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07/16/1999 |
Legacy Site Inspection |
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08/26/1999 |
Warning Letter Issued |
Expect Request For Meeting. | Scheduled Meeting. Expect Request For Meeting. | Scheduled Meeting. |
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09/14/1999 |
Telephone Conversation |
Cancelled Enforcement Meeting Due To Approaching Huricane. Cancelled Enforcement Meeting Due To Approaching Huricane. |
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10/08/1999 |
Enforcement Meeting |
Needs To Supply Written Documentation Of Corrective Actions. Needs To Supply Written Documentation Of Corrective Actions. |
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11/19/1999 |
Telephone Conversation |
Called Mr. Byington. Submittal Of Documentation Of Corrective Actions Overdue. He Promised To Fedexpress Monday 22nov99. Called Mr. Byington. Submittal Of Documentation Of Corrective Actions Overdue. He Promised To Fedexpress Monday 22nov99. |
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11/24/1999 |
Submittal Received By Department |
Received Documentation Of Corrective Actions. Received Documentation Of Corrective Actions. |
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12/02/1999 |
Telephone Conversation |
Told Mr. Byington Analysis Should Include Pass/Fail On Shipping Papers And That The Words "Used Oil" Needed To Be Added To The Filter Label. Spill Cleanup Verfication Has Been Scheduled. Ask For Analytical Results When Available. Told Mr. Byington Analysis Should Include Pass/Fail On Shipping Papers And That The Words "Used Oil" Needed To Be Added To The Filter Label. Spill Cleanup Verfication Has Been Scheduled. Ask For Analytical Results When Available. |
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02/10/2000 |
Compliance W/O Formal Enforcement Action |
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02/16/2000 |
Project Closed Letter |
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02/16/2000 |
Case Closed By District |
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02/01/2007 |
Telephone Conversation |
Call From Attorney, Some Documents Delayed, Will Try To Get In By 2/8/07 Call From Attorney, Some Documents Delayed, Will Try To Get In By 2/8/07 |
128 |
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09/06/2007 |
Legacy Site Inspection |
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09/06/2007 |
Significant Non-Complier - Yes |
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128 |
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12/07/2007 |
Warning Letter Issued |
Warning Letter Issued, Response Due 12/21 Warning Letter Issued, Response Due 12/21 |
128 |
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01/17/2008 |
Enforcement Meeting |
Discussed Violations, Business Sale Resolves Compliance Issue, Facility States There Was No Economic Benefit From Noncompliance And Will Submit Data 2 Weeks Discussed Violations, Business Sale Resolves Compliance Issue, Facility States There Was No Economic Benefit From Noncompliance And Will Submit Data 2 Weeks |
128 |
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01/17/2008 |
Significant Non-Complier - No |
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128 |
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04/10/2008 |
Draft Consent Order Issued |
Draft Co Sent To Respondent, Copy To Attorney Via E-Mail Draft Co Sent To Respondent, Copy To Attorney Via E-Mail |
128 |
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04/21/2008 |
Letter |
Email From Attorney Rejecting Settlement Offer, Letter To Follow Email From Attorney Rejecting Settlement Offer, Letter To Follow |
128 |
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05/08/2008 |
Case Referred To Ogc |
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128 |
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12/29/2008 |
Judicial Complaint/Petition Filed |
Issued for JUDICIAL COMPLAINT/PETITION FILED-12/29/2008 ; Finished-05/28/2009 |
128 |
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06/22/2009 |
Enforcement Tracking |
Issued for JUDICIAL CONSENT DECREE-06/22/2009 ; Response Due for JUDICIAL CONSENT DECREE-07/22/2009 ; Finished-09/16/2011 Project Name: On Time Envrionmental 2007
Project Id: 308398
Project Description: Used Oil Transfer Facility And First Claimant Marketer |
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07/15/2009 |
Judicial Consent Decree |
Event added to complete Document translation to EPA per Spreadsheet responses -07/15/2009 ; Finished-07/15/2009 |
128 |
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07/23/2009 |
Penalty |
Received for PENALTY-07/15/2009 ; Finished-07/23/2009 |
128 |
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10/02/2009 |
Status Report |
Due Date for STATUS REPORT-08/17/2009 ; Received for STATUS REPORT-08/20/2009 ; Finished-10/02/2009 |
128 |
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11/16/2009 |
Site Inspection |
Routine; Used Oil Transporter Synergy Recycling Of Central Florida, Llc (Synergy) Was Inspected On November 16, 2009 To Determine The Facility'S Compliance With State And Federal Hazardous Waste And Used Oil Regulations. Mr. Jeff Englin Accompanied The Inspectors Throughout The Inspection. This Facility Has Been Inspected By The Department In The Past When It Was On-Time Environmental. Synergy Is A Registered Used Oil And Used Oil Filter Transporter/Transfer Facility. | At The Time Of The Inspection, Synergy Was Not Operating In Compliance With State And Federal Regulations Governing Used Oil Transporter/Transfer Facilities. | Synergy Currently Employs Seven Drivers, Two Of Whom Operate Out Of Synergy'S Tampa Location. Drivers Pick Up Spent Antifreeze, Used Oil And Filters In Pump Trucks And Box Trucks Which Are Unloaded Nightly. Drums Of Used Oil, Spent Antifreeze And Spent Filters Are Unloaded Into The Drum Storage Area Located Inside The Building. Used Oil Filters Are Segregated By Type. The Metal Filters Are Placed In A 20 Cy Roll-Off And Are Picked Up By Us Foundry Out Of Miami. The Paper Filters Are Transported To Synergy'S Kingsland, Ga Facility. The Spent Antifreeze Drums Are Pumped Out Into The Tank. Spent Antifreeze Is Managed By Mmt Of Lakeland Or On-Site Recycling. Used Oil Is Typically Pumped Out Of The Pump Truck And Into The Facility'S 10,000 Gallon Tank Located In The Rear Of The Facility. Contents Of The Tank Are Then Pumped Out Through A Filter Sock Into The The 18,000 Gallon Used Oil Compartment Of The Facility'S 25,000 Gallon Tank. The Remaining Two Compartments Contain Used Oil, Oily Water Or Spent Antifreeze. The Filter Lint Is Removed From The Socks And Is Disposed Of Through The Kingsland Facility. Recent Analytical Data Deemed The Sludge As Non-Hazardous.
The Facility'S Records Indicate That They Calibrate The Drivers' Tek-Mate "Sniffer" Units Monthly. The Records Also Indicate The The Drivers Last Received Used Oil Training On February 26, 2009. The Tampa-Based Driver Had Additional Training On August 6, 2009. During The Inspection It Was Observed That The Fire Extinguisher In One Of The Box Truck Had Been Expended And Had Not Been Replaced. Subsequent To The Inspection, A New Extinguisher Was Placed Inside The Vehicle. | Please Approve | Submitted For Approval By Camp, Shannon D. | Submitted For Approval By Camp, Shannon D. |
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12/17/2009 |
Warning Letter |
Sent for WARNING LETTER-12/17/2009 ; Finished-01/04/2010 |
20610 |
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01/04/2010 |
Phone Conversation |
Finished-01/04/2010 |
20610 |
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01/21/2010 |
Meeting |
Finished-01/21/2010 |
20610 |
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02/08/2010 |
Short Form Consent Order |
Drafted for SHORT FORM CONSENT ORDER-01/21/2010 ; Executed for SHORT FORM CONSENT ORDER-02/08/2010 ; Issued for SHORT FORM CONSENT ORDER-02/09/2010 ; Finished-02/25/2010 |
20610 |
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02/25/2010 |
Penalty |
Reviewed for PENALTY-02/24/2010 ; Finished-02/25/2010 |
20610 |
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03/02/2010 |
Enforcement Tracking |
Finished-03/02/2010 |
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01/20/2011 |
Status Report |
Finished-01/20/2011 ; Generated for STATUS REPORT-01/20/2011 |
128 |
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04/28/2011 |
Site Inspection |
Routine; CESQG (<100 kg/month) - Routine; Used Oil Transporter - Routine; Used Oil Processor - Routine; VSQG (<100 kg/month) Synergy Recycling Of Central Florida, Llc (Synergy) Was Inspected On April 28, 2011, To Determine The Facility'S Compliance With State And Federal Hazardous Waste And Used Oil Regulations. Mr. Gerry Allen Accompanied The Inspector Throughout The Inspection. Synergy Is A Registered Used Oil Processor/Transporter And A Used Oil Filter Transporter/Transfer Facility. Synergy Received Its Used Oil Processing And Material Handling Permit On January 26, 2010. The Permit Was Modified On June 30, 2011, Following The Installation Of Two Additional 25,000 Gallon Single Walled Used Oil Storage Tanks Located In Secondary Containment. | Synergy Currently Has Approximately Seven Drivers, Two Of Whom Operate Out Of Synergy'S Tampa Location. The Tampa Transfer Facility Is Located At The Florida Tank Wash Facility At The Intersection Of I-4 And Martin Luther King Jr. Blvd. The Tampa Synergy Location Has Its Own Epa Id Number And Is Inspected By The Department Separately. Route Drivers Operating From The Winter Haven Facility Pick-Up And Deliver Used Oil, Used Oil Filters, Oily Water, Antifreeze, Oily Rags, Oil Contaminated Dirt And Oil Dry To The Winter Haven Facility Daily For Temporary Storage. The Used Oil, Used Oil Filters, Oily Rags, Oil Contaminated Dirt And Oil Dry Are Then Transported To Synergy'S Kingsland, Georgia Facility For Management And Processing. There Are About Seven Shipments To Kingsland Weekly. Spent Antifreeze Is Picked Up And Managed By Mmt Of Lakeland And On-Site Recycling In Ft. Meyers. Oily Water Is Sent To Diversified Environmental Services (Des) In Tampa For Processing.
The Inspection Of The Containers In The Drum Storage Area And The Storage Tanks Revealed No Violations. All Tanks And Containers Were In Good Condition, Had No Leaks, And Were All Properly Labeled. The Two New 25,000 Gallon Single Walled Used Oil Tanks Were Not In Service At The Time Of The Onsite Inspection.
The Shop Area Had One Parts Washer Which Contained Diesel. At The Time Of The Inspection There Were No Spent Fluorescent Bulbs On-Hand. Spent Bulbs Were Being Managed By Aerc And Had Been Previously Picked Up On August 30, 2010, And April 22, 2011. Fire Extinguishers Were Located Throughout The Building And Inside Each Truck. All The Extinguishers Were Functional And Had Been Serviced By Haines City Fire Extinguisher Service In June Of 2010.
There Were Four Trucks Inspected During The Inspection. They Included Three That Were Being Prepared For Their Daily Runs And A Vac Truck That Was Parked On A Non-Paved Area In The Southeast Corner Of The Facility. There Were No Deficiencies Noted With The Trucks. All Were Properly Licensed And Had Their Annual Inspection Sticker Properly Displayed. Each Truck Contained A Fire Extinguisher, Warning Triangles, Absorbent Pads And A Functioning Sniffer. Driver Records For Five Drivers Were Reviewed And Were Found To Be In Order Except For Up-To-Date Training Records For Mr. Leonard Stout Who Was A New Driver Who Had Not Received His Required Training At The Time Of The Inspection. Mr. Stout Received The Required Training Following The Inspection. All Drivers Had Current Driver Licenses And Medical Cards.
The Facility'S Lab Area Had Been Moved Since The Previous Inspection. A Dedicated Room Has Now Been Established To Perform Required Screening Of The Used Oil. The Department Is Concerned That The Facility'S Analysis Plan Was Not Being Followed. Halogen Screening Using A Dexsil Clor-D-Tect Kit Was Not Being Performed On All Incoming Loads Of Used Oil. Mr. Allen Said That He Would Insure That All Inbound Shipments Would Be Screened Using An Approved Epa Method.
A Representative Number Of Incoming And Outgoing Manifests Were Reviewed For Completeness And Accuracy. Every Incoming Manifest Had The Proper Documentation Showing That It Had Been Screened For Halogen Content. Synergy Was Also Documenting All Shipments Of Used Oil Refused Because Of A Halogen Content Of Greater Than 1000 Pp |
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08/16/2011 |
Informal Verbal Enforcement |
Closed for Informal Verbal Enforcement-05/02/2011 ; Finished-08/16/2011 |
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08/23/2012 |
Site Inspection |
Routine; CESQG (<100 kg/month) - Routine; Used Oil Transporter - Routine; Used Oil Processor - Routine; VSQG (<100 kg/month) Synergy Recycling Of Central Florida, Llc (Synergy) Was Inspected On August 23, 2012, To Determine The Facility'S Compliance With State And Federal Hazardous Waste And Used Oil Regulations. Mr. Garry Allen Accompanied The Inspector Throughout The Inspection. Synergy Is A Registered Used Oil Processor/Transporter And A Used Oil Filter Transporter/Transfer Facility. The Department Last Inspected This Facility In April 2011.
| Operations At This Facility Have Not Changed Since The Previous Inspection. Route Drivers Pick-Up And Deliver Used Oil, Used Oil Filters, Oily Water, Antifreeze, Oily Rags, Oil Contaminated Dirt And Oil Dry To The Facility Daily For Temporary Storage. The Used Oil, Used Oil Filters, Oily Rags, Oil Contaminated Dirt And Oil Dry Are Then Transported To Synergy'S Kingsland, Georgia Facility For Management And Processing. There Are Several Shipments To Kingsland Weekly. Spent Antifreeze Is Picked Up And Managed By Mmt Of Lakeland And On-Site Recycling In Ft. Myers. Oily Water Is Sent To Diversified Environmental Services (Des) In Tampa For Processing. Used Oil Is Screened By Sniffers In The Field. Synergy Conducts Quality Assurance Tests On The Sniffers Monthly. A Log Of Monthly Testing Is Maintained On Site. All Incoming Loads Of Used Oil Are Tested With A Dexsil Clor-D-Tect Kit Prior To Placing Into The Tank System. Synergy Is Not Currently Marketing On Specification Oil.
The Containers In The Drum Storage Area And The Trailer Being Loaded For Transport To Georgia, Along With The Storage Tanks Were Inspected. All Tanks And Containers Were In Good Condition, Had No Leaks, And Were All Properly Labeled. One Bucket Used To Collect Used Oil Located Under The Used Oil Fill Port Was Unlabeled At The Time Of The Inspection. In Addition, The Fill Hose For Tank 1 Was Not Located Within The Secondary Containment Structure. No Trucks Were On Site For Inspection During The Inspection.
A Representative Number Of Incoming And Outgoing Manifests Were Reviewed For Completeness And Accuracy. Synergy Was Also Documenting All Shipments Of Used Oil Refused Because Of A Halogen Content Greater Than 1000 Ppm And An Inability To Rebut The Presumption. Rejected Loads Are Often Managed As Hazardous Waste And Brokered To Clean Solutions For Disposal. A Small Nummber Of The Manifests Reviewed Did Not Have The Halogen Screening Results Noted. In Addition, A Small Portion Did Not Have The Generators Signature. A Review Of The Facility'S Other Requested Documentation Was Also Conducted. Records Indicate Used Oil Training Was Last Given In August 2012. The Facility'S Permit, Operating Log, And Contingency Plan Were Available For Inspection. Descrepancies With The Required Documentation Are Noted Below.
At The Time Of The Inspection There Were No Spent Fluorescent Lamps On-Hand. Spent Lamps Are Being Managed By Aerc And Veolia. Synergy Last Disposed Of Spent Lamps In July 2012 Through Veolia.
At The Time Of The Inspection, Synergy Was Not Registered With The Department Of Transportion (Dot) To Transport Hazardous Materials. Records Indicate That The Facility Routinely Transports Used Oil With A Flash Point Less Than 200 Degrees Fahrenheit Along With "Bad" Gas And Used Oil And Fuel Mixtures. In Addition, The Shipping Papers For These Materials Did Not Have The Appropriate Shipping Descriptions Noted. Subsequent To The Inspection, The Facility Registered With Dot And Made New Shipping Papers To Help The Drivers Select More Appropriate Shipping Descriptions For Flammable Materials. | At The Time Of The Inspection, Synergy Recycling Of Central Florida Llc Was Not Operating In Compliance With State And Federal Used Oil Regulations Governing Used Oil Processors. The Facility Returned To Compliance Following The Inspection. | For Your Approval
| For Your Approval
| For Your Approval
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09/18/2012 |
Informal Verbal Enforcement |
Finished-09/18/2012 ; Closed for Informal Verbal Enforcement-09/18/2012 |
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03/28/2013 |
Site Inspection |
Routine; Used Oil Processor Synergy Recycling Of Central Florida, Llc (Synergy) Was Inspected On March 28, 2013, To Determine The Facility'S Compliance With State And Federal Hazardous Waste And Used Oil Regulations. Mr. Garry Allen Accompanied The Inspectors Throughout The Inspection. Synergy Is A Registered Used Oil Processor/Transporter And A Used Oil Filter Transporter/Transfer Facility. The Department'S Hazardous Waste Program Last Inspected This Facility In August 2012. | Operations At This Facility Have Not Changed Since The Previous Inspection. Route Drivers Pick-Up And Deliver Used Oil, Used Oil Filters, Oily Water, Antifreeze, Oily Rags, Oil Contaminated Dirt/Debris To The Facility Daily For Temporary Storage. The Used Oil, Used Oil Filters, Oily Rags And Oil Contaminated Dirt/Debris Are Then Transported To Synergy'S Kingsland, Georgia Facility For Management And Processing. There Are Several Shipments To Kingsland Weekly. Used Antifreeze Is Also Transported To The Kingsland Facility Prior To Recycling At Polyfreeze In Indiana. Oily Water Is Sent To Diversified Environmental Services In Tampa For Processing. Petroleum Contact Water Is Transported Directly To Aqua Clean For Processing. Used Oil Is Screened By Sniffers In The Field. Synergy Conducts Quality Assurance Tests On The Sniffers Monthly. A Log Of Monthly Testing Is Maintained On Site. All Incoming Loads Of Used Oil Are Tested With A Dexsil Clor-D-Tect Kit Prior To Placing Into The Tank System. Synergy Is Not Currently Marketing On Specification Oil.
The Containers In The Drum Storage Area And The Trailer Being Loaded For Transport To Georgia, Along With The
Storage Tanks Were Inspected. All Tanks And Containers Were In Good Condition, Had No Leaks, And Were All Properly Labeled. Only The Fill Hose For Tank 1 Was Not Located Within The Secondary Containment Structure. No Trucks Were On Site For Inspection During The Inspection.
A Representative Number Of Incoming And Outgoing Manifests Were Reviewed For Completeness And Accuracy.
Synergy Was Also Documenting All Shipments Of Used Oil Refused Because Of A Halogen Content Greater Than
1000 Ppm And An Inability To Rebut The Presumption. Rejected Loads Are Often Managed As Hazardous Waste
And Brokered To Clean Solutions For Disposal. A Review Of The Facility'S Other Requested Documentation Was Also Conducted. Records Indicate Used Oil Training Was Last Given In February 2013. The Facility'S Permit, Operating Log, And Contingency Plan Were Available For Inspection.
At The Time Of The Inspection There Were No Spent Fluorescent Lamps On-Hand. Spent Lamps Are Being Managed By Veolia. Synergy Last Disposed Of Spent Lamps In July 2012 Through Veolia. Synergy Also Picks Up Waste Tires From Select Customers For Disposal. Waste Tires Are Transported To Wheelabrator For Disposal. | At The Time Of The Inspection, Synergy Recycling Of Central Florida Llc Was Not Operating In Compliance With
State And Federal Used Oil Regulations Governing Used Oil Processors. The Facility Returned To Compliance
During The Inspection. | For Your Approval | For Your Approval |
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04/05/2013 |
Informal Verbal Enforcement |
Finished-04/05/2013 ; Closed for Informal Verbal Enforcement-04/05/2013 |
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02/27/2015 |
Site Inspection |
Routine; CESQG (<100 kg/month) - Routine; Used Oil Transporter - Routine; Used Oil Generator - Routine; Used Oil Processor - Routine; VSQG (<100 kg/month) Synergy Recycling Of Central Florida, Llc, (Synergy) Was Inspected To Determine Its Compliance With State And Federal Hazardous Waste And Used Oil Regulations. Synergy Is A Registered Used Oil And Used Oil Filter Transporter, Transfer Facility And A Permitted Used Oil (Permit #292753-Ho-005) And Solid Waste (Permit #92753-So-006) Processing Facility. Mr. Jeff Englin, General Manager, Accompanied The Inspectors Throughout. The Facility Was Inspected By The Department'S Hazardous Waste Section In 1999, 2007, 2009, 2011, 2012 And 2013. | Operations At This Facility Have Not Changed Since The Previous Inspection, Except As Noted. Route Drivers Pick Up And Deliver Used Oil, Used Oil Filters, Oily Water, Used Antifreeze, Oily Rags And Other Oil Contaminated Debris To The Facility Daily. The Used Oil Filters, Oily Rags And Debris Are Transported To The Synergy Facility In Kingsland, Ga, For Management And Processing. There Are Several Shipments To Kingsland Weekly. Used Antifreeze Is Ultimately Recycled At Poly-Freeze /Org Chem Group, Troy, In. Oily Water Is Sent To Diversified Environmental Services In Tampa For Processing. Petroleum Contact Water Is Transported Directly To Aqua Clean For Processing, And Is Not Stored On Site. Used Oil Is Screened By Sniffers In The Field. All Incoming Loads Of Used Oil Are Tested With A Dexsil Clor-D-Tect Kit Prior To Placing Into The Tank Systems.
Since The Previous Inspection, Synergy Has Begun Marketing On Specification (On-Spec) Used Oil, And Is Now Shipping Its Used Oil By Rail To A Re-Refinery In Marraro, La, Owned By Vertex Energy, Inc. The On-Spec Used Oil Is Loaded Onto Trucks At This Location And Driven To Synergy'S Auburndale Facility Nearby Where It Is Transferred To Rail Cars And Shipped To Vertex. The Required On-Spec Analyses Are Being Performed By Vertex, As Well. Vertex Is Not Certified To Perform These Analyses, However, And The Analytical Reports Provided To Synergy Do Not Meet The Quality Assurance (Qa) Standards Of Chapter 62-160, Florida Administrative Code (Fac). Additional Information About This Issue And The Required Corrective Actions Can Be Found Later In This Report.
During The Facility Walkthrough, There Were At Least Ten Unlabeled Containers Of Various Sizes That Were Storing Used Oil. There Were Also Fifteen Large Storage Bins Of Used Oil Filters That Were Not Labeled, And One Bin Was Also Being Stored Outside On A Pervious Surface With No Protection From The Weather. All The Containers Were Labeled Appropriately During The Inspection, And It Was Confirmed On 03-13-15 That The Used Oil Filter Bin Was Moved Back Inside The Building. All The Tanks Were Labeled Correctly, And The Secondary Containment Dikes Looked Relatively Clean And Free Of Used Oil. No Trucks Were On Site For Inspection During The Inspection.
A Small Used Oil Spill Occurred In The Loading/Unloading Area At Approximately 1:00 Am That Morning, And There Was Portland Cement Spread Across The Loading Pad And Adjacent Area To The North To Absorb Any Remaining Used Oil. Mr. Englin Said That Synergy'S Response Contractor, Sws, Would Be On Site Later To Further Address The Spill. The Facility Submitted The Required Written Report Of The Incident To The Department On 03-16-15.
There Was Evidence Of Another Discharge Of Used Oil Observed On The South Side Of The Property. Adjacent To The Asphalt, There Was Soil Stained With Used Oil From Approximately The Middle Of The Property Line Extending Approximately 70-Ft Eastward Almost To The Corner Of The Property. The Width Of The Stained Area Was Approximately 2-Ft. Additionally, There Was Significant Erosion Of Soils Near The Southeast Corner Indicating That Stormwater Runoff Is Flowing South And East And Exiting The Property At This Corner. The Vegetation In, And Adjacent To, The Eroded Stormwater Pathways Appeared To Be Stained With Used Oil Also.
Mr. Englin Was Informed That The Impacted Soils Would Have To Be Removed And |
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03/13/2015 |
Site Inspection |
Complaint; Used Oil-Other Synergy Recycling Of Central Florida, Llc, (Synergy) Was Inspected By The Department Of Environmental Protection (Department) As A Result Of A Citizen'S Complaint. The Complaint Alleged That The Facility Was Storing Used Oil In An Unpermitted Aboveground Storage Tank (Ast) Located Outside The Building, And It Was About To Overflow. Synergy Is A Permitted Used Oil Processor Which Was Last Inspected By The Department'S Hazardous Waste Section On February 27, 2015, Just Days Before This Complaint Was Received. Jeff Englin, General Manager, Accompanied The Inspectors During This Complaint Investigation. | Note That This Inspection Focused Only On The Allegations In The Complaint. As Indicated, The Facility Was Inspected Approximately One Week Prior To Receiving This Complaint, And A Separate Report For That Inspection Will Be Issued. The Ast Referred To In The Complaint Is Located On The North Side Of The Property, Has A Capacity Of 25,000-Gallons And Was Noted During The Inspection The Week Before. The Inspectors Were Told That It Was Empty And Being Moved From The Now Closed Synergy Location In Hillsborough County To Their Facility In Georgia. At That Time, There Was No Evidence To Indicate Otherwise.
During The Complaint Investigation, Mr. Englin Was Asked About The Ast, And He Again Stated That It Was Empty And Destined For Georgia. The Ast Was In The Same Location It Was On 02-27-15. The Inspectors Examined The Area Beneath And Around The Ast, Which Is Sitting Just Off The Asphalt North Of The Main Building. The Ground Appeared To Free From Staining. Additionally, It Was Noted That The Ast Is Configured So That All Appurtenances Are On The Top, And The Stationary Ladder That Would Normally Be Affixed To The Sidewall Had Been Removed.
Mr. Elgin Was Asked To Confirm That It Was Empty. A Ladder Was Obtained From Inside The Facility, And Synergy'S Environmental Consultant, Mike Stillinger, Climbed Up And Stuck The Tank. The Sound Of The Stick Gauge Hitting The Bottom Of The Ast Was Clearly Heard, And Upon Removal, Indicated Around 1-Inch Of Used Oil Was Present In The Ast. Since The Ast Was Used At Another Facility, This Was Not Unexpected. The Allegation That The Ast Was About To Overflow Was Unfounded. Moreover, Based On The Appearance Of The Area Immediately Adjacent To And Under The Ast, It Did Not Appear To Be In Use At All. | Based On The Observations Made During This Complaint Investigation, The Complaint Was Not Substantiated. | For Your Approval. Beth, This Is Just For The Complaint. I Am Still Working On The Report For The Cei. | For Your Approval. Beth, This Is Just For The Complaint. I Am Still Working On The Report For The Cei. |
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06/25/2015 |
Electronic Communication |
Finished-06/25/2015 |
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06/25/2015 |
Electronic Communication |
Finished-06/25/2015 |
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01/27/2017 |
Site Inspection |
Routine; CESQG (<100 kg/month) - Routine; Used Oil Transporter - Routine; Used Oil Processor - Routine; VSQG (<100 kg/month) A Routine Hazardous Waste Program Compliance Inspection Was Conducted At Synergy Recycling Of Central Florida'S ("Srcf") Used Oil Processing Facility. Since The Facility'S Previous Inspection On February 27, 2015, Srcf'S Parent, Synergy Recycling, Llc, Has Acquired Ricky'S Oil & Environmental Services, Fld981019755, And A Number Of Srcfs Employees Have Transferred To That Location Or Now Split Time Between Facilities. James Clements Provided Information On The First Day Of This Inspection, But Some Of The Company'S Records Were Not Available Until The Second Day Of The Inspection, When Jeff Englin Returned From Miami. Other Records Were Submitted After The Inspection. Srcf'S Operating Permits 292753-Ho-005 And 292753-So-006 Were Renewed Effective March 2, 2015. During A Record Review Prior To The Inspection, It Was Noted That The Company Has Not Applied For Coverage Under The Npdes Generic Storm Water Permit Applicable To Used Oil Processing Facilities, Sector N. In Addition, It Was Noted That The Contingency Plan Had Not Been Updated When Staff Tranferred To Ricky'S. The Contingency Plans Was Updated After The Inspection, However Srcf Was Also Cited For This Violation In 2015 And 2012.
Srcf Does Not Have On-Site Rail Service. The Company Leases A Private Siding In Auburndale, Florida For Loading Cars That Are To Be Shipped By Rail. Mr. Englin Said That Cars Are Released To Csx Within 24 Hours After Loading. Sidings That Hold Used Oil During The Course Of Transport For Less Than 24 Hours Are Not Required To Register As A Used Oil Transfer Facility Or Have Secondary Containment Under 40 Cfr 279.45(D). No Records Related To Oil Shipments By Rail Were On Site At The Time Of The Inspection. Mr. Englin Said That Rail Shipments Were Arranged By The Synergy Recycling Llc Office In Marietta Georgia, And That Records Were Maintained There, Rather Than On Site As Required By Fac Rule 62-710.510(4). | Srcf'S Operating Permit Includes Conditions For Used Oil Processing, Oil Filter Storage And Solid Waste Material Processing. Since The Original Permit Was Issued, Synergy Recycling Llc (Registered As A Florida Transporter - Gar000048009) Opened A Used Oil Processing Facility In Kingsland, Georgia That Is Now Receiving Most Of Srcf'S Collected Oil For Re-Refining. During The Inspection, Mr. Englin Stated That Srcf Had Not Made Any On-Specification Claims For The Previous Three Years, And Therefore No Analyses Have Been Conducted By Certified Labs. However This Statement Was Not Supported By The Annual Reports Filed For Calendar Years 2014 And 2015. These Reports State That All The Oil Shipped From The Facility In Those Years Was Shipped As On-Specification Fuel. These Shipments Include 280 20,000 Gallon Tank Cars Of Oil Shipped By Rail, Plus Any Oil Transported By Truck.
The Report For 2016 Is Not Yet Due, However Information Was Provided By Vertex Energy Regarding The Specification Status Of The 44 Tank Cars Of Oil Shipped During 2016. According To Bryan Daniel Of Vertex, The Company Does Not Accept Any Oil That Is Not Certified To Meet The Specification Parameters. No Laboratory Analyses For The Specification Parameters Were On Site At Srcf At The Time Of The Inspection. Copies Of The Specification Claim Documentation Were Requested From Vertex, And During A Follow Up Telephone Call, Mr. Englin Clarified His Previous Statement. When Oil Is Being Shipped To Vertex, Samples Are Collected From The Loaded Rail Car And Shipped To Vertex Overnight. Vertex Conducts Pre-Qualification Specification Testing, And Would Reject Any Oil That Did Not Meet The Specification Or That Was A Usdot Flammable Liquid. Vertex Also Conducts Confirmation Testing On Each Rail Car After It Is Received. None Of The Oil Shipped To Vertex Failed The Specification. Failure To Maintain Records On Site To Document The Specification Claim Is A Violation Of 40 Cfr 279.57(A)(2)(I).
Synergy Has Been Cited For Non Compliance With Specification Testing Requ |
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03/24/2017 |
Warning Letter |
Drafted-03/08/2017 ; Approved-03/16/2017 ; Sent-03/24/2017 ; Finished-03/24/2017 |
179802 |
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05/25/2017 |
Meeting |
Finished-05/25/2017 |
179802 |
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07/03/2017 |
Short Form Consent Order |
Drafted-06/08/2017 ; Issued-06/27/2017 ; Finished-07/03/2017 ; Executed-07/03/2017 |
179802 |
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07/14/2017 |
Penalty |
Received-07/13/2017 ; Finished-07/14/2017 ; Due Date-07/17/2017 |
179802 |
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10/17/2017 |
Penalty |
Received-10/05/2017 ; Due Date-10/15/2017 ; Finished-10/17/2017 |
179802 |
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01/19/2018 |
Penalty |
Received-01/09/2018 ; Finished-01/19/2018 |
179802 |
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04/25/2018 |
Penalty |
Finished-04/25/2018 |
179802 |
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07/23/2018 |
Penalty |
Received-07/09/2018 ; Finished-07/23/2018 |
179802 |
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07/24/2018 |
Project Closed Letter |
Generated-07/23/2018 ; Sent-07/24/2018 ; Finished-07/25/2018 |
179802 |
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07/25/2018 |
Enforcement Tracking |
Finished-07/25/2018 |
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03/25/2019 |
Site Inspection |
Routine; CESQG (<100 kg/month) - Routine; Used Oil Transporter - Routine; Used Oil Processor - Routine; VSQG (<100 kg/month) Synergy Recycling Of Central Florida Was Not Operating In Compliance With State And Federal Hazardous Waste Regulations, However, All Violations Were Corrected At The Time Of The Inspection And The Facility Has Since Been Returned To Compliance.
Please Note, The State Of Florida Recently Adopted The New Generator Improvement Rule. For Information On This New Rule, Visit The Epa Website (Link Below), As Regulation Changes May Apply To Your Facility.
Https://Www.Epa.Gov/Hwgenerators/Final-Rule-Hazardous-Waste-Generator-Improvements | A Routine Hazardous Waste Compliance Evaluation Inspection Was Conducted At Synergy Recycling Of Central Florida (Srcf) Used Oil Processing Facility On March 25, 2019. The Facility Was Previously Inspected On February 3, 2017. This Inspection Resulted In A Consent Order #Ogc 17-0843. Srcf Has Two Operating Permits: 292753-Ho-005 And 292753-So-006, Both Of Which Were Issued On March 2, 2015 And Expire On January 26, 2020. Mr. Jeff Englin, General Manager, Assisted Department Inspectors Throughout The Inspection. | Srcf’S Operating Permit Includes Conditions For Used Oil Processing, Used Oil Filter Storage, And Solid Waste Material Processing. Route Drivers Pick Up And Deliver Used Oil, Used Oil Filters, Oily Water, Used Antifreeze, Oily Rags, And Other Oil Contaminated Debris To The Facility Daily. Srcf Has Approximately Twenty-Five Employees, Four Of Which Are Drivers. Used Oil From Independent Used Oil Transporters Is Not Accepted By The Facility. The Facility No Longer Ships Any Used Oil By Rail. Srcf Has Four Tanker Trucks, One Box Truck, One Haz-Mat Certified Truck, And Two Vacuum Trucks (One 3,500-Gallon Truck And One 3,000-Gallon Truck). The 3,500-Gallon Vacuum Truck Services Oil-Water Separators, And Grit And Other Waste Generated From Servicing The Oil-Water Separators Is Disposed Of Using Liquid Environmental Solutions.
Srcf Has Five Regulated Aboveground Used Oil Storage Tanks (Storage Tank Facility Id# 9802060). One Is 25,000-Gallon, Double-Walled Tank, Split Into Three Compartments (3a, 3b, And 3c) Rated For 18,000/3,500/3,500-Gallons Respectively. There Is One 10,000-Gallons Storage Tank, One 1,500-Gallon Storage Tank, And Two 25,000-Gallon Storage Tanks. All Tanks Are In Concrete Secondary Containment. As Per Their Permit, Daily Inspections Of The Aboveground Storage Tanks Must Be Conducted. These Inspections Are Documented Once Per Week. The Inspection Records Were Available For Review At The Time Of The Inspection, And There Did Not Appear To Be Any Deficiencies In The Records.
The Used Oil Filters Are Taken To Us Foundry In Miami. At The Time Of The Inspection, There Were 27 Bins Of Used Oil Filters, Properly Labeled Located Inside The Warehouse On Impervious Concrete Floor.
Inside The Warehouse, There Was A Rather Large Quantity Of Virgin Antifreeze. Mr. Englin Stated That The Antifreeze Will Be Going To Jiffy Lube. There Was Also A Purewash Parts Washer, However Mr. Englin Said That Is Was Not Being Used. There Is An Open Mechanic’S Bay On The West Side Of The Building, Under An Overhang. This Is Used For Routine Maintenance, Including Oil Changes. At The Time Of The Inspection, There Were Three Unlabeled Used Oil Containers. All Containers Of Used Oil Must Be Labeled With The Words “Used Oil”. This Was Corrected During The Inspection.
Dexsil Q-1000 Kits Are Used To Determine The Halogen Content Of Incoming Used Oil. The Api Method Is Used To Detemine Water Content. The Results Of The Halogen And Water Content Are Recorded. These Records Were On Site And Readily Available For Review. Expired Kits Are Used To Train New Drivers. Specification Claims Are Verified Following Analysis Conducted By Lakeland Labs (Nelap Certificate No. E84880).
Spill Kits And Fire Extinguishers Were On Site. Spill Kits Are Checked Regularly And Stocked With Visquene And Absorbents. Fire Extinguishers Were Last Maintained In April Of 2018.
The Contingency Plan Was On Site For Review. It Was |
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04/11/2019 |
Informal Verbal Enforcement |
Submittal Received by Departmentfor InformalVerbalEnforcement-04/10/2019 ; Finished-04/11/2019 |
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05/07/2021 |
Site Inspection |
Routine; CESQG (<100 kg/month) - Routine; Used Oil Transporter - Routine; Used Oil Transfer Facility - Routine; Used Oil Processor - Routine; VSQG (<100 kg/month) The Florida Department Of Environmental Protection ("Department") Conducted A Routine Hazardous Waste Compliance Evaluation Inspection At Synergy Recycling Of Central Florida ("Synergy") Used Oil Processing Facility On May 7, 2021. The Facility Has Been Inspected By The Department Numerous Times In The Past, Most Recently On March 25, 2019. Synergy Has Two Operating Permits: 292753-007-Ho And 292753-008-So, Both Of Which Were Issued On January 30, 2020 And Expire On January 26, 2025. Mr. Jeff Englin, General Manager, Assisted Department Inspectors Throughout The Inspection. | Synergy'S Operating Permit Includes Conditions For Used Oil Processing, Used Oil Filter Storage, And Solid Waste Material Processing. Route Drivers Pick Up And Deliver Used Oil, Used Oil Filters, Oily Water, Used Antifreeze, Oily Rags, And Other Oil Contaminated Debris To The Facility Daily. Hours Of Operation Include 7 Am To 5 Pm, Monday Through Friday. The Facility Is On City Of Winter Haven Water And Sewer. Used Oil From Independent Used Oil Transporters Is Not Accepted By The Facility. The Facility No Longer Ships Any Used Oil By Rail. Synergy Operates Nine Collection Trucks Which Have Approximately 3,600-Gallon Tanks And A Drum Corral Which Can Store Up To Fourteen Drums Of Waste. Additionally, The Facility Has Five 7,000-Gallon Tankers Which Are Used To Ship Collected Used Oil To Synergy'S Refinery In Kingsland, Georgia (Epa Is #Gar000048009); One Haz-Mat Certified Truck, And Three Approximately 3,000-Gallon Vacuum Trucks Which Service Oil-Water Separators. Oily Water From The Oil-Water Separators Is Sent To Cliff Berry, Inc., While Grit And Other Waste Generated From Servicing The Oil-Water Separators Is Disposed Of Using Liquid Environmental Solutions, Cliff Berry, Inc., Or Universal Environmental Solutions, Llc In Tampa. Synergy Has Approximately Twenty-Five Employees Including Five Drivers That Haul Loads To Synergy'S Refinery In Georgia, Nine Drivers That Pick Up From Customers, Two Drivers For The Vacuum Trucks, And One Driver Who Is Used As Needed.
Synergy Has Five Regulated Aboveground Storage Tanks (Asts). Tank Three Is A 25,000-Gallon, Double-Walled Tank That Is Split Into Three Compartments (3a, 3b, And 3c) Used For The Storage Of Used Oil, Used Antifreeze, And Used Oil, Respectively. Tanks One, Two, Four, And Five Are Used For The Storage Of Used Oil And Are In Concrete Secondary Containment. Tank Two Is Rarely Used. The Tanker Truck Loading And Unloading Area Is Bermed.
There Is An Open Mechanic’S Bay On The West Side Of The Building, Under An Overhang. This Is Used For Routine Maintenance Of Synergy'S Vehicles. A 30-Gallon, Purewash Systems Parts Washer Was Located In This Area. Filters Are Cleaned Using Diesel Fuel In The Onsite Parts Washer. Spent Diesel Fuel From This Process Is Mixed In With The Used Oil Sent For Processing.
The Clean Used Oil Filters Are Taken To Us Foundry In Miami. At The Time Of The Inspection, There Were Several Used Oil Filter Bins, Properly Labeled With The Words "Used Oil Filter" And Located Inside The Warehouse On Impervious Concrete Floor.
Dexsil Q-1000 Kits Are Used To Determine The Halogen Content When Used Oil Is Picked Up From Synergy'S Clients. The Api Method Is Used To Determine Water Content Of Used Oil. Additional Used Oil Testing Is Conducted When Loads Are Received By Synergy'S Processing Facility In Kingsland Georgia. The Results Of The Halogen And Water Content Are Recorded.
Spill Kits And Fire Extinguishers Were Onsite. Uniforms Are Laundered By Cintas.
The Contingency Plan Including Arrangements Made With Local Authorities Was On Site For Review And Appeared To Be Complete. Training Records Were Current And Available For Review. Used Oil Acceptance And Delivery Records Were Reviewed And Appear To Be Complete. As Per Their Permit, Daily Inspections Of The Aboveground Storage Tanks Must Be Conducted. These Inspections Are Documented Once Per Week. The Inspection Records Were Availab |
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06/21/2023 |
Site Inspection |
Routine; Used Oil Processor Synergy Recycling Of Central Florida Llc (Synergy) Was Inspected On June 21, 2023, By The Florida Department Of Environmental Protection (Department) To Determine The Facility’S Compliance With State And Federal Hazardous Waste Regulations. The Facility Initially Notified As A Used Oil Handler On February 23, 1999 Under The Name Necessary Services. The Facility Re-Notified As A Used Oil And Used Oil Filter Transporter, A Used Oil And Used Oil Filter Transfer Facility On June 29, 2005 Under The Name On Time Environmental Services, Inc. On April 30, 2008, The Facility Re-Notified As Synergy Recycling Of Central Florida, Llc. Synergy Most Recently Re-Notified June 9, 2023; This Notification Included Notifying As A Very Small Quantity Generator (Vsqg) Of Hazardous Waste. The Facility Has Been Inspected By The Department Numerous Times In The Past, Most Recently On May 7, 2021. Alex White, Terminal Manager And Ricardo Soler, Director Assisted Department Inspectors At The Inspection.
Permits/Registrations:
• Permit Number 292753-007-Ho Issued On January 30, 2020, And Expire On January 26, 2025.
• Permit Number 292753-008-So Issued On January 30, 2020, And Expire On January 26, 2025.
• Used Oil/Used Oil Filter Transporter, Used Oil/Used Oil Filter Transfer Facility, Used Oil Processor, Used Oil Marketer, And Used Oil Collection Facility Registration Issued On June 12, 2023 And Expires On June 30, 2024. | Synergy'S Operating Permits Include Conditions For Used Oil Processing, Used Oil Filter Storage, And Solid Waste Material Processing. Route Drivers Pick Up And Deliver Used Oil, Used Oil Filters, Oily Water, Used Antifreeze, Oily Rags, And Other Oil Contaminated Debris To The Facility Daily. Hours Of Operation Include 7 Am To 5 Pm, Monday Through Friday. The Facility Is On City Of Winter Haven Water And Sewer. Used Oil From Independent Used Oil Transporters Previously Was Not Accepted By The Facility, However A Recent Permit Change Now Allows The Facility To Accept 55-Gallons At A Time. The Facility No Longer Ships Any Used Oil By Rail.
Synergy Operates Ten Collection Tank Trucks Each Of Which Have Approximately 3,600-Gallon Tanks And A Drum Corral Which Can Store Up To Fourteen Drums Of Waste. Additionally, The Facility Has Four 7,000-Gallon Tankers Which Are Used To Ship Collected Used Oil To Synergy'S Refinery In Kingsland, Georgia (Epa Is #Gar000048009); One Haz-Mat Certified Truck, And Three Approximately 3,000-Gallon Vacuum Trucks Which Service Oil-Water Separators. Oily Water From The Oil-Water Separators Is Sent To Cliff Berry, Inc. Or Aqua Clean, While Grit And Other Waste Generated From Servicing The Oil-Water Separators Is Disposed Of Using Liquid Environmental Solutions, Cliff Berry, Inc., Or Universal Environmental Solutions, Llc In Tampa. Synergy Has Approximately Twenty-Five Employees Including Four Drivers That Haul Loads To Synergy'S Refinery In Georgia, Ten Drivers That Pick Up From Customers, Two Drivers For The Vacuum Trucks, And One Driver Who Is Used As Needed.
Synergy Has Five Regulated Aboveground Storage Tanks (Asts). Tanks One, Two, Four, And Five Are Used For The Storage Of Used Oil And Are In Concrete Secondary Containment. Tank Three Is A 25,000-Gallon, Double-Walled Tank That Is Split Into Three Compartments (3a, 3b, And 3c) Used For The Storage Of Used Oil, Used Antifreeze, And Used Oil, Respectively. Tank Two Is Rarely Used. The Tanker Truck Loading And Unloading Area Is Bermed.
Previously There Was An Open Mechanic’S Bay On The West Side Of The Building, Under An Overhang; This Area Is Now Used For Storage. The Facility Is Planning To Enclosed This Area In The Near Future And Re-Purpose It Into A Training Area. A 30-Gallon, Purewash Systems Parts Washer Was Located In This Area, Which Is Not Currently In Use. A Used Oil Spilled Near The Overhang Located On The West Side Of The Building Was Observed During The Inspection.
Used Oil Filters Are Picked Up In 55-Gallon Drums. When They Arrive At The |
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07/17/2023 |
Issue Non-Compliance Letter |
Sent-07/17/2023 ; Submittal Received by Department-07/26/2023 ; Return to Compliance Letter Sent (RCL)-07/31/2023 ; Finished-08/07/2023 |
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