Response From Facility To Schedule Enf Mtg 03/28/05 Due Date For Response From Facility To Schedule Enf Mtg |
|
03/23/2005 |
Telephone Conversation |
Facility Called To Set Up Enf Mtg On 4/12/05 Facility Called To Set Up Enf Mtg On 4/12/05 |
|
04/12/2005 |
Enforcement Meeting |
Facility To Submit Additional Info To Refute Alleged Violations By 4/22/05 Facility To Submit Additional Info To Refute Alleged Violations By 4/22/05 |
|
04/13/2005 |
Letter |
Counter Offer By Facility On Allegations/Penalties Counter Offer By Facility On Allegations/Penalties |
|
05/16/2005 |
Short Form Consent Order Issued |
Draft Sfco Issued. Suspense Date For Reply June 3, 2005 Draft Sfco Issued. Suspense Date For Reply June 3, 2005 |
|
06/03/2005 |
Telephone Conversation |
Discussion With Clients Attorney On Alleged Violations In Co Discussion With Clients Attorney On Alleged Violations In Co |
|
06/06/2005 |
Letter |
Faxed Howco Attorney Historic Cei Reports As Requested On 6/3/05 Phone Call Faxed Howco Attorney Historic Cei Reports As Requested On 6/3/05 Phone Call |
|
06/21/2005 |
Telephone Conversation |
Notified Facility Of Final Suspense Date Of 6/23/05 To Respond To Co Issued 5/16/05 Notified Facility Of Final Suspense Date Of 6/23/05 To Respond To Co Issued 5/16/05 |
|
06/21/2005 |
Letter |
Letter From Attorney Responding To 6/3/05 Phone Call And Issued Co Letter From Attorney Responding To 6/3/05 Phone Call And Issued Co |
|
07/11/2005 |
Amended Consent Order Issued |
Suspense Date For Signed Co 7/15/05 Suspense Date For Signed Co 7/15/05 |
|
07/21/2005 |
Consent Order Executed |
8/17/05 Suspense Date For Payment Of Penalty To Close Case 8/17/05 Suspense Date For Payment Of Penalty To Close Case |
|
07/25/2005 |
Penalty Received |
Full Penalty Payment Received Full Penalty Payment Received |
|
07/28/2005 |
Project Closed Letter |
|
|
07/28/2005 |
Case Closed By District |
|
|
08/31/2005 |
File Review |
Review File To Ensure Compliance With Co Ogc # 97-2190 Review File To Ensure Compliance With Co Ogc # 97-2190 |
|
09/01/2005 |
Project Closed Letter |
Upon Reviewing File And Submittals The Facility Has Complied With The Order Upon Reviewing File And Submittals The Facility Has Complied With The Order |
|
09/01/2005 |
Return To Compliance From Formal Enforcement |
|
|
09/01/2005 |
Case Closed By District |
|
|
11/07/2005 |
Legacy Site Inspection |
Need To Return To Facility To Review Records Unavailable At Time Of Inspection Need To Return To Facility To Review Records Unavailable At Time Of Inspection |
|
11/07/2005 |
Enforcement Project Initiated |
|
36 |
11/07/2005 |
Significant Non-Complier - Yes |
|
36 |
01/05/2006 |
Legacy Site Inspection |
Site Visit To Review Records Site Visit To Review Records |
36 |
02/16/2006 |
Legacy Site Inspection |
On 1st Follow Up Visit Solid Waste Processing Was Unacceptable On This Visit It Was Observed That Conditions Have Not Improved On 1st Follow Up Visit Solid Waste Processing Was Unacceptable On This Visit It Was Observed That Conditions Have Not Improved |
36 |
04/05/2006 |
Submittal Received By Department |
Facility Submitted Documentation And Pictures That Secondary Containment Had Been Repaired And Re-Sealed Facility Submitted Documentation And Pictures That Secondary Containment Had Been Repaired And Re-Sealed |
36 |
06/01/2006 |
Legacy Site Inspection |
Drfating Cei Report Drfating Cei Report |
36 |
07/21/2006 |
Warning Letter Issued |
Penalty Authorization Sent To Ogc For Approval | Suspense Date To Schedule Enf. Meeting 8/9/06 Penalty Authorization Sent To Ogc For Approval | Suspense Date To Schedule Enf. Meeting 8/9/06 |
36 |
07/21/2006 |
Civil Penalty Authorization Memo |
Ogc Penalty Authorization Request Sent For Approval Prior To Enf. Meeting Ogc Penalty Authorization Request Sent For Approval Prior To Enf. Meeting |
36 |
08/02/2006 |
Letter |
Facility Response To Warning Letter To Schedule Enf. Mtg. Last Week Of August 06 Facility Response To Warning Letter To Schedule Enf. Mtg. Last Week Of August 06 |
36 |
08/21/2006 |
Letter |
Penalty Computation Sheet Mailed To Facility As Part Of Wl #293141 Penalty Computation Sheet Mailed To Facility As Part Of Wl #293141 |
36 |
08/29/2006 |
Enforcement Meeting |
Suspense Date To Respond To Penalty Computation Is 9/13/06 Suspense Date To Respond To Penalty Computation Is 9/13/06 |
36 |
09/15/2006 |
Submittal Received By Department |
Rcvd Facility Counter-Offer On Penalties Assessed Rcvd Facility Counter-Offer On Penalties Assessed |
36 |
12/06/2006 |
Legacy Site Inspection |
Case Reassigned To Jim Dregne Case Reassigned To Jim Dregne |
36 |
03/22/2007 |
Case Referred To Ogc |
|
36 |
09/04/2007 |
Enforcement Meeting |
Howco And Department Came To Agreement On Penalty. Department Will Draft Short For Consent Order. Howco And Department Came To Agreement On Penalty. Department Will Draft Short For Consent Order. |
36 |
09/13/2007 |
Short Form Consent Order Issued |
Response Due In 21 Days. Response Due In 21 Days. |
36 |
09/19/2007 |
Legacy Site Inspection |
Report To Be Drafted; Remainder Of Paperwork To Be Reviewed At Corporate Office Next Week Report To Be Drafted; Remainder Of Paperwork To Be Reviewed At Corporate Office Next Week |
|
09/19/2007 |
Informal Verbal Enforcement |
|
|
10/09/2007 |
Short Form Consent Order Executed |
First Quarterly Payment Due November 1, 2007. Penalty $27,998. First Quarterly Payment Due November 1, 2007. Penalty $27,998. |
36 |
10/09/2007 |
Significant Non-Complier - No |
|
36 |
10/11/2007 |
Letter |
First Quarterly Payment Of $3,498.00 Due Nlt 11/1/2007. Eight Quarterly Payments Due. Final Payment Due 8/1/2009. First Quarterly Payment Of $3,498.00 Due Nlt 11/1/2007. Eight Quarterly Payments Due. Final Payment Due 8/1/2009. |
36 |
10/17/2007 |
Compliance W/O Formal Enforcement Action |
|
|
10/25/2007 |
Penalty Received |
First Of Eight Quarterly Payments Received. $3,498.00. Next Seven Payments $3,500.00 Each. Next Payment Due 2/01/2008. First Of Eight Quarterly Payments Received. $3,498.00. Next Seven Payments $3,500.00 Each. Next Payment Due 2/01/2008. |
36 |
01/02/2008 |
Penalty Received |
Second Of Eight Payments Received. $3,500. Next Quarterly Patment Due 5/01/2008. Second Of Eight Payments Received. $3,500. Next Quarterly Patment Due 5/01/2008. |
36 |
01/14/2008 |
Meeting |
Records Review At Main Office Records Review At Main Office |
|
02/27/2008 |
Return To Compliance Letter |
|
|
02/27/2008 |
Project Closed Letter |
|
|
02/27/2008 |
Case Closed By District |
|
|
03/27/2008 |
Penalty Received |
Rcvd Payment #3 Of 8; Next Payment Due Approx June 27, 2008. Rcvd Payment #3 Of 8; Next Payment Due Approx June 27, 2008. |
36 |
06/30/2008 |
Penalty Received |
Rcvd Payment 4 Of 8; Next Payment Due Approx 10-01-08 Rcvd Payment 4 Of 8; Next Payment Due Approx 10-01-08 |
36 |
08/15/2008 |
Site Inspection |
Permitting; Used Oil-Other Howco Environmental Services (Howco) Was Inspected To Evaluate The Facility'S Compliance With State And Federal Hazardous Waste Regulations. The Inspectors Were Accompanied Throughout The Inspection By Richard Dillen, Who Manages The Laboratory, And Lee Morris, Who Manages The Yard. The Facility Was Last Inspected By The Department Of Environmental Protection (Department) On September 19, 2007. | Howco Stores, Processes And Markets Used Oil And Is A Registered Used Oil Filter Transporter And Processor, As Well. Additionally, Howco Accepts Oily Waste Solids Which Are Processed And Solidified Prior To Disposal At A Landfill. Hazmat Supplies Are Stored In One Of Three Large Trailers On The South Side Of The Property. The Contents Of The Hazmat Trailer Included Drums Of Fire Suppression Foam, As Well As Spill Control Equipment. Also In This Trailer Were Numerous Cans Of Paints And Coatings.
It Was Noted That At Least Two Of The Containers Were Leaking, And At Least 10 Were In Poor Condition. Leaked Product Was Observed On Some Of The Cans And On The Bottom Of The Trailer. After The Inspection, The Trailer Was Cleaned Up.
Behind The Laboratory, There Were Two 55-Gallon Drums Of Used Oil In Secondary Containment. The Drums Were Covered And Labeled, However, Used Oil Was Observed In The Containment Pan. The Pan Was Cleaned Out After The Inspection.
It Was Noted That The Facility Does Not Keep A Log Of Xrf Analyses. The Results Are Retained, But No Log Is Kept. The Department Is Not Requiring Howco To Obtain Nelap Certification For This Test Method, However, In Accordance With 62-160.300(6), Fac, Laboratory Organizations Shall Follow The Relevant Department-Approved Methods As Provided In Rule 62-160.320, Fac, As Applicable. In Addition, The Laboratory Shall Operate A Quality Assurance Program Consistent With The Quality Systems Standards Of The Nelac Specified In Chapter 64e-1, Fac. As Discussed Subsequent To The Inspection, Howco Can Meet This Requirement By Keeping A Bound Log Of All Samples Analyzed With The Xrf Unit.
The Log Should Include An Equipment/Instrument Description List That Includes The Manufacturer, Model Number, Year Of Purchase, Accessories, And Any Modifications, Updates, Or Upgrades That Have Been Made To The Unit. Samples Should Receive A Unique Identification Number, And The Log Should Include This Number, Along With The Date And Time Of Sampling, The Person Performing The Testing, The Source Of The Sample And The Results, Including The Analysis Number Assigned By The Unit. If Any Sample Cleanup Is Done, Such As Centrifuging To Remove Water. It Should Also Be Documented. The Department Also Recommends The Howco Implement Analyzing Duplicate Samples At Least Once Per Week, If Not Daily. | As Requested In The Previous Inspection Report, Howco Should Improve The Solid Waste Tracking So That Each Contributor To A Load Of Solid Waste Can Be Individually Identified.
Also As Requested In The Previous Inspection Report, Address The Issue Of The Deteriorated Asphalt Throughout The Yard, And Ensure That The Facility Is Operated So As To Minimize The Possibility Of Releasing Used Oil Or Used Oil Constituents Through The Asphalt To The Environment. Note That Failure To Maintain And Operate The Facility To Minimize The Possibility Of Any Unplanned Sudden Or Non-Sudden Release Of Used Oil Or Used Oil Constituents To The Environment Is A Violation Of Specific Condition I.14.(A) In The Facility'S Operating Permit, As Well As A Violation Of 40 Cfr 279.52(A)(1). The Department Recommends Using A Less Permeable, More Compatible Surface Than Asphalt.
| Submitting For Approval. | Submitted For Approval By Honey, Kelly |
|
10/10/2008 |
Penalty |
Received on Wed Oct 08, 2008-10/08/2008 ; Finished-10/10/2008 |
36 |
10/22/2008 |
Meeting |
Finished-10/22/2008 |
|
11/21/2008 |
Informal Verbal Enforcement |
Finished-11/21/2008 |
|
01/27/2009 |
Penalty |
Received on Fri Jan 23 00:00:00 EST 2009-01/23/2009 ; Finished-01/27/2009 |
36 |
03/31/2009 |
Penalty |
Received for PENALTY-03/26/2009 ; Finished-03/31/2009 |
36 |
04/23/2009 |
Site Inspection |
Routine; CESQG (<100 kg/month) - Routine; Used Oil Transporter - Routine; Used Oil Generator - Routine; Used Oil Marketer - Routine; VSQG (<100 kg/month) - Permitting; Used Oil Processor Howco Environmental Services (Howco) Was Jointly Inspected By The United States Environmental Protection Agency (Usepa) And The Florida Department Of Environmental Protection (Department) To Evaluate The Facility'S Compliance With State And Federal Hazardous Waste Regulations. Brian Gross, Environmental Scientist, Led The Inspection On Behalf Of The Usepa. The Inspectors Were Accompanied Throughout By Richard Dillen, Who Manages The Laboratory, And Lee Morris, Who Manages The Yard. The Facility Was Last Inspected By The Department On August 15, 2008. Howco Has A Used Oil Processing Permit Issued By The Department On July 7, 2007. | Howco Stores, Processes And Markets Used Oil And Is A Registered Used Oil Filter Transporter And Processor, As Well. Additionally, Howco Accepts Oily Waste Solids Which Are Processed And Solidified Prior To Disposal. As A Result Of The Lab Wastes Generated During Qa Testing, Howco Is Also A Conditionally Exempt Small Quantity Generator Of Hazardous Waste (Cesqg). The Processes At The Facility Have Not Changed Since The Previous Inspection. During This Inspection, The Department Had The Opportunity To Inspect One Of Howco'S Transport Vehicles That Was Not Currently On The Road, And It Was Found To Be Equipped With Used Oil Testing Kits And Emergency Equipment, Such As Fire Extinguishers.
Hazmat Supplies Are Stored In One Of Three Large Trailers On The South Side Of The Property. The Contents Of The Hazmat Trailer Included Drums Of Fire Suppression Foam, As Well As Spill Control Equipment. During The Inventory Of This Equipment, Is Was Determined That Some Of The Tyvek Suits Referenced On Howco'S Inventory List Were Significantly Deteriorated. It Is Recommended That Howco Inspect These These Items More Frequently To Ensure That There Is A Full Inventory Of Emergency Response Equipment, As Required By Part I.14(C) Of Its Permit. One Of The Facility'S Bullhorns Was Tested And Found To Be Operable. The Fire And Emergency Equipment Are Inspected Monthly And Tested Annually.
At The Time Of This Inspection, Howco Was In The Process Of Replacing Its Condenser Unit, And Therefore, No Used Oil Processing Was Occurring. Howco Was Also Taking The Opportunity While The System Was Down To Replace Some Pumps, Valves, Etc. There Was Some Used Oil Observed Around These Work Areas, But Overall, The Secondary Containment Was Found To Be Free Of Used Oil And Stormwater. There Were Two 20-Cubic Yard Rolloffs Near The Wtu Sludge Processing Tanks That Contained Sludges Removed From The Cooker Tanks. The Rolloffs Were Labeled And Covered. Used Oil Was Observed In The Rolloffs, And Staff Said That It Seeps From The Sludge, Rises To The Surface And Is Transferred To The Processing Storage Tanks Daily Using A Vacuum Truck. When All The Free Liquid Is Removed From The Sludge, It Will Be Taken To Pinellas County'S Waste-To-Energy Facility For Incineration After Being Solidified With Mulch Provided By The County For This Purpose.
It Was Observed That Although The Yard Was Much Cleaner Than In Previous Inspections, There Were Several Areas Where The Asphalt Was Completely Deteriorated And Lifting Off In Chunks. It Was Also Observed That A Large Part Of The Yard Was Blocked Off With Cones, And Mr. Morris Said That Howco Was Getting The Yard Recoated With Asphalt. Tampa Paving Constructors Has Been Contracted To Recoat The Rear Portion Of The Yard From The Washing Area To The Filter Block Loading Bay. It Was Noted That Some Of The Deteriorated Asphalt Was Outside This Specified Area, And Mr. Morris Was Directed To Please Recoat All Suspect Areas Of The Yard. When The Department Returned To The Facility To Review Records On 05-27-09, It Was Observed That The Yard Still Had Not Been Recoated. Given The Extremely Poor Condition Of Some Sections Of The Asphalt, Howco Needs To Recoat The Yard As Soon As Possible.
Because Much Of The Yard Had Been Emptied Due To The Planned Recoating, The Used Oil |
|
05/27/2009 |
Meeting |
Finished-05/27/2009 |
|
06/09/2009 |
Informal Verbal Enforcement |
Finished-06/09/2009 |
|
07/23/2009 |
Penalty |
Received for PENALTY-07/06/2009 ; Finished-07/23/2009 |
36 |
07/24/2009 |
Letter |
Sent for LETTER-07/24/2009 ; Finished-08/21/2009 |
36 |
08/21/2009 |
Enforcement Tracking |
Finished-08/21/2009 Project Name: Howco Cei Ffy06
Project Id: 293141
Project Description: Annual Compliance Inspection |
|
08/21/2009 |
Letter |
Sent to OGC for LETTER-07/23/2009 ; Finished-08/21/2009 |
36 |
06/24/2010 |
Site Inspection |
Routine; CESQG (<100 kg/month) - Routine; Used Oil Transporter - Routine; Used Oil Transfer Facility - Routine; Used Oil Generator - Routine; Used Oil Processor - Routine; Used Oil Marketer - Routine; VSQG (<100 kg/month) Howco Environmental Services (Howco) Was Inspected By The Department Of Environmental Protection (Department) To Evaluate The Facility'S Compliance With State And Federal Hazardous Waste Regulations. The Inspectors Were Accompanied Throughout By Richard Dillen, Who Manages The Laboratory, And Lee Morris, Who Manages The Yard. In The Past Ten Years, The Facility Has Been Inspected By The Department Eight Times, Most Recently On April 23, 2009. Howco Has A Used Oil Processing Permit Issued By The Department On July 7, 2007. This Permit Expires On August 3, 2010. Howco Submitted Its Permit Renewal Application On June 8, 2010. | Howco Stores, Processes And Markets Used Oil And Is A Registered Used Oil Filter Transporter And Processor, As Well. Additionally, Howco Accepts Oily Waste Solids Which Are Processed And Solidified Prior To Disposal. As A Result Of The Lab Wastes Generated During Qa Testing, Howco Is Also A Conditionally Exempt Small Quantity Generator Of Hazardous Waste (Cesqg). At The Plant, There Are Currently Five Employees, Plus Two Recovery Truck Drivers And One Tanker Trailer Driver. The Facility Is On City Of St. Petersburg Water And Sewer Systems. The Processes At The Facility Have Not Changed Since The Previous Inspection.
Since The Previous Inspection, Howco Has Replaced All Its Underground Piping With Aboveground Piping, In Accordance With Chapter 62-762, Fac. Additionally, The Yard Has Been Resurfaced. The Majority Of Old Equipment That Used To Be In The "Bone Yard" Has Also Been Removed. The Overall Appearance Of The Yard Was Relatively Tidy. In The Tank Farm, It Was Noted That Two Of The Asts (#134 And #133) Had Open Access Ports On Top. During The Inpsection, Howco Staff Were Directed To Replace The Port Plugs.
One Of The Facility'S Bullhorns Was Tested And Found To Be Operable. The Fire And Emergency Equipment Are Inspected Monthly And Tested Annually. Hazmat Supplies Are Stored In One Of Three Large Trailers On The South Side Of The Property. The Contents Of The Hazmat Trailer Included Personal Protective Equipment As Well As Spill Control Equipment. During The Inventory Of The Trailer, Is Was Determined That Some Of The Equipment Referenced On Howco'S Inventory List Were Missing, Including Two Drums And Four Bags Of Absorbent. It Was Noted That These Materials Were At The Facility, But Not In The Designated Trailer. These Materials Have Since Been Replaced. In The Past, The Department Has Allowed Howco To Keep Its List Of Emergency Equipment In The Trailer, However, In Accordance With 40 Cfr 279.52(B)(2)(V), Howco Must Include This List In Its Contingency Plan.
At The Time Of The Inspection, There Was One Properly Labeled 20 Cubic Yard Roll-Off Of Oily Waste. At The Rear Of The Solid Waste Pad Were Two Aboveground Storage Tanks (Asts) That Were Labeled Used Oil. These Asts Were Open. Staff Indicated That These Asts Were Probably Returned From Customers. Near The Drum Washing Area, There Were Approximately 25 Drums To Be Cleaned. Some Of The Drums Were Not Closed Or The Lids Were Cracked Allowing Rainwater To Enter The Drums And Mix With The Oil Residue Inside. In Future, Howco Should Ensure That These Drums Are Protected From The Weather. In The Oily Waste Staging Area, There Were Approximately 39 Drums Of Grease, Oily Sorbent Material, Asphalt, Recovered Diesel Fuel And Paper Filters. There Was Also One Unlabeled Drum Of Used Oil Filters. In The Used Oil Filter Processing Area, There Were Approximately 100 Drums Of Used Oil Filters In Storage. One Of These Drums Was Not Labeled. The Crusher Was Equipped With A Small Pan To Collect Leaking Hydraulic Oil. This Pan Was Also Not Labeled. All These Containers Were Labeled During The Inspection, And Staff Were Directed To Replace The Plugs In The Open Asts. Crushed Used Oil Filters Are Shipped To A Smelter. Used Oil Collected In The Crushing Unit Is Transferred To Tank #109.
Solid Waste Managed At The Facil |
|
08/06/2010 |
Meeting |
Finished-08/06/2010 |
|
08/12/2010 |
Warning Letter |
Sent for WARNING LETTER-08/12/2010 ; Finished-08/17/2010 |
26458 |
09/30/2010 |
Meeting |
Finished-09/30/2010 |
26458 |
11/10/2010 |
Short Form Consent Order |
Drafted for SHORT FORM CONSENT ORDER-09/30/2010 ; Issued for SHORT FORM CONSENT ORDER-10/04/2010 ; Response Due for SHORT FORM CONSENT ORDER-11/03/2010 ; Executed for SHORT FORM CONSENT ORDER-11/10/2010 ; Finished-11/10/2010 |
26458 |
12/09/2010 |
Penalty |
Received for PENALTY-11/29/2010 ; Finished-12/09/2010 |
26458 |
12/09/2010 |
Letter |
Sent for LETTER-12/09/2010 ; Finished-12/14/2010 |
26458 |
03/02/2011 |
Letter |
Sent for LETTER-03/02/2011 ; Finished-09/02/2011 |
26458 |
06/21/2011 |
Letter |
Sent for LETTER-06/21/2011 ; Finished-09/02/2011 |
26458 |
08/31/2011 |
Site Inspection |
Routine; CESQG (<100 kg/month) - Routine; Universal Waste Transporter - Routine; Used Oil Processor - Routine; Used Oil Marketer - Routine; VSQG (<100 kg/month) Howco Environmental Services (Howco) Was Inspected By The Department Of Environmental Protection (Department) To Evaluate The Facility'S Compliance With State And Federal Hazardous Waste Regulations. The Inspectors Were Accompanied Throughout By Richard Dillen, Who Manages The Laboratory, And Lee Morris, Who Manages The Yard. In The Past Ten Years, The Facility Has Been Inspected By The Department Nine Times, Most Recently On June 24, 2010. Howco Has A Used Oil And Solid Waste Processing Permit Issued By The Department On June 2, 2011. The Permit Expires On August 3, 2015. | Howco Stores, Processes And Markets Used Oil And Is A Registered Used Oil Filter Transporter And Processor, As Well. Additionally, Howco Accepts Oily Waste Solids Which Are Processed And Solidified Prior To Disposal. As A Result Of The Lab Wastes Generated During Qa Testing, Howco Is Also A Conditionally Exempt Small Quantity Generator Of Hazardous Waste (Cesqg). At The Plant, There Are Currently Five Employees, Plus Two Recovery Truck Drivers And One Tanker Trailer Driver. The Facility Is On City Of St. Petersburg Water And Sewer Systems. The Processes At The Facility Have Not Changed Since The Previous Inspection.
The Overall Appearance Of The Yard Was Relatively Tidy. Howco Now Has 48 Aboveground Storage Tanks (Asts), Storing Petroleum Contact Water (Pcw), Used Oil, Etc. All Of The Asts Were Recently Repainted, And None Were Observed To Have Open Access Ports. One Of The Facility'S Bullhorns Was Tested And Found To Be Operable, Although The Cabinet In Which It Is Stored Needs Repair. The Fire And Emergency Equipment Are Inspected Monthly And Tested Annually. It Was Noted That The Person Responsible For Inspections, Tim Hagan, Jr., While Noting Deficiencies, Was Not Recording The Date And Nature Of Associated Corrective Actions. The Department Recommends That This Information Be Recorded And Maintained As Part Of The Operating Record.
Hazmat Supplies Are Stored In One Of Three Large Trailers On The South Side Of The Property. The Contents Of The Hazmat Trailer Included Personal Protective Equipment As Well As Spill Control Equipment. Since The Previous Inspection, Howco Has Added Its List Of Emergency Equipment To The Contingency Plan In Accordance With 40 Cfr 279.52(B)(2)(V). In The Used Oil Filter Processing Area, There Were Approximately 38 Empty Drums, 19 Drums Of Used Oil Filters, And 11 Large Bins Of Used Oil Filters In Storage. All The Containers Were Labeled.
At The Time Of The Inspection, There Were Three Properly Labeled 20 Cubic Yard Roll-Offs Of Oily Solid Waste (E.G., Oily Filter Paper, Oily Sludge) On The Solid Waste Storage Pad, Along With A Parked Truck Of Solid Waste. Nearby Were Approximately 36 Drums Of Oily Absorbent Material In The Oily Waste Staging Area. The Solid Waste Storage Pad Is Constructed Of Thick Hdpe And Is Covered With Welded Steel Plates To Protect The Lining. The Plates Were Noted To Be In Need Of Repair. The Department Recommends Repair Of The Steel Plates As Soon As Possible To Prevent Equipment From Either Tearing The Liner Directly, Or From Causing A Bent And Damaged Steel Plate To Tear It Or Wear A Hole In It.
Solid Waste Managed At The Facility Includes Oily Solid Waste Generated By Howco And Its Customers. Solid Waste Streams Received Are Analyzed At Least Once Every Five Years In Accordance With The Permit. The Wtu Sludge And The Oil-Extracted Sludge Generated At The Facility Is To Be Analyzed Annually. The Sludge Was Last Sampled June 8, 2011, And Results Indicate That Both Waste Streams Are Nonhazardous. Solid Waste Is Either Sent To A Landfill Or To The Incinerator. Howco Is Well Under Both Its 40,000-Gallon Limit For Sending Received Solid Wastes To A Landfill And Its 200,000-Gallon Limit For Sending Received Solid Wastes To An Energy Recovery Facility.
The Maintenance Shop Generates Used Oil Filters, Used Oil, Used Antifreeze And Oily Waste. There Is Also A |
|
09/02/2011 |
Penalty |
Received for PENALTY-02/22/2011 ; Finished-09/02/2011 |
26458 |
09/02/2011 |
Penalty |
Received for PENALTY-05/27/2011 ; Finished-09/02/2011 |
26458 |
09/02/2011 |
Penalty |
Received for PENALTY-07/29/2011 ; Finished-09/02/2011 |
26458 |
09/02/2011 |
Electronic Communication |
Finished-09/02/2011 |
26458 |
09/02/2011 |
Electronic Communication |
Finished-09/02/2011 |
26458 |
09/02/2011 |
Electronic Communication |
Finished-09/02/2011 |
26458 |
09/06/2011 |
Letter |
Drafted for LETTER-09/02/2011 ; Forwarded for Review for LETTER-09/02/2011 ; Approved for LETTER-09/02/2011 ; Sent for LETTER-09/06/2011 ; Finished-09/07/2011 |
26458 |
09/07/2011 |
Enforcement Tracking |
Finished-09/07/2011 ; Finished-09/07/2011 |
|
09/15/2011 |
Meeting |
Finished-09/15/2011 |
|
08/10/2012 |
Site Inspection |
Routine; CESQG (<100 kg/month) - Routine; Used Oil Transporter - Routine; Used Oil Generator - Routine; Used Oil Processor - Routine; Used Oil Marketer - Routine; VSQG (<100 kg/month) Howco Environmental Services (Howco) Was Inspected By The Department Of Environmental Protection (Department) To Evaluate The Facility'S Compliance With State And Federal Hazardous Waste Regulations. The Inspector Was Accompanied Throughout By Richard Dillen, Who Manages The Laboratory, With Additional Assistance Provided By Lee Morris, Who Manages The Yard. The Facility Was Most Recently Inspected By The Department'S Hazardous Waste Section On August 31, 2011. Howco Has A Used Oil And Solid Waste Processing Permit Issued By The Department On June 2, 2011. The Permit Expires On August 3, 2015. | Howco Stores, Processes And Markets Used Oil And Is A Registered Used Oil Filter Transporter And Processor, As Well. Additionally, Howco Accepts Oily Waste Solids Which Are Processed And Solidified Prior To Disposal. As A Result Of The Lab Wastes Generated During Qa Testing, Howco Is Also A Conditionally Exempt Small Quantity Generator Of Hazardous Waste (Cesqg). The Facility Is On City Of St. Petersburg Water And Sewer Systems. The Processes At The Facility Have Not Changed Since The Previous Inspection.
The Overall Appearance Of The Yard Was Relatively Tidy. The Facility Was In The Process Of Resurfacing The Solid Waste Processing Pad And Recoating The Whole Area On The South Side Of The Facility Comprised Of The Drum Washing Area, The Used Oil Filter Processing Area And The Solid Waste Processing Pad. Howco Now Has 48 Aboveground Storage Tanks (Asts), Storing Petroleum Contact Water (Pcw), Used Oil, Etc. The Emergency Address System (I.E., The Bullhorn) Was Not Operable At The Time Of The Inspection. This Has Since Been Corrected. The Fire And Emergency Equipment Are Inspected Monthly And Tested Annually.
Hazmat Supplies Are Stored In One Of Three Large Trailers On The South Side Of The Property. The Contents Of The Hazmat Trailer Included Personal Protective Equipment As Well As Spill Control Equipment. In The Used Oil Filter Processing Area, There Were Approximately 72 Drums Of Used Oil Filters, All Of Which Were Labeled And Protected From The Weather.
At The Time Of The Inspection, There Was One Roll-Off On The Solid Waste Processing Pad, And Several That Were Being Stored On The East Side Of The Facility While The Pad Was Being Resurfaced. In Accordance With The Permit, All Solid Waste Received At The Facility Must Be Stored On An Impervious Surface. After The Inspection, The Roll-Offs Were Relocated. The Solid Waste Storage Pad No Longer Has Steel Plates Covering The Top. The Pad Appears To Be Constructed On Concrete And Has Been Coated, But The Coating Was Already Scrapped Off Under The Single Roll-Off Placed On It. The Department Recommends Replacement Of The Steel Plates As Soon As Possible To Prevent Equipment From Removing The Impervious Coating. It Is Unknown Whether The Concrete Is Lined Underneath.
Solid Waste Managed At The Facility Includes Oily Solid Waste Generated By Howco And Its Customers. The Wtu Sludge And The Oil-Extracted Sludge Generated At The Facility Is Analyzed Annually. The Wastewater Treatment Sludge Was Last Sampled June 6, 2012, And The Oil-Extracted Sludge Was Sampled On July 20, 2012. Results Indicate That Both Waste Streams Are Nonhazardous. Solid Waste Is Either Sent To A Landfill Or To The Waste-To-Energy Incinerator. Howco Appears To Be Under Both Its 40,000-Gallon Limit For Sending Received Solid Wastes To A Landfill And Its 200,000-Gallon Limit For Sending Received Solid Wastes To An Energy Recovery Facility.
The Maintenance Shop Generates Used Oil Filters, Used Oil, Used Antifreeze And Oily Waste. There Is Also A 25- Gallon Parts Washer In Use. Spent Solvent From The Parts Washer Is Disposed Of With The Shop'S Used Oil. Used Oil And Antifreeze Containers Are Equipped With Secondary Containment. Batteries Are Returned To The Vendor For Core Credit. It Was Noted That The Area Next To The Maintenance Shop Contained No Wastes.
Behind The Labor |
|
08/30/2012 |
Meeting |
Finished-08/30/2012 |
|
09/14/2012 |
Meeting |
Finished-09/14/2012 |
|
09/19/2012 |
Phone Conversation |
Finished-09/19/2012 |
|
09/19/2012 |
Phone Conversation |
Finished-09/19/2012 |
|
09/20/2012 |
Informal Verbal Enforcement |
Closed for Informal Verbal Enforcement-09/19/2012 ; Finished-09/20/2012 |
|
09/10/2014 |
Site Inspection |
Routine; CESQG (<100 kg/month) - Routine; VSQG (<100 kg/month) - Routine; Used Oil Processor Howco Environmental Services (Howco) Was Inspected By The Department Of Environmental Protection On September 10, 2014, To Determine The Facility'S Compliance With State And Federal Hazardous Waste And Used Oil Regulations. The Inspectors Were Accompanied Throughout The Facility By Mr. Richard Dillen, Who Manages The Laboratory, And Additional Assistance Was Provided By Mr. Lee Morris, Who Manages The Yard. Howco Was Last Inspected By The Department On September 5, 2012. Howco Has A Used Oil And Solid Waste Processing Permit Issued By The Department On June 2, 2011. The Permit Will Expire On August 3, 2015. | Howco Stores, Processes And Markets Used Oil And Is A Registered Used Oil Filter Transporter And Processor, As Well. Additionally, Howco Accepts Used Oil, Oily Water And Petroleum Contact Water From Third Party Transporters. As A Result Of The Lab Waste Generated During Qa Testing, Howco Is Also A Conditionally Exempt Small Quantity Generator Of Hazardous Waste (Cesqg). The Facility Is On City Of St. Petersburg Water And Sewer Systems. The Only Change To The Processes Since The Previous Inspection Is That The Facility No Longer Processes Solid Waste. Additional Information Regarding The Process Description Can Be Found In Past Reports.
The Overall Appearance Of The Yard Was Relatively Tidy. Howco Has 23 Registered Aboveground Storage Tanks Storing Petroleum Contact Water (Pcw), Used Oil, Finished Oil Product, Waste Water, Etc. The Fire And Emergency Equipment Are Inspected Monthly And Tested Annually. At The Time Of The Inspection It Was Noted That The Fire Extinguisher In The Laboratory Had A Service Tag Dated April 2012. Hazmat Supplies Are Stored In One Of Three Trailers On The South Side Of The Property And Include Personal Protective Equipment And Spill Control Equipment. Finished Product Is Sold To Asphalt Companies Such As Apec, Gulf Paving And Mosaic. Oily Waste Water And Pcw Accepted For Recovery Is Separated Through Gravity Separation. Oil Is The Sent Through The Recovery Process And Fuel From Pcw Added To The Fuel Blending Process. Water Recovered From These Processes Is Treated In The Water Treatment System Prior To Being Discharged To The Potw.
Howco Screens Incoming Oil For Halogens First In The Field By The Drivers. Upon Arrival At The Facility A Sample Is Taken And Analyzed For Chlorine Content In The Lab Prior To Off Loading.
Howco No Longer Operates A Solid Waste Management For Waste Generated By Its Customers. There Is Now Only One Dumpster For Solid Waste Generated At The Facility, And Roll-Off Containers Are No Longer In Use. Waste Water Treatment Sludge And Oil- Extracted Sludge Were Last Sampled On September 15, 2014. Howco Has Stopped Doing Sludge Solidification On Site And Now Outsources This Waste Stream To Clark Environmental.
The Maintenance Shop Generates Used Oil Filters, Used Oil, Used Antifreeze And Oily Waste. The Drums Are Labeled And Protected From The Weather. Spent Solvent From The Parts Washer Is Disposed Of With The Shop'S Used Oil. Used Oil And Antifreeze Containers Are Kept Within Secondary Containment. Batteries Are Returned To The Vendor For Core Credit. Crushed Metal Used Oil Filters Are Sent To Kellen Environmental In Mulberry, Fl And Fiber Used Oil Filters Are Sent To Pinellas County'S Incinerator.
Behind The Laboratory, There Are Two 55-Gallon Drums Of Used Oil In Secondary Containment. The Drums Are Labeled And Protected From The Weather. The Drums Collect Sample Waste From The Laboratory. Processed Oil Is Randomly Sampled Bi Weekly And Tested To Confirm It Is On-Spec. There Has Not Been Any Cases Of Off-Spec Oil Since The Last Inspection. Analyses Are Done Off Site By Phoslab. Samples Of Processed Oil Are Retained In The Laboratory For 30 Days. Hazardous Cod Testing Waste Generated In The Laboratory, And Spent Vials Are Accumulated In A Box Labeled "Spent Vials." Cod Testing Is Done For Compliance With The Facility'S Wast |
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01/09/2015 |
Meeting |
Finished-01/09/2015 |
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02/18/2015 |
Electronic Communication |
Finished-02/18/2015 |
|
03/09/2016 |
Site Inspection |
Routine; Used Oil Transporter - Routine; Used Oil Generator - Routine; Used Oil Processor - Routine; Used Oil Marketer Howco Environmental Services (Howco) Was Inspected By The Department Of Environmental Protection (Department) To Evaluate The Facility'S Compliance With State And Federal Hazardous Waste Regulations. The Inspector Was Accompanied Throughout By Richard Dillen, Howco'S Quality Assurance Officer, And Lee Morris, The Director Of Operations. Greg Bradley, The Operations Manager, Was Present For The Walkthrough Portion Of The Inspection. The Relevant Paperwork Was Subsequently Reviewed On 04-07-16 At The Facility'S Main Office On Central Avenue In St. Petersburg. The Facility Has Been Inspected Numerous Times By The Department'S Hazardous Waste Section, Most Recently On 09-14-14. On 01-22-16, The Department Issued Howco A Single Permit With Two Permit Numbers Authorizing Operation Of A Used Oil Processing Facility (#33721-Ho-004) And A Solid Waste / Materials Processing Facility (#33721-So-005). The Permit Expires 08-03-20. | Howco Stores, Processes And Markets Used Oil And Is A Registered Used Oil Filter Transporter And Processor, As Well. Additionally, Howco Accepts Oily Waste Solids From Its Customers For Consolidation And Subsequent Disposal At A Class I Landfill. No Solid Waste Treatment Or Solidification Is Performed. Used Anti-Freeze Is Shipped Monthly To On-Site Antifreeze Recycling, Ft. Meyers, Fl. As A Result Of The Lab Wastes Generated During Qa Testing, Howco Is Also A Conditionally Exempt Small Quantity Generator Of Hazardous Waste (Cesqg). The Facility Is On City Of St. Petersburg Water And Sewer Systems. The Processes At The Facility Have Not Changed Since The Previous Inspection.
The Overall Appearance Of The Yard Was Organized And Maintained. Howco Is Permitted To Have 48 Aboveground Storage Tanks (Asts), Storing Petroleum Contact Water (Pcw), Used Oil, Etc. The Emergency Address System (I.E., The Bullhorn) Was Tested And Found To Be Fully Functional. The Fire And Emergency Equipment Are Inspected Monthly And Tested Annually, However, There Was No Indication On The Fire Extinguishers That They Had Been Recertified Since October 2014. Mr. Dillen Said He Was Sure That The Extinguishers Were All Recertified At The Same Time Months Ago. During The Subsequent Paperwork Review, Mr. Dillen Provided A Copy Of Invoice #252362 From Abco Fire & Safety, Inc., That Showed 6 Fire Extinguishers Were Certified At The Facility On 08-19-15. It Is Unclear Why The Technician Did Not Relabel The Extinguishers At The Time Of The Certification.
As Indicated, The Overall Condition Of The Facility Was Good, But There Was Some Peeling And Flaking Observed In Several Places On The Floor Of Containment #1a. In Accordance With 40 Cfr 279.54(D), Existing Aboveground Tanks Used To Store Or Process Used Oil At Processing And Re-Refining Facilities Must Be Equipped With A Secondary Containment System, However, 40 Cfr 279.54(D)(2) Further States That The Containment System, Including Walls And Floor, Must Be Sufficiently Impervious To Used Oil To Prevent Any Used Oil Released Into The Containment System From Migrating Out Of The System To The Soil, Groundwater, Or Surface Water.
At This Time, Containment #1a Still Appears To Meet The Federal Requirements For Secondary Containment, But Does Not Appear To Fully Meet The Requirements Of Florida'S Aboveground Storage Tank Systems Rule (Chapter 62-762, Florida Administrative Code). Please Ensure That The Containment Is Fully Compliant With State Requirements Before Howco'S Next Storage Tanks Compliance Inspection By The Pinellas County Pollutant Storage Tank Program. Additionally, One Of The Valves For Tank #125 Looked Wet, And There May Be Some Possible Seepage At The Joints. Howco Needs To Evaluate This Piece Of Equipment And Repair As Needed.
Stormwater And Wastewater Are Collected Throughout The Facility, Including From The Containments, The Processing Areas, The Truck Wash, The Drum Washing Area, And The Yard. All Collected Wastewater Is Routed To The Wtu Via Sum |
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10/14/2016 |
Meeting |
Finished-10/14/2016 |
|
10/14/2016 |
Informal Verbal Enforcement |
Compliance Assistance On-Site Visit for Informal Verbal Enforcement-03/09/2016 ; Compliance Assistance Offer Verbal for Informal Verbal Enforcement-03/09/2016 ; Finished-10/14/2016 |
|
06/29/2018 |
Site Inspection |
Routine; Used Oil Transporter - Routine; Used Oil Generator - Routine; Used Oil Processor - Routine; Used Oil Marketer Howco Environmental Services (Howco) Was Inspected To Determine Its Compliance With State And Federal Hazardous Waste Regulations. On January 22, 2016, The Department Of Environmental Protection (Department) Issued Howco A Single Permit With Two Permit Numbers Authorizing Operation Of A Used Oil Processing Facility (Permit #33721-Ho-004) And A Solid Waste / Materials Processing Facility (Permit #33721-So-005); The Dual Permit Expires On August 3, 2020. The Department Has Conducted A Number Of Hazardous Waste Compliance Inspections At This Facility, Most Recently On March 9, 2016. The Inspectors Were Accompanied For The Walkthrough Portion Of The Inspection By Richard Dillen, Quality Assurance Officer, And Greg Bradley, The Operations Manager. Lee Morris, Director Of Operations, Was Present For The Record Review At The Facility'S Main Office On Central Avenue In St. Petersburg. | Howco Stores, Processes And Markets Used Oil And Is A Registered Used Oil Filter Transporter And Processor. Additionally, Howco Accepts Oily Waste Solids From Its Customers For Consolidation And Subsequent Disposal. No Solid Waste Treatment Or Solidification Is Performed. Used Anti-Freeze Is Shipped Monthly To On-Site Antifreeze Recycling, Ft. Meyers, Fl. Howco Is Also A Very Small Quantity Generator Of Hazardous Waste (Vsqg) Due To The Lab Wastes Generated During Qa Testing. Howco Is Permitted To Have 48 Aboveground Storage Tanks (Asts), Storing Petroleum Contact Water (Pcw), Used Oil, Processed Oil, And Water/Antifreeze. The Facility Has 23 Asts Which Are Regulated By The Storage Tank Program And Are Registered Under Storage Tank Facility #8624557. The Facility Operated Under Npdes Stormwater Permit # Flr05b511, Which Expires On February 4, 2021. The Facility Has An Emergency Address System (I.E., The Bullhorn) In Place. The Fire And Emergency Equipment Are Inspected Monthly And Tested Annually; The Fire Extinguishers Were Recertified In June 2018.The Facility Is On City Of St. Petersburg Water And Sewer Systems. Except As Noted Below, The Processes At The Facility Have Not Changed Since The Previous Inspection.
Stormwater And Wastewater Are Collected Throughout The Facility, Including From The Water Plant Containment Sumps, The Oil Plant Containment Sumps, The Truck Wash, The Drum Washing Area, And The Yard. All Collected Wastewater Is Routed To The Water Plant Via Sumps And Pumps. After Treatment, The Effluent Is Discharged Via A Parshall Flume To The Sanitary Sewer System Under Industrial Pretreatment Permit #Spfl-5622219-Ciu-86-32 With The City Of St. Petersburg. General Facility Stormwater Is Routed Through Two Oil/Water Separators In Tandem Prior To Being Discharged To The St. Petersburg Ms4. During The Inspection, A Large Crack Was Observed In The Concrete Stormwater Conveyance Near The Oil Plant. The Department Recommends Repairing This During The Planned Yard Re-Surfacing.
The Facility’S On-Site Laboratory Is Located North Of The Main Facility On 8th Street South. Processed Oil Is Randomly Sampled Biweekly And Tested To Confirm It Is On-Specification. Samples Are Prepared And Retained In The Facility’S On-Site Laboratory For Thirty Days. Specification Analyses Are Done Off Site By Phoslab. Chemical Oxygen Demand (Cod) Testing Is Conducted In The Laboratory To Satisfy The Requirements Of The Industrial Pretreatment Permit. The Spent Vials From The Cod Process Are Hazardous Waste Containing Acid And Chromium; The Vials Are Accumulated In Several Boxes Labeled "Spent Vials;" Some Of These Vials Are Dated 2013. The Laboratory Also Operates A Mass Spectrometer. The Mass Spectrometer Produces Hazardous Waste In The Spent Vials Which Are 10% Used Oil And 90% Solvent (F003). The Laboratory Uses Mercury Thermometer And Maintains A Mercury Spill Kit. No Poly Chlorinated Biphenyl (Pcb) Sampling Is Conducted In-House. As The Facility Is A Vsqg, They Are Able To Take Their Hazardous Laboratory Waste And Spent Fluorescent La |
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07/20/2018 |
Informal Verbal Enforcement |
Compliance Assistance Offer Verbalfor InformalVerbalEnforcement-06/29/2018 ; Finished-07/20/2018 |
|
01/30/2020 |
Site Inspection |
Routine; CESQG (<100 kg/month) - Routine; Used Oil Transporter - Routine; Used Oil Generator - Routine; Used Oil Processor - Routine; Used Oil Marketer - Routine; VSQG (<100 kg/month) At The Time Of The Inspection, Howco Environmental Services Was Not Operating In Compliance With State And Federal Regulations For Very Small Quantity Generators Of Hazardous Waste And Used Oil. The Facility Returned To Compliance During The Inspection. | An Inspection Was Conducted At Howco Environmental Services (Howco) On January 30, 2020 By The Florida Department Of Environmental Protection (Department). The Department Has Conducted A Number Of Hazardous Waste Compliance Inspections At This Facility, Most Recently On June 29, 2018. On January 22, 2016, The Department Of Environmental Protection (Department) Issued Howco A Single Permit With Two Permit Numbers Authorizing Operation Of A Used Oil Processing Facility (Permit #33721-Ho-004) And A Solid Waste / Materials Processing Facility (Permit #33721- So-005); The Dual Permit Expires On August 3, 2020. The Inspectors Were Accompanied For The Walkthrough Portion Of The Inspection By Richard Dillen, Quality Assurance Officer, And Greg Bradley, The Operations Manager. | Howco Stores, Processes And Markets Used Oil And Is A Registered Used Oil Filter Transporter And Processor. Additionally, Howco Accepts Oily Waste Solids From Its Customers For Consolidation And Subsequent Disposal. No Solid Waste Treatment Or Solidification Was Actively Occuring At The Time Of The Inspection. Howco Is Also A Very Small Quantity Generator Of Hazardous Waste (Vsqg) Due To The Lab Wastes Generated During Qa Testing. Howco Is Permitted To Have 48 Aboveground Storage Tanks (Asts), Storing Petroleum Contact Water (Pcw), Used Oil, Processed Oil, And Water/Antifreeze. The Facility Has 23 Asts Which Are Regulated By The Storage Tank Program And Are Registered Under Storage Tank Facility #8624557. The Facility Operates Under Npdes Stormwater Permit # Flr05b511, Which Expires On February 4, 2021. The Facility Has An Emergency Address System (I.E., The Bullhorn) In Place. The Fire And Emergency Equipment Are Inspected Monthly And Tested Annually; The Fire Extinguishers Were Recertified In June 2018.The Facility Is On City Of St. Petersburg Water And Sewer Systems. Except As Noted Below, The Processes At The Facility Has Not Changed Since The Previous Inspection Which Has An In Depth Explanation Of The Facility'S Process.
The Facility’S On-Site Laboratory Is Located North Of The Main Facility On 8th Street South. Processed Oil Is Randomly Sampled Biweekly And Tested To Confirm It Is On-Specification. Samples Are Prepared And Retained In The Facility’S On-Site Laboratory For Thirty Days. Specification Analyses Are Done Off Site By Phoslab. Chemical Oxygen Demand (Cod) Testing Is Conducted In The Laboratory To Satisfy The Requirements Of The Industrial Pretreatment Permit. The Spent Vials From The Cod Process Are Hazardous Waste Containing Acid And Chromium. The Laboratory Also Operates A Mass Spectrometer. The Mass Spectrometer Produces Hazardous Waste In The Spent Vials Which Are 10% Used Oil And 90% Solvent (F003). The Laboratory Uses A Mercury Thermometer And Maintains A Mercury Spill Kit. No Poly Chlorinated Biphenyl (Pcb) Sampling Is Conducted Inhouse. As The Facility Is A Vsqg, They Are Able To Take Their Hazardous Laboratory Waste And Spent Fluorescent Lamps To The Pinellas County Collection Center For Disposal. Per Facility Staff, Hazardous Waste Has Not Been Taken To The Collection Center Since 2016. Two 55-Gallon Metal Drums Of Used Oil In Secondary Containment Are Located Behind The Laboratory. The Drums Are For The Collection Used Oil Sample Waste From The Laboratory (Including Samples Past Retention). The Drums Were Covered, Labeled, On Containment Pallets And Are Under A Small Roof.
The Maintenance Shop Is Located Next To The Laboratory. The Facility Operates A Bench Style Parts Washer Which Uses Non-Chlorinated Parts Washing Fluid. Spent Parts Washing Fluid Is Mixed In With The Used Oil Collected The Shop. In Addition, The Shop Generates Used Oil Filters, Used Oil, Used Antifreeze, And Oil |
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02/27/2020 |
Informal Verbal Enforcement |
Finishedfor InformalVerbalEnforcement-02/25/2020 ; Return to Compliance Letter Sent (RCL)for InformalVerbalEnforcement-02/25/2020 ; Finished-02/27/2020 |
|
06/18/2020 |
Phone Conversation |
Finished-06/18/2020 |
|
10/27/2021 |
Site Inspection |
Routine; CESQG (<100 kg/month) - Routine; Used Oil Transporter - Routine; Used Oil Generator - Routine; Used Oil Processor - Routine; VSQG (<100 kg/month) An Inspection Was Conducted At Howco Environmental Services (Howco) On October 27, 2021 By The Florida Department Of Environmental Protection (Department) To Evaluate The Facility’S Compliance With State And Federal Hazardous Waste Regulations. The Department Has Conducted A Number Of Hazardous Waste Compliance Inspections At This Facility, Most Recently On January 30, 2020. On July 31, 2020, The Department Issued Howco A Single Permit With Two Permit Numbers Authorizing Operation Of A Used Oil Processing Facility (Permit #33721-Ho-006) And A Solid Waste / Materials Processing Facility (Permit #33721- So-007); The Dual Permit Expires On August 3, 2025. The Inspectors Were Accompanied For The Walkthrough Portion Of The Inspection By Prima Mull, The Operations Manager. | At The Time Of The Inspection, Howco Environmental Services Was Operating In Compliance With State And Federal Regulations For Very Small Quantity Generators Of Hazardous Waste And Used Oil. | Howco Stores, Processes And Markets Used Oil And Is A Registered Used Oil Filter Transporter And Processor. Additionally, Howco Accepts Oily Waste Solids From Its Customers For Consolidation And Subsequent Disposal. Howco Is Also A Very Small Quantity Generator Of Hazardous Waste (Vsqg) Due To The Lab Wastes Generated During Qa Testing. Howco Is Permitted To Have 48 Aboveground Storage Tanks (Asts), Storing Petroleum Contact Water (Pcw), Used Oil, Processed Oil, And Water/Antifreeze. Additionally, The Facility Has 23 Asts Which Are Regulated By The Storage Tank Program And Are Registered Under Storage Tank Facility #8624557. The Facility Operates Under Npdes Stormwater Permit # Flr05b511.
Howco Operates Five Days A Week, From 9a.M. To 5p.M., And Employs Twenty People, Five Of Which Are Drivers. The Facility Is On City Of St. Petersburg Water And Sewer Systems. Except As Noted Below, The Processes At The Facility Have Not Changed Since The Previous Inspection Which Has An In Depth Explanation Of The Facility'S Process.
Laboratory
The Facility’S On-Site Laboratory Is Located North Of The Main Facility On 8th Street South. Processed Oil Is Randomly Sampled Biweekly And Tested To Confirm It Is On-Specification. Samples Are Prepared And Retained In The Facility’S On-Site Laboratory For Thirty Days. Additional Specification Analyses Are Done Off Site By Phoslab. Chemical Oxygen Demand (Cod) Testing Is Conducted In The Laboratory To Satisfy The Requirements Of The Industrial Pretreatment Permit. The Spent Vials From The Cod Process Are Hazardous Waste Containing Acid And Chromium. The Laboratory Also Operates A Mass Spectrometer. The Mass Spectrometer Produces Hazardous Waste In The Spent Vials Which Are 10% Used Oil And 90% Solvent (F003). The Laboratory Uses A Mercury Thermometer And Maintains A Mercury Spill Kit. No Poly Chlorinated Biphenyl (Pcb) Sampling Is Conducted In-House. As The Facility Is A Vsqg, They Are Able To Take Their Hazardous Laboratory Waste And Spent Fluorescent Lamps To The Pinellas County Collection Center For Disposal. At The Time Of The Inspection, There Was No Hazardous Waste Or Universal Waste Lamps On Site. One, 5-Gallon Bucket, Located Inside The Laboratory Was Being Used For The Collection Of Used Oil Sample Waste From The Laboratory (Including Samples Past Retention). The Bucket Was Properly Labeled, And Under The Cover And Containment Of The Laboratory Building. Discharged Used Oil Samples From The Laboratory Are Returned To The Facility For Processing.
Maintenance Shop
The Maintenance Shop Is Located Next To The Laboratory. The Facility Operates A Bench Style Parts Washer Which Uses Non-Chlorinated Parts Washing Fluid. Spent Parts Washing Fluid Is Mixed In With The Used Oil Collected The Shop. In Addition, The Shop Generates Used Oil Filters, Used Oil, Used Antifreeze, And Oily Waste. At The Time Of This Inspection, Two 55-Gallon Drums, One Of Used Oil Filters And One Of Hydraulic Oil, Were Located Outside The Shop. Additionally, There Was A |
|
01/17/2024 |
Site Inspection |
Routine; Used Oil Transporter - Routine; Used Oil Generator - Routine; Used Oil Processor - Routine; Used Oil Marketer Hagan Holding Company Dba Howco Environmental Services (Howco) Was Inspected By The Florida Department Of Environmental Protection (Department) On January 17, 2024, To Determine The Facility’S Compliance With State And Federal Regulations Governing Used Oil, Universal Waste, And Very Small Quantity Generators (Vsqg) Of Hazardous Waste. The Facility Initially Notified As A Used Oil Transporter, Transfer Facility And Recycling Facility On February 26, 1986, Under The Name Howco Environmental Services, Inc. The Department Has Conducted A Number Of Hazardous Waste Compliance Inspections At This Facility, Most Recently On October 27, 2021. The Inspectors Were Accompanied By Prima Mull, Director Of Sales And Operations, During The Site Walk Through.
Permits
• Used Oil/Solid Waste Permit: Used Oil Permit #33721-Ho-006 And A Solid Waste / Materials Processing Facility Permit #33721- So-007; Issued On July 31, 2020, And Expires On August 3, 2025.
• Npdes Stormwater Permit: Permit #Flr05b511; Issued On January 16, 2021, And Expires On January 15, 2026. | Howco (Facility) Is Authorized To Transport, Store And Process Used Oil, Oily Wastewater, Petroleum Contact Water (Pcw), Oily Solid Waste, Used Antifreeze, And Used Oil Filters Under Their Permit. Additionally, Howco Accepts Oily Waste Solids From Its Customers For Consolidation And Subsequent Disposal. Howco Is Also A Vsqg Of Hazardous Waste Due To The Lab Wastes Generated During Qa Testing.
This Facility Is Located On An Approximately 3.2-Acre Property Owned By Hagan Holdings, D/B/A Howco Environmental Services. Howco Currently Has Approximately 15 Employees. The Hours Of Operation Are Monday Through Friday From 5 Am To 6:30 Pm. The Facility Is Connected To The City Of St. Petersburg Utilities For Water And Sewer Services.
The Facility Picks Up Used Oil, Used Oil Filters, Use Antifreeze, Used Absorbents, Industrial Wastewater And Waste Gas From Their Customers. Howco Requires Customers To Analyze All New Wastes Prior To Initial Pick Up And Requires The Generator To Recertify Every Three Years That There Has Been No Change To The Process, And Requires New Waste Analysis Every Five Years. As Part Of Its Acceptance Criteria, Drivers Use Halogen Meters To Test All Used Oil For Halogen Content. If The Instruments Indicate The Halogen Content Is >1,000-Ppm, The Used Oil Is Analyzed Using A Dexsil Kit. If The That Also Shows The Oil Has A High Halogen Content, It Is Not Picked Up, Unless The Presumption The Material Is Hazardous Is Rebutted. All Used Oil Arriving At The Plant Has Been Accepted In Accordance With This Criterion, And Therefore There Are No "Rejected Loads." Between 50 And 60 Percent Of Their Customers Are "Routing Customers;" These Are Customers On A Prearranged Pickup Schedule. The Remaining Customers Are "At Will" Customers That Call To Schedule Each Pickup Individually.
Hazmat Trailer/Facility Safety
Hazmat And Emergency Response Supplies Are Stored In A Shed On The South Side Of The Property (See Attached Photos). The Contents Of The Hazmat Trailer Included Personal Protective Equipment As Well As Spill Response Equipment. The Required Items Appear To Be Present. The Facility Has An Emergency Address System (I.E., The Bullhorn) In Place. The Fire And Emergency Equipment Are Inspected Monthly And Tested Annually.
Used Oil Filter Crushing Area
Howcos Other Facilities Located In Ft. Meyers And Astor Send Their Collected Used Oil Filters To This Location, As This Facility Is The Hub For Crushing. Drums Of Used Oil Filters Are Received From The The Collection Routes Run From This Facility And From Their Sister Facilities Are Staged In The Filter Processing Area Awaiting Draining And Crushing. There Were Numerous 55-Gallon Drums Of Used Oil Filters Stored In The Filter Processing Area. All The Used Oil Filter Drums Were Labeled With The Words "Used Oil Filters."
Used Oil Filters That Arrive At The Facility Are Allowed To Drain. After The Used Oil Filters Are Emptied An |
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02/13/2024 |
Informal Verbal Enforcement |
Submittal Received by Department-01/18/2024 ; Finished-02/13/2024 ; Return to Compliance Letter Sent (RCL)-02/13/2024 |
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08/26/2024 |
Electronic Communication |
Finished-08/26/2024 |
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02/11/2025 |
Site Inspection |
Routine; Used Oil Transporter - Routine; Used Oil Generator - Routine; Used Oil Processor - Routine; Used Oil Marketer Hagan Holding Company Dba Howco Environmental Services (Howco) Was Inspected By The Florida Department Of Environmental Protection (Department) On February 11, 2025, To Determine The Facility’S Compliance With State And Federal Regulations Governing Used Oil, Universal Waste, And Very Small Quantity Generators (Vsqg) Of Hazardous Waste. The Facility Initially Notified As A Used Oil Transporter, Transfer Facility And Recycling Facility On February 26, 1986, Under The Name Howco Environmental Services, Inc. The Department Has Conducted A Number Of Hazardous Waste Compliance Inspections At This Facility, Most Recently On January 17, 2024. The Inspectors Were Accompanied By Prima Mull, Director Of Sales And Operations, During The Site Walk Through.
Permits
• Used Oil/Solid Waste Permit: Used Oil Permit #33721-Ho-006 And A Solid Waste / Materials Processing Facility Permit #33721- So-007; Issued On July 31, 2020, And Expires On August 3, 2025.
• Npdes Stormwater Permit: Permit #Flr05b511; Issued On January 16, 2021, And Expires On January 15, 2026.
• City Of St. Petersburg Industrial Wastewater Pretreatment Discharge Permit #Spfl-562219-Ciu-86-32; Issued January 15, 2025, And Expires On January 14, 2028.
| Howco (Facility) Is Authorized To Transport, Store, And Process Used Oil, Oily Wastewater, Petroleum Contact Water (Pcw), Used Antifreeze, And Used Oil Filters Under Their Permit. Additionally, Howco Accepts Oily Waste Solids From Its Customers For Consolidation And Subsequent Disposal. Howco Is Also A Vsqg Of Hazardous Waste Due To The Lab Waste Generated During Qa Testing.
This Facility Is Located On An Approximately 3.2-Acre Property Owned By Hagan Holdings, D/B/A Howco Environmental Services. Howco Currently Has Approximately 16 Employees. The Hours Of Operation Are Monday Through Friday From 6 Am To 6 Pm. The Facility Is Connected To The City Of St. Petersburg Utilities For Water And Sewer Services.
The Facility Picks Up Used Oil, Used Oil Filters, Used Antifreeze, Used Absorbents, Industrial Wastewater, Oily Waste Solids, And Waste Gas From Their Customers. Howco Requires Customers To Analyze All New Wastes Prior To Initial Pick Up And Requires The Generator To Recertify Every Three Years That There Has Been No Change To The Process And Requires New Waste Analysis Of Each Generators Waste Stream(S) Every Five Years. As Part Of Its Acceptance Criteria, Drivers Use Halogen Meters To Test All Used Oil For Halogen Content. If The Instruments Indicate The Halogen Content Is >1,000-Ppm, The Used Oil Is Analyzed Using A Dexsil Kit. If That Also Shows The Oil Has A High Halogen Content, It Is Not Picked Up, Unless The Presumption Of The Material Is Hazardous Is Rebutted. All Used Oil Arriving At The Plant Has Been Accepted In Accordance With This Criterion, And Therefore There Are No "Rejected Loads." Approximately 70 Percent Of Their Customers Are "Routing Customers;" These Are Customers On A Prearranged Pickup Schedule. The Remaining Customers Are "At Will" Customers That Call To Schedule Each Pickup Individually.
Hazmat Trailer/Facility Safety
Hazmat And Emergency Response Supplies Are Stored In A Shed On The South Side Of The Property. The Contents Of The Hazmat Trailer Included Personal Protective Equipment As Well As Spill Response Equipment. The Facility Has An Emergency Address System (I.E., The Bullhorn) In Place. The Fire And Emergency Equipment Is Inspected Monthly And Tested Annually.
Used Oil Filter Storage And Absorbent (Abs) Area
Howcos Other Facilities Located In Ft. Myers And Astor Send Their Collected Used Oil Filters To This Location, As This Facility Is The Hub For Filter Crushing. Drums Of Used Oil Filters Are Received From The Collection Routes Run From This Facility And From Their Sister Facilities Are Staged In The Filter Processing Area Awaiting Draining And Crushing.
Facility Personnel Stated Liquid Waste Collected From Draining Of The Used Oil Filters Via The Crusher Is Sent To The On-Site Tre |
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