06/01/2009 |
Site Inspection |
Routine; Non-Handler - Routine; Hazardous Waste Transporter - Routine; Used Oil Transporter - Routine; Hazardous Waste Transfer Facility - Routine; Used Oil Transfer Facility Heritage - Crystal Clean, Llc (Hcc) Was Inspected On June 01, 2009, As An Announced Hazardous Waste Compliance Evaluation Inspection. Two Locations Were Inspected On This Day, Hcc'S New Facility At 11643 103rd Street, Jacksonville (Flr 000 154 278), And Hcc'S Old Location At 833-B Pickettville Road, Jacksonville (Flr 000 142 174). Hcc Has Never Before Been Inspected At Either Location And Is Currently Operating At Its New Facility At 11643 103rd Street As A Hazardous Waste Transporter/Transfer Facility, A Used Oil Transporter/Transfer Facility, A Used Oil Filter Transporter, And A Universal Waste Transporter. Hcc No Longer Occupies Space At Its Old Location On Pickettville Road, But Was Previously Operating There As A Hazardous Waste Transporter/Transfer Facility, Used Oil Transporter, And Universal Waste Transporter. According To Mr. Troy Strause, Jacksonville Branch Manager, Hcc Began Operations At Its New Location Approximately Three Months Prior To The Inspection. Mr. Strause Was Present Throughout The Inspection. | Hcc Is An Environmental Services Company, Which Offers Parts Washer Servicing, Hazardous And Non-Hazardous Waste Collection, And Used Oil And Used Oil Filter Collection.
Hcc Provides Solvent And Aqueous Parts Washers And Other Cleaning Machines, Such As Paint Gun Cleaners And Immersion Cleaners, For Sale Or Lease To Their Customers. Hcc Offers Two Types Of Parts Washers, The First
Has A 142° F Flash Point Solvent And Is Referred To As "High Flash Non-Hazardous Solvent" By Hcc. According To Mr. Strause, This Solvent Is Collected From Customers And Is Then Shipped Somewhere To Be "Recycled" And Then Sold Back To The Customer As New Solvent. The Other Parts Washer Has A 106° F Flash Point Solvent And Is On Hcc'S "Re-Use" Policy. According To Mr. Strause, Hcc'S Jacksonville Branch Is Currently Only Providing The "High Flash Non-Hazardous" Solvent To Its Customers.
Containers Of Hazardous Waste And Containers Of Non-Hazardous High Flash Mineral Spirits Picked Up From Hcc'S Customers Are Transferred Directly From The Route Trucks Onto An Unhitched Storage Trailer. At Least Every Ten Days, Trailers With New Product And Supplies Are Brought Into The Facility, And The Waste Trailers Are Attached To The Truck Cab And Transported To Hcc'S Hub In Atlanta, Georgia. The 103rd Street Facility Includes Some Office And Warehouse Space, But No Transfer Operations Or Storage Takes Place Inside The Building. All Of The Facility'S Employees Are Dispatched On Service Routes For The Majority Of The Day.
The Facility Is Surrounded On Three Sides (East, West, And North) By Trees And On The South Side Of The Facility By A Fence. The Facility Provides No Surveillance, And The Entrance Gate Remains Open During Business Hours, Even When No Hcc Employees Are Present On-Site. The Entrance Gate Is Locked At Night. Failure To Provide 24-Hour Surveillance Or A Physical Barrier Or Fence Which Completely Surrounds The Active Portion Of The Facility Is A Violation Of 40 Cfr 265.14(A). The Facility Failed To Post The Appropriate Warning Signs On The South Fence, Which Is A Violation Of 40 Cfr 265.14(C).
There Were Three Semi-Trailers Present During The Inspection, Two Of Which Contained Product And Supplies. The Third Trailer Contained Non-Hazardous Wastes For Disposal. No Hazardous Wastes Were Present On-Site During The Inspection; However, Hazardous Wastes Are Frequently On-Site. The Trailers Were Parked On The South Side Of The Facility Parallel To The Fence. According To The Duval County Property Appraisers Website, The Property Line Runs Just North Of This Area, Between The Fence And The Building, And The Storage Trailers Appear To Be On City Of Jacksonville Property (Photo 1) (Attachment 1 - Property Line Map). The Storage Of Ignitable Waste Within 50 Feet From The Property Line Is A Violation Of 40 Cfr 265.176. The Facility Did Not Post The Required "No Smoking" Signs In The Waste Storage Area, Which I |
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07/10/2009 |
Request For Additional Information |
Sent for REQUEST FOR ADDITIONAL INFORMATION-07/10/2009 ; Due Date for REQUEST FOR ADDITIONAL INFORMATION-08/01/2009 ; Finished-03/19/2015 |
17080 |
01/13/2010 |
Warning Letter |
Sent for WARNING LETTER-01/13/2010 ; Finished-03/19/2015 |
17080 |
11/16/2010 |
Letter |
Sent for LETTER-11/16/2010 ; Finished-03/19/2015 |
17080 |
09/30/2011 |
Letter |
Sent for LETTER-09/30/2011 ; Finished-10/21/2014 |
17080 |
06/06/2014 |
Site Inspection |
Routine; Non-Handler - Routine; Hazardous Waste Transporter - Routine; Used Oil Transporter - Routine; Hazardous Waste Transfer Facility - Routine; Used Oil Transfer Facility Heritage-Crystal Clean, Llc (Hcc) Was Inspected June 6, 2014, As An Unannounced Hazardous Waste Compliance Inspection. Hcc Was Last Inspected By The Department At This Location On June 1, 2009, As A Hazardous Waste Transporter/Transfer Facility, A Used Oil Transporter/Transfer Facility, A Used Oil Filter Transporter, And A Universal Waste Transporter. The Facility Has Been Issued The Epa/Dep Identification Number Flr 000 154 278. Please Use This Number On All Correspondence With The Department'S Hazardous Waste Section.
The Inspection Was Conducted In Coordination With Us Epa Region Iv Personnel. An Inspection Report Will Be Issued By The Us Epa. Please Refer To That Inspection Report For The Specifics Of The Observations Noted During The Inspections. | Approved | Approved |
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07/11/2014 |
Meeting |
Finished-07/11/2014 |
|
10/21/2014 |
Meeting |
Finished-10/21/2014 |
17080 |
03/19/2015 |
Enforcement Tracking |
Finished-03/19/2015 Ji-2 - Cases Involving More Than One Facility. | Formal Enforcement Not Pursued For Non-Federal Snc. |
|
03/19/2015 |
Meeting |
Finished-03/19/2015 |
17080 |
03/19/2015 |
Submittal Received By Department |
Received for SUBMITTAL RECEIVED BY DEPARTMENT-06/21/2010 ; Finished-03/19/2015 |
17080 |
03/19/2015 |
Civil Penalty Authorization Memo |
Sent to Program for CIVIL PENALTY AUTHORIZATION MEMO-06/10/2010 ; Received from Program for CIVIL PENALTY AUTHORIZATION MEMO-06/18/2010 ; Sent to OGC for CIVIL PENALTY AUTHORIZATION MEMO-08/04/2010 ; Approved for CIVIL PENALTY AUTHORIZATION MEMO-08/12/2010 ; Received from OGC for CIVIL PENALTY AUTHORIZATION MEMO-08/12/2010 ; Finished-03/19/2015 Cpam $203,750, Not Sent To Facility |
17080 |
03/19/2015 |
Case Report |
Sent to OGC for CASE REPORT-11/09/2010 ; Finished-03/19/2015 |
17080 |
03/19/2015 |
Submittal Received By Department |
Received for SUBMITTAL RECEIVED BY DEPARTMENT-12/17/2010 ; Finished-03/19/2015 |
17080 |
05/08/2018 |
Site Inspection |
Routine; Non-Handler - Routine; Hazardous Waste Transporter - Routine; Used Oil Transporter - Routine; Hazardous Waste Transfer Facility - Routine; Used Oil Transfer Facility Heritage-Crystal Clean, Llc (Hcc) Was Inspected On May 8, 2018. A Site Visit Was Also Conducted On May 31, 2018, For Records Review. Hcc Was Last Inspected By Both The Usepa'S And The Department'S Hazardous Waste Program On June 6, 2014, And By The Department'S Hazardous Waste Program On June 1, 2009. Mr. Ricky Powell, Warehouseman, Was Present During The Inspection On May 8, And Mr. Kevin Falls, General Manager, Was Present During The May 31 Visit. Mr. Vinnie Glorioso, Hcc Regional Manager, Participated By Phone During A Portion Of The May 31 Site Visit.
Hcc Is A Registered Used Oil Transporter/Transfer Facility, A Used Oil Filter Transporter/Transfer Facility, A Hazardous Waste Transporter/Transfer Facility And A Universal Waste Transfer Facility. Hcc Is Currently A Non-Handler Of Hazardous Waste. The Facility Has Been Issued Epa/Dep Identification Number Flr 000 154 278. Please Use This Number On All Correspondence With The Department'S Hazardous Waste Program.
Hcc Has Been At This Location Since 2009. Hcc Leases Approximately One Acre Of A Seven-Acre Parcel That Is Owned By Group Iv Cecil, Inc., Based In Jacksonville, Fl. The Facility Is Connected To A Private Water Supply And City Sewer. It Operates Three Used Oil Vacuum Trucks, One Fuel-Only Pump Truck And Three Box Trucks. The Facility'S Vehicle Fleet Is Maintained Off-Site By A Third-Party Vendor. Hcc Has Eight Employees, Including Five Drivers, And Operates Monday Through Friday From 6:00 Am To 5:00 Pm. The Facility Consists Of Administrative Offices, A Main Warehouse, A Truck Parking Lot And The Waste Transfer Area.
| Used Oil Transporter And Transfer Facility
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Hcc Transports Used Oil In Vacuum Trucks That Return To The Facility At The End Of The Work Shift And Park In The Truck Parking Lot Described Below. When The Vacuum Truck Is Full, The Vacuum Truck Transports The Used Oil To The Jacksonville Transflo Facility (Transflo, Fld 984 253 526) Where It Is Loaded Onto A Rail Car And Shipped To Hcc'S Facility In Atlanta, Ga (Gar 000 078 279) For Processing. According To Mr. Falls, Used Oil Is Transferred To Transflo Two To Three Times Each Week. Occasionally, A Truck That Is Not Empty Will Be Parked At The Facility Over A Weekend And Longer Than 24-Hours. The Truck Parking Lot Is Unsealed Asphalt, Loose Limerock And Dirt, Is Not Oil-Impermeable And Does Not Have Secondary Containment [62-710.401(6), Fac]. Hcc Also Transports Oily Water Collected From Customers To Liquid Environmental Solutions Of Florida (Fld 981 928 484) For Processing.
Mr. Falls Stated That New Customers Are Required To Complete A “Generator Certification” Form Upon Requesting Service. The Form Requires The Customer To Identify Its Hazardous Waste Generator Category And Epa Id, If Applicable, And To Certify That Its Used Oil Meets The Definition Of Used Oil Contained In 40 Cfr 279. Hcc Uses This Form To Determine Whether A Customer Has An Epa Id Number And To Determine The Frequency That Hcc Performs Used Oil Halogen Screening Prior To Transport. Mr. Falls Stated That Used Oil Generated During Automotive Repair/Maintenance Work Is Screened With Chlor-D-Tect Kits Prior To Pick-Up From First-Time Customers And Then It Is Only Screened Approximately Every Six Months Thereafter. Used Oil Generated During Industrial-Related Work Is Screened Prior To Each Pick-Up. Because Every Load From Some Customers Is Not Screened Every Time, Hcc Failed To Screen All Used Oil Prior To Transport [40 Cfr 279.44(A)].
A Used Oil Sample Is Collected From Each Customer And A Batch Sample Is Collected From The Vacuum Truck Prior To Transferring The Used Oil To Transflo. The Samples Are Kept In The Main Warehouse (Photo 1), Described Below, For Three Months In Case The Receiving Facility In Atlanta Requests Lab Analysis. After Three Months, The Used Oil Is Emptied Into One Of Two Used Oil Containers Located Inside The M |
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09/21/2018 |
Warning Letter |
Sent-09/21/2018 ; Finished-09/21/2018 |
183320 |
12/13/2018 |
Meeting |
Finished-12/13/2018 |
183320 |
05/02/2019 |
Short Form Consent Order |
Finished-05/02/2019 ; Executed-05/02/2019 |
183320 |
05/22/2019 |
Penalty |
Received-05/21/2019 ; Finished-05/22/2019 |
183320 |
05/28/2019 |
Return To Compliance Letter |
Finished-05/28/2019 ; Sent-05/28/2019 |
183320 |
07/05/2019 |
Enforcement Tracking |
Finished-07/05/2019 |
|
05/04/2022 |
Site Inspection |
Routine; Non-Handler - Routine; Hazardous Waste Transporter - Routine; Used Oil Transporter - Routine; Hazardous Waste Transfer Facility - Routine; Used Oil Transfer Facility Heritage-Crystal Clean, Llc (Hcc, The Facility) Was Inspected On May 4, 2022. Hcc Was Last Inspected By The Department'S Hazardous Waste Program On May 8, 2018. Mr. Dalton Register, Hcc General Manager, Was Present Throughout The Inspection. Ms. Anita Decina, Hcc Vice President (Operational, Safety & Environmental Excellence) Provided Documents During The Records Review Portion Of The Inspection That Was Conducted Electronically.
Hcc Is A Registered Used Oil Transporter/Transfer Facility, A Used Oil Filter Transporter/Transfer Facility, A Hazardous Waste Transporter/Transfer Facility, A Universal Waste Transporter/Transfer Facility, And A Petroleum Contact Water Transporter. Hcc Transports These Wastes Under Epa Id #Ilr000130062 And The Jacksonville Facility Acts As The Transfer Facility. Hcc Is Currently A Non-Handler Of Hazardous Waste.
Hcc Has Been At This Location Since 2009. Hcc Leases Approximately One Acre Of A Seven-Acre Parcel That Is Owned By Group Iv Cecil, Inc., Based In Jacksonville, Fl. The Facility Is Connected To A Private Water Supply And City Sewer. It Operates Two Used Oil Vacuum Trucks, One Fuel-Only Pump Truck And Four Box Trucks. The Facility'S Vehicle Fleet Is Maintained Off-Site By A Third-Party Vendor. Hcc Has Nine Employees, Including Six Drivers, And Operates Monday Through Friday From 6:00 Am To 5:00 Pm. The Facility Consists Of Administrative Offices, A Main Warehouse, A Truck Parking Lot, And The Waste Transfer Area.
| Used Oil Transporter And Transfer Facility Operations
Hcc Transports Used Oil In Vacuum Trucks That Return To The Facility At The End Of The Work Shift And Park In The Truck Parking Lot Described Below. When The Vacuum Truck Is Full, The Vacuum Truck Transports The Used Oil To Jacksonville Transflo Terminal (Transflo, Fld984253526) Where It Is Loaded Onto A Rail Car And Shipped To Hcc'S Facility In Atlanta, Ga (Gar000078279) For Processing. Used Oil Is Transferred To Transflo Two To Three Times Each Week. Occasionally, A Truck That Is Not Empty Will Be Parked At The Facility Over A Weekend And/Or Longer Than 24-Hours. When This Occurs, The Truck Is Parked Within The Facility’S Sealed, Curbed Concrete Secondary Containment Area Located In The Truck Parking Lot Described Below. Hcc Also Transports Oily Water Collected From Customers To Liquid Environmental Solutions Of Florida (Fld981928484) For Processing.
Hcc Screens All Used Oil With Chlor-D-Tect Kits Prior To Pick-Up. A Halogen Detector Is Used For Confirmatory Testing If The Technician Deems It Necessary. A Used Oil Sample Is Collected From Each Customer And A Batch Sample Is Collected From The Vacuum Truck Prior To Transferring The Used Oil To Transflo. The Samples Are Kept In The Main Warehouse For Three Months In Case The Receiving Facility In Atlanta Requests Lab Analysis (Photo 1). After Three Months, The Samples Are Emptied Into A Used Oil Container Located Inside The Main Warehouse. When The Containers Are Full, The Used Oil Is Pumped Into The Vacuum Truck. No Containers Of Used Oil Were Observed At The Time Of The Inspection.
Hcc Generates A Routine Wastestream, "Branch Debris," During The Transport And Transfer Of Used Oil. This Wastestream Includes Solid Wastes Such As Wipes, Absorbents, Ppe And Similar Items. Hcc Manages Branch Debris As Non-Hazardous Waste And Had Analysis To Support This Process. There Were Two Containers Of Branch Debris Accumulating At The Time Of The Inspection (Photo 2). Both Containers Were Closed And Labeled.
Used Oil Transporter And Transfer Facility Records Review:
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Hcc Maintains An Electronic Log For Used Oil For A Period Of Three Years, And Ms. Decina Provided Three Years Of Electronic Logs For Used Oil Transported By Hcc. However, The Electronic Log Did Not Include The Used Oil Generator Epa Id#, And Did Not Include The Date That The Used Oil Was Del |
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10/07/2022 |
Issue Non-Compliance Letter |
Sent-10/07/2022 ; Finished-02/15/2023 ; Return to Compliance Letter Sent (RCL)-02/15/2023 |
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