|
08/08/2012 |
Site Inspection |
Compliance Assistance Site Visit; Used Oil-Other - Compliance Assistance Site Visit; SQG (100-1000 kg/month) - Compliance Assistance Site Visit; TSD Facility - Compliance Assistance Site Visit; Used Oil Transporter On August 8, 2012, Department Personnel Jim Byer, Bheem Kothur, And Aaron Mitchell Conducted A Compliance Assisted Site Visit At The Florida Transformer, Inc. Facility Located In Defuniak Springs, Florida. Jessica Pennington The Facility'S Environmental Compliance Specialist Facilitated The Site Visit. The Purpose Of The Site Visit Was To Review The Facility Operations In Regards To The Used Oil Processing Permit Application That Was Being Reviewed By The Department For Approval. Inspectors Reviewed Site Management Practices For The Facility And Also Were Given Information About How The The Facility Used Oil Processing Procedures Would Be Conducted. A Review Of Offsite And Onsite Procedures And Management Were Reviewed For The Department As Well. | Swift | Swift |
|
|
12/12/2013 |
Site Inspection |
Routine; LQG (>1000 kg/month) - Routine; TSD Facility - Routine; Used Oil Transporter - Routine; Used Oil Generator - Routine; Used Oil Processor - Routine; Used Oil Marketer Florida Transformer Inc.(Fti), Is A Transformer Repair And Processing Facility Located In Defuniak Springs, Florida. The Facility Operations Include Transformer Repair, Used Oil Processing, And Transformer Sales And Service. Fti Notified The Department As A Small Quantity Generator Of Hazardous Waste. The Facility Has Been In Operation For Over 38 Years And Has Approximately 100 Employees. The Facility Is Situated On 25 Acres,
Of Which 15 Acres Are Actively Used While 10 Are Not. The Inspection Was Facilitated By Jessica Pennington (Environmental Compliance Officer) And Jerome Stuckey (Plant Manager). | On December 10, 2013, Department Personnel Aaron Mitchell And Chris Stoll And Epa Inspector Javier Garcia Conducted A Routine Inspection Of The Fti Transformer Sales And Service Site. An Inspector From The Alabama Department Of Environmental Management (Adem), Ms. Donna Adams, Conducted A Pcb Inspection Under The Supervision Of The Epa. The State Of Florida Does Not Regulate Pcbs And Thus Does Not Have A Program In Place To Ensure Compliance With The Applicable Rules And Regulations Governing Their Management. The Inspection Consisted Of A Records Review And Visual Site Inspection.
Visual Inspection:
The Visual Inspection Consisted Of The Following: Intake Processing, Laboratory, Hazardous Waste Storage Area, Pcb Ancillary Area/Universal Waste Storage Area, Pcb-Contaminated Oil Storage Area, Middle Paint Room, Red Dragon Used Oil Processor, And Tank Farm. Jessica Pennington Facilitated The Visual Inspection Of The Facility.
Intake Processing:
The Facility Receives Transformers From Alabama, Mississippi, Georgia, Tennessee, Florida, North Carolina, South Carolina, And Maryland. The Facility Uses Contracted Drivers To Transport All Out-Of-State Pickups.
Fti Only Has One Employed Driver That Conducts All In-State Transformer Transporting. The Transformers Are Unloaded Onto A Conveyor System.
Any Transformers That Are Shipped For Disposal Must Be Accompanied By Oil Analysis Test Documents Before Being Received By Facility. The Transformers That Are Not Designated For Disposal Have Oil Samples Taken Once They Arrive At The Facility. Each Transformer Has Its Own Barcode Attached To It Once It Enters The Facility. This Barcode Follows The Transformer Throughout Its Processing. The Transformers With Pcb-Contaminated Oils Receive A Red And Orange Tag And The Transformers With Non-Pcb Oils Receive A White Tag. Fti Uses In-House Software To Scan The Transformer Barcodes Before Weighing And Emptying The Them Of Their Oil. The Empty Transformers Are Then Scanned Again And Weighed. The Empty Weight Is Used To Calculate The Amount Of Oil Removed.
The Removed Oils That Are Found To Have Less Than Two Parts Per Million (Ppm) Of Pcbs Are Filtered, Visually Inspected For Moisture And Place Into A Storage Tank. The Removed Oils That Range Between 2-49 Ppm Of Pcbs Are Pumped To One Of Three Holding Tanks. These Oils Are Then Processed Via The Onsite Processing Equipment (Red Dragon) And Subsequently Stored In A 15,000 Gallon Tank. The Processed Oils Are Marketed As A Lubricant. Transformer Oils That Have Between 50 And 499 Ppm Of Pcb Content Are Pumped Into One Of Four 1,295-Gallon Storage Tanks Located In The Pcb Storage Room. Transformers That Have A Content Of 3,000 Gallons Or More Of Used Oil Are Not Processed Onsite. These Transformers Are Moved To The Pcb Storage Room And Transferred To Another Tci Location In Pell City, Alabama. Fti Also Receives Customer Generated Used Oils And Consolidates Those With The Facility Generated Used Oils.
Laboratory:
The Facility Conducts All Sampling Tests In The Onsite Laboratory Located Adjacent To The Intake Area. All Sample Containers Are Matched To The Barcode That Is Applied To The Individual Transformers In The Intake Area.
The Samples Have Hexane And Hydrosulfuric Acid Added To Them In Preparation For Use In The Facility'S Gas Chromatic Spectro |
|
|
12/27/2013 |
Case Referral To Epa |
Sent for CASE REFERRAL TO EPA-12/27/2013 ; Finished-07/30/2014 Drop From Epa Report |
171959 |
|
07/30/2014 |
Case Referral To Epa |
Drafted for CASE REFERRAL TO EPA-07/11/2014 ; Finished-07/30/2014 Drop From Epa Report |
171959 |
|
07/31/2014 |
Enforcement Tracking |
Finished-07/30/2014 ; Finished-07/30/2014 ; Finished-07/31/2014 |
|
|
10/09/2014 |
Letter |
Received for LETTER-07/11/2014 ; Finished-10/09/2014 |
|
|
10/09/2014 |
Letter |
Received for LETTER-10/07/2014 ; Finished-10/09/2014 |
|
|
10/09/2014 |
Letter |
Received for LETTER-09/23/2014 ; Finished-10/09/2014 |
|
|
10/09/2014 |
Letter |
Received for LETTER-09/23/2014 ; Finished-10/09/2014 |
|
|
10/09/2014 |
Letter |
Finished-10/09/2014 ; Received for LETTER-10/09/2014 |
|
|
10/09/2014 |
Letter |
Finished-10/09/2014 ; Received for LETTER-10/09/2014 |
|
|
10/09/2014 |
Site Photos |
Generated for SITE PHOTOS-12/12/2013 ; Received for SITE PHOTOS-10/07/2014 ; Finished-10/09/2014 |
|
|
08/01/2017 |
Submittal Received By Department |
Finished-08/01/2017 |
|
|
09/15/2017 |
Site Inspection |
Routine; LQG (>1000 kg/month) - Routine; Hazardous Waste Transporter - Routine; Used Oil Transporter - Routine; Used Oil Generator - Routine; Used Oil Processor - Routine; Used Oil Marketer Florida Transformer Inc.(Fti), Is A Power Transformer Repair And Processing Facility Located In Defuniak Springs, Florida. The Facility Operations Include Transformer Repair, Used Oil Processing, And Transformer Sales And Service. Fti Is Notified With The Department As A Large Quantity Generator (Lqg) Of Hazardous Waste, A Used Oil Transporter/Transfer Facility/Processor/Marketer, And Used Oil Filter Transporter. Transporter Registrations Expire On June 30, 2018.
The Facility Has Been In Operation For Over 38 Years And Has Approximately 113 Employees Working From 6am To 4:30pm, Six Days Per Week. The Facility Is Situated On 25 Acres, Of Which 15 Acres Are Actively Used While 10 Are Not. Fti Is On The City Sewer System. The Current Facility Manager Is Andy Hall. The Inspection Was Facilitated By Jessica Pennington, Fti’S Director Of Safety And Environmental Compliance.
| Throughout The Facility, The Main Points Of Hazardous Waste Generation Are Sludges Resulting From The Used Oil Processing Unit (Redragon), Waste From Paint Booth Operations, And Materials From Laboratory Analysis Of Transformer Oil.
On September 15, 2017, Department Personnel Paige Plier And Corinna Clanton Conducted A Routine Inspection Of The Fti Site. The Inspection Consisted Of Visual Site Examination And A Review Of The Facility’S Records. The Visual Inspection Consisted Of The Following: Intake Processing, Laboratory, Pcb Ancillary Area/Universal Waste Storage Area, Hazardous Waste 90-Day Storage Area, Redragon Used Oil Processor/Tank Farm, Middle Paint Booth, And The Transformer Repair Shop.
--------------------------
Intake Processing:
The Facility Receives Transformers From Alabama, Mississippi, Georgia, Tennessee, Florida, North Carolina, South Carolina, And Maryland. The Facility Uses Contracted Drivers To Transport All Out-Of-State Pickups. Transformers Arrive At Intake Processing Which Is A Large Warehouse Building With Open Garage Bays And An Extended Roof That Covers The Loading Dock Area. The Transformers Are Unloaded And Placed Onto A Conveyor System Into One Of Ten Assembly Lines Based On Transformer Type (Photo 1). Any Transformers That Are Destined For Disposal From The Generator Must Be Accompanied By Oil Analysis Test Documents Before Being Received By Facility. The Transformers That Are Not Designated For Disposal Have Oil Samples Taken Once They Arrive At The Facility. Each Transformer Has Its Own Barcode Attached To It Once It Enters The Facility. This Barcode Follows The Transformer Throughout Its Processing. After The Oils Have Been Tested For Polychlorinated Biphenyl (Pcb) Concentration, The Transformers Receive An Additional Colored Tag Based On The Average Pcb Concentration In Parts Per Million (Ppm). Transformers With Pcb-Contaminated Oil Receive And A Red And Orange Tag And The Transformers With Non-Pcb Oils (< 2ppm) Receive A White Tag. Transformers Are Also Temporarily Spray Painted With Their Tag Color And The Pcb Concentration Is Written On The Lid Of The Transformer (Photo 2). Transformers That Need Repairs Are Marked With A Blue “X” Or An “R.”
Oils That Are Found To Have Less Than Two Ppm Of Pcbs Are Filtered, Visually Inspected For Moisture And Place Into A Storage Tank. The Removed Oils That Range Between 2-49 Ppm Of Pcbs Are Pumped To One Of Three Holding Tanks. These Oils Are Then Processed Via The Onsite Oil Processing Equipment (Redragon) And Subsequently Stored In A 15,000-Gallon Tank. The Processed Oils Are Marketed As A Lubricant. Transformer Oils That Have Between 50 And 499 Ppm Of Pcb Content Are Pumped Into One Of Four 1,295-Gallon Storage Tanks Located In The Pcb Storage Room. Transformers That Have A Content Of 3,000 Gallons Or More Of Used Oil Or Have A Pcb Content Of Above 499 Ppm Are Not Processed Onsite. These Transformers Are Moved To The Pcb Storage Room And Transferred To Another Location In Pell City, Alabama. Fti Also Receives Customer Generated Used Oils In Plastic Ibc Totes And Consolida |
|
|
09/26/2017 |
Phone Conversation |
Finished-09/26/2017 |
|
|
10/04/2017 |
Electronic Communication |
Finished-10/04/2017 |
|
|
10/24/2017 |
Electronic Communication |
Finished-10/24/2017 Official Cao Response & Rtc Efforts |
|
|
10/24/2017 |
Submittal Received By Department |
Finished-10/24/2017 |
|
|
10/26/2017 |
Site Inspection |
Follow-Up; LQG (>1000 kg/month) - Follow-Up; Used Oil Processor This Follow-Up Report Addresses Minor Out-Of-Compliance Issues Noted In Florida Transformer’S Initial Inspection Report Dated September 15, 2017. The Facility Was In Violation Of Title 40 Code Of Federal Regulations (Cfr) Parts 265.52(D), 265.52(E), 265.53(B) And Of Chapter 62-710.401(6) And 62-737.400(5)(A). Specifically, The Sites’ Contingency Plan Was Missing Items Specific To The Resource Conservation And Recovery Act (Rcra), At Least Two Used Oil Containers Were Open, And Universal Waste Lamps Were Not Being Managed In A Way To Prevent Releases Of Mercury.
The Facility Sufficiently Responded To The Department’S Compliance Assistance Offer Letter That Was Sent On September 25, 2017. Their Official Response Was Received On October 4, 2017, Via Electronic Communication.
A Follow-Up Site Visit And Inspection Was Conducted On October 26, 2017. During The Inspection, An Updated Copy Of The Contingency Plan Was Reviewed And The Universal Waste And Used Oil Storage Areas Were Visually Inspected. Upon Review Of These Items, All Deficiencies Noted In The Initial Report Were Corrected And The Facility Appears To Be In Compliance.
| Florida Transformer Appeared To Be In Compliance With State And Federal Hazardous Waste Regulations. |
|
|
10/30/2017 |
Informal Verbal Enforcement |
Compliance Assistance Offer Writtenfor InformalVerbalEnforcement-09/25/2017 ; Compliance Assistance Phone Callfor InformalVerbalEnforcement-09/26/2017 ; Compliance Assistance Correspondencefor InformalVerbalEnforcement-10/04/2017 ; Compliance Assistance On-Site Visitfor InformalVerbalEnforcement-10/26/2017 ; Finished-10/30/2017 |
|
|
11/02/2017 |
Informal Verbal Enforcement |
Finished-11/02/2017 |
|
|
11/02/2017 |
Informal Verbal Enforcement |
Finished-11/02/2017 |
|
|
11/02/2017 |
Informal Verbal Enforcement |
Finished-11/02/2017 |
|
|
10/25/2018 |
Site Inspection |
Routine; Used Oil Processor Florida Transformer Inc.(Fti), Is A Power Transformer Repair And Processing Facility Located In Defuniak Springs, Florida. The Facility Operations Include Transformer Repair, Used Oil Processing, And Transformer Sales And Service. Fti Is Notified With The Department As A Large Quantity Generator (Lqg) Of Hazardous Waste, A Used Oil Transporter/Transfer Facility/Processor/Marketer, And Used Oil Filter Transporter. Transporter Registrations Expire On June 30, 2019.
The Facility Has Been In Operation For Over 38 Years And Has Approximately 98 Employees Working From 6am To 4:30pm, Six Days Per Week. The Facility Is Situated On 25 Acres, Of Which 15 Acres Are Actively Used While 10 Are Not. Fti Is On The City Sewer System. The Current Facility Manager Is Andy Hall. The Inspection Was Facilitated By Jessica Pennington, Fti’S Director Of Safety And Environmental Compliance.
| Throughout The Facility, The Main Points Of Hazardous Waste Generation Are Sludges Resulting From The Used Oil Processing Unit (Redragon), Waste From Paint Booth Operations, And Materials From Laboratory Analysis Of Transformer Oil. Mrs. Pennington Stated That During A Financial Review Of Company Expenses, The Redragon Unit Is Temporarily Not Being Used. Currently, Used Oil Is Being Transported And Processed At Offsite Facilities, Returned, And Used As Product Oil (See ‘Records’).
The Inspection Consisted Of Visual Site Examination And A Review Of The Facility’S Records. The Visual Inspection Consisted Of The Following: Intake Processing, Laboratory, Pcb Ancillary Area/Universal Waste Storage Area, Hazardous Waste 90-Day Storage Area, Redragon Used Oil Processor/Tank Farm, Outdoor & Indoor Paint Booths, And The Transformer Repair Shop.
--------------------------
Intake Processing:
The Facility Receives Transformers From Alabama, Mississippi, Georgia, Tennessee, Florida, North Carolina, South Carolina, And Maryland. The Facility Uses Contracted Drivers To Transport All Out-Of-State Pickups. Transformers Arrive At Intake Processing Which Is A Large Warehouse Building With Open Garage Bays And An Extended Roof That Covers The Loading Dock Area. The Transformers Are Unloaded And Placed Onto A Conveyor System Into One Of Ten Assembly Lines Based On Transformer Type. Any Transformers That Are Destined For Disposal From The Generator Must Be Accompanied By Oil Analysis Test Documents Before Being Received By Facility. The Transformers That Are Not Designated For Disposal Have Oil Samples Taken Once They Arrive At The Facility. Each Transformer Has Its Own Barcode Attached To It Once It Enters The Facility. This Barcode Follows The Transformer Throughout Its Processing. After The Oils Have Been Tested For Polychlorinated Biphenyl (Pcb) Concentration, The Transformers Receive An Additional Colored Tag Based On The Average Pcb Concentration In Parts Per Million (Ppm). Transformers With Pcb-Contaminated Oil Receive And A Red And Orange Tag And The Transformers With Non-Pcb Oils (< 2ppm) Receive A White Tag. Transformers Are Also Temporarily Spray Painted With Their Tag Color And The Pcb Concentration Is Written On The Lid Of The Transformer. Transformers That Need Repairs Are Marked With A Blue “X” Or An “R.”
Oils That Are Found To Have Less Than Two Ppm Of Pcbs Are Filtered, Visually Inspected For Moisture And Place Into A Storage Tank. The Removed Oils That Range Between 2-49 Ppm Of Pcbs Are Pumped To One Of Three Holding Tanks. These Oils Are Then Processed Via The Onsite Oil Processing Equipment (Redragon) And Subsequently Stored In A 15,000-Gallon Tank. The Processed Oils Are Marketed As A Lubricant. Transformer Oils That Have Between 50 And 499 Ppm Of Pcb Content Are Pumped Into One Of Four 1,295-Gallon Storage Tanks Located In The Pcb Storage Room. Transformers That Have A Content Of 3,000 Gallons Or More Of Used Oil Or Have A Pcb Content Of Above 499 Ppm Are Not Processed Onsite. These Transformers Are Moved To The Pcb Storage Room And Transferred To Ano |
|
|
02/24/2021 |
Site Inspection |
Routine; LQG (>1000 kg/month) - Routine; Hazardous Waste Transporter - Routine; Used Oil Transporter - Routine; Used Oil Processor - Routine; Used Oil Marketer Florida Transformer Llc (Fl Transformer Or Facility) Is A Power Transformer Repair And Processing Facility Located In Defuniak Springs, Florida. The Facility, Situated On Approximately 25 Acres, Has Been In Operation For Over 40 Years And Currently Has 93 Employees. The Current Operations Include Transformer Repair, Service, Sales, And Used Oil Processing. The Facility Is A Large Quantity Generator (Lqg) Of Hazardous Waste, And A Registered Hazardous Waste Transporter, Used Oil Filter Transporter, And Used Oil Transporter, Transfer Facility, Processer, And Marketer.
Fl Transformer Was Last Inspected On October 25, 2018, By The Florida Department Of Environmental Protection (Dep Or Department) As A Routine Used Oil Processer And A Hazardous Waste Compliance Evaluation Inspection (Cei) And Was Determined To Be In Compliance With Applicable State And Federal Regulations.
A Routine Hazardous Waste Cei Was Conducted, Jointly With The Us Environmental Protection Agency (Epa) On Febraruy 24, 2021 To Determine Compliance With State And Federal Hazardous Waste And Used Oil Regulations. Monica Hardin Represented Dep And Héctor Danois And Kayla Acosta Represented Epa. The Inspection Was Facilitated By Jessica Pennington- Director Of Safety & Environmental Compliance And Kimber Armstrong- Regulated Services Supervisor.
Inspectors Wore Personal Protective Equipment While Onsite Including Safety Boots, Safety Glasses, Hard Hats, And Face Mask Coverings (Due To Covid-19).
| Due To Covid-19, The Facility Was Contacted In Advance Of The Onsite Inspection And An Opening Interview Was Conducted Via Teams Meeting On February 19, 2021. Electronic Records Were Requested In Advance As Well For Offsite Review. On February 24, 2021 Inspectors Arrived Onsite At Approximately 09:00 And Were Received By Ms. Pennington And Ms. Armstrong We Introduced Ourselves, Briefly Discussed The Purpose Of The Visit And Discussed A Plan For The Onsite Inspection.
Visual Inspection
Laboratory
The Laboratory (Lab) Is In An Indoor Area Immediately Adjacent To In Processing With A Chemical Storage Room Also Nearby. The Lab Was Described As The First Point Of Hazardous Waste Generation In The Facility. The Lab Is Responsible For Conducting Analyses On All Equipment’S Oil That Comes Into The Facility For Repair. Hexane And Sulfuric Acid Are Primarily Used For Extraction In A Gas Chromatic Spectrometer.
Within The Lab We Observed One Satellite Accumulation Area (Saa) With One 5-Gallon Container Labeled For Hazardous Waste And Pcb Waste. The Container Appeared Closed And In Good Condition But Did Not Appear To Have An Indication Of The Content’S Hazards (Photo 1). The Container Is Emptied Daily In The 90-Day Accumulation Area. There Was Also One 5-Gallon Container For Pcb Contaminated Wastes Such As Pipettes And Gloves; No Liquid Wastes Are Placed Within This Container.
--------------------
In Processing
In Processing Is A Large Warehouse Building With Five Garage Bays And An Extended Roof Covering A Loading Dock Area. The Facility Receives Electrical Equipment Such As Transformers And Capacitors Via A Transportation Fleet Owned By The Facility With The Exception Of Three Contract Drivers. Equipment Is Unloaded And Placed On A Conveyor System Into One Of Ten Assembly Lines Based On Type. Transformers That Are Destined For Disposal From A Generator Must Be Accompanied With Oil Analysis Documents Upon Arrival At The Facility. Transformers Destined For Repair Have Oil Samples Taken Upon Arrival At The Facility, A Barcode Is Attached And Remains With The Equipment For The Duration Of Its Time At The Facility. Once Oil Analyses Are Obtained, The Equipment Receives A Colored Tag Based On Polychlorinated Biphenyl (Pcb) Concentrations In Parts Per Million (Ppm). In Addition To The Colored Tags, Transformers Are Also Temporarily Spray Painted With Their Tag Color And The Pcb Concentration Is Written On The Lid.
Oils That Are Found To Have Less Tha |
|
|
04/13/2021 |
Issue Non-Compliance Letter |
Sent-04/13/2021 ; Finished-02/01/2022 |
|
|
07/14/2021 |
Site Inspection |
Follow-Up; LQG (>1000 kg/month) - Follow-Up; Hazardous Waste Transporter - Follow-Up; Used Oil Transporter - Follow-Up; Used Oil Processor - Follow-Up; Used Oil Marketer This Follow-Up Report Addresses Out-Of-Compliance Issues Noted In The Florida Transformer Llc Dba Emerald Transformer (Fl Transformer Or Facility) Initial Inspection Report Dated February 23, 2021. The Facility Was In Violation Of Title 40 Code Of Federal Regulations (Cfr) Parts 262 And 279, And Chapter 62-710, Florida Administrative Code (F.A.C.). Specifically, For Open Hazardous Waste Containers, Hazardous Waste Container Lacking The Contents’ Hazards, Lacking ‘No Smoking’ Signs, Used Oil Tank/Containers Lacking ‘Used Oil’, And Failure To Provide Adequate Secondary Containment For Used Oil.
The Department Sent A Compliance Assistance Offer To The Facility On April 13, 2021. The Facility Responded On May 10, 2021 Via Electronic Communication. The Facility’S Written Response Addressed Each Violation Individually; An Onsite Follow-Up Inspection Was Conducted On July 14, 2021 By Monica Hardin And Nicole Hetzel Of The Florida Department Of Environmental Protection (Department Or Dep) And Was Facilitated By Kimber Armstrong, Regulated Services Supervisor Of Fl Transformer.
All Of The Above Listed Violations Were Corrected During And/Or Following The Initial Inspection And Return-To-Compliance Efforts Are Described In Detail Below.
| 40 Cfr 262.15(A)(4)- Open Hazardous Waste Container(S)
The Grit Blast Unit In The Paint Area Sends Spent Blast Media To 55-Gallon Drums. At The Time Of The Initial Inspection, We Noted Two 55-Gallon Drums Were Attached To The Unit Via Hoses Through A Hole Cut In The Top Of The Drums; The Hoses Did Not Appear Sealed With Gaps Evident.
In The Cao Response, The Facility Indicated ‘Flashing Boots’ Will Be Affixed To The Drum Tops To Secure The Hoses Eliminating Gaps. During The Follow-Up Inspection, The Grit Blast Unit Drums Appeared Closed By The Addition Of The Flashing Boots (Photo 1).
40 Cfr 262.15(A)(5)- Hazards Of The Contents Label
The Satellite Accumulation Container (Saa) In The Laboratory Did Not Contain An Indication Of The Contents’ Hazards.
The Facility Affixed A Flammable Label To The Container To Indicate The Associated Hazard. At The Time Of The Follow-Up Inspection, The Lab Saa Container Appeared Appropriately Labeled (Photo 2).
40 Cfr 262.17(A)(1)(Vi)(B)- Posted 'No Smoking' Near Ignitable Waste Storage
At The Time Of The Initial Inspection, ‘No Smoking’ Signs Were Not Posted Near The Central Accumulation Storage Areas Storing Ignitable Wastes.
The Facility Immediately Addressed This Issue Following The Onsite Inspection And Provided A Photo On February 26, 2021 Of A Posted ‘No Smoking’ Sign In A Central Accumulation Area. At The Time Of The Follow-Up Inspection, ‘No Smoking’ Signs Were Noted Near The Three Designated Waste Accumulation Areas.
40 Cfr 279.22(C)(1)- 'Used Oil' Labeling
In The Decommission Area, Containers In Place To Catch Residual Used Oil And An Above Ground Storage Tank Were Not Labeled With ‘Used Oil’.
In The Cao Response, The Facility Stated They Stenciled ‘Used Oil’ On The Identified Containers And Tanks; Photos Were Provided On May 10, 2021. During The Follow-Up Inspection, All Observed Used Oil Containers And Tanks Appeared Appropriately Labeled.
62-710.401(6), F.A.C.- Secondary Containment
Used Oil Tanks And Containers Were Observed Lacking Appropriate Secondary Containment In Three Areas Throughout The Facility.
In The Cao Response, The Facility Indicated Materials Were Purchased To Construct Adequate Secondary Containment For Tank Q. The Ibc Totes Were Emptied And Moving Forward The Facility Has Designated A Storage Area With Existing Containment For Up To 3,000 Gallons. The Facility Is Also In The Process Of Determining The Best Method For Providing Secondary Containment In The Decommission Area And May Berm The Entire Area.
At The Time Of The Follow-Up Inspection, The Facility Had Ceased Using Tank Q Until The Secondary Containment Could Be Constructed And Installed; A Sign Was On The Unit To Prevent Personnel From Adding Used Oi |
|
|
09/08/2023 |
Site Inspection |
Routine; LQG (>1000 kg/month) - Routine; Hazardous Waste Transporter - Routine; Used Oil Transporter - Routine; Used Oil Processor - Routine; Used Oil Marketer Photos:
1. In Processing - Where Transformers Enter Facility
2. The Laboratory - Pcb Waste Container
3. Outside Lab - Eye Wash Station
4. 90 Day Central Accumulation Area
5. 90 Day Central Accumulation Area
6. 90 Day Central Accumulation Area
7. Tank Q - No Secondary Containment
8. Repair Shops - No Secondary Containment
9. Paint Room - No Hazardous Waste Label
10. Paint Room - No Labels
11. Pcb Storage Room
12. Outside Storage Area | Florida Transformer Will Remain Out Of Compliance Until All Violations Above Have Been Addressed. A Follow-Up Inspection Will Be Conducted In The Future. |
Florida Transformer (Ft Or Facility), Emerald Transformer'S Florida Facility Is Located At 4509 State Highway 83 N, Defuniak Springs, Florida. For Over 50 Years They Have Offered Services Including Remanufactured Transformer Stock, Repairs, Decommissioning, Field Technical Services, Parts, Polychlorinated Biphenyl (Pcb) Disposal And Recycling. Florida Transformer Is Registered As A Used Oil Processor, Though Facility Personnel Stated They Are Currently Not Processing Their Used Oil. The Facility Sits On 25 Acres Of Land, With 11 Additional Acres Recently Purchased. Of The 11 Acres, Five Will Be Used For Storage And The Other Six Will Remain Undeveloped For The Time Being. Florida Transformer Was Last Inspected February 24, 2021, With Out Of Compliance Issues Noted. The Facility Returned To Compliance As Of July 14, 2021.
On July 26, 2023, The Florida Department Of Environmental Protection (Dep Or Department) Personnel Arrived Onsite To Conduct An Unannounced Routine Compliance Evaluation Inspection To Determine If The Facility Was In Compliance With State And Federal Hazardous Waste And Used Oil Regulations. Emerald Transformer Claimed They Had No One At The Facility To Lead The Department Through Their Inspection And Asked If Dep Could Come Back At Another Time. Per Florida Statute 403.091, An Authorized Representative Of The Department May Inspect A Hazardous Waste Facility At Any Reasonable Time. The Facility Provided A Couple Employees To Walk Department Personnel Through Several Sections Of The Establishment. However, At One-Point Personnel Were Left Alone In The In Processing Area. At This Time, Dep Decided It Would Be Best To Leave The Facility For Safety Purposes And Lack Of Guidance.
On September 8, 2023, Department Personnel Stephanie Kindos, Camille Cox, And Mark Sumner Returned To Complete A Routine Compliance Evaluation Inspection Of The Facility, Facilitated By Jessica Pennington And Will Higdon Of Florida Transformer. Personal Protective Equipment (Ppe) Was Required, Including Safety Glasses, Vest, And Appropriate Footwear. The Facility Is A Large Quantity Generator (Lqg) Of Hazardous Waste, A Registered Hazardous Waste Transporter, Used Oil And Used Filter Transporter, Transfer Facility, Processor, And Marketer. The Inspection Consisted Of Multiple Buildings And Rooms Including In Processing, Which Encompassed Three 90-Day Central Accumulation Areas, The Laboratory, The Repair Shops, Paint Area, Tank Farm, And Decommission Area.
|
In Processing
The Inspection Began In The In Processing Area, Which Is Housed In A Large Warehouse With An Extended Roof Covering A Loading Dock Area Where Transformers Enter The Facility To Be Checked In. The Transformers Are Offloaded Onto 10 Sets Of Rollers Or Left Outside The Warehouse If Too Large. All Equipment Is Issued A Bar Code That Follows The Transformer Through Its Entire Process While At Ft. A Copy Of Each Label Is Transferred To A Small Vial Filled With Oil From The Transformer. Each Vial Is Then Taken To The Laboratory On Site Where It Is Tested For Pcb Concentrations. A Transformer Whose Oil Contains Less Than 2 Parts Per Million (Ppm) Of Pcb Is Determined Non-Detect And Then Placed Into A Storage Tank Or Set Aside In An Intermediate Bulk Container (Ibc Tote) If The Customer Wants The Same Oil Returned To Their Transformer. Transformer Oils That Have A Pcb Concentration Of L |
|
|
05/01/2024 |
Site Inspection |
Routine; Used Oil Transporter - Routine; Used Oil Transfer Facility - Routine; Used Oil Processor Florida Transformer (Ft Or Facility), Emerald Transformer'S Florida Facility Is Located At 4509 State Highway 83 N, Defuniak Springs, Florida. For Over 50 Years They Have Offered Services Including Remanufactured Transformer Stock, Repairs, Decommissioning, Field Technical Services, Parts, Polychlorinated Biphenyl (Pcb) Disposal And Recycling. Florida Transformer Is Registered As A Used Oil Processor And A Large Quantity Generator (Lqg) Of Hazardous Waste. The Facility Sits On 25 Acres Of Land, With 11 Additional Acres Recently Purchased. Of The 11 Acres, Five Will Be Used For Storage And The Other Six Will Remain Undeveloped For The Time Being.
On May 1, 2024, A Routine Unannounced Hazardous Waste Inspection Was Conducted At Ft By The Florida Department Of Environmental Protection (Dep Or Department) To Assess Compliance With Used Oil Processing Requirements. A Concurrent Inspection Was Conducted By A Separate Dep Inspector Relating To Previous Out Of Compliance Concerns Regarding Hazardous Waste Management. Both Inspections Were Facilitated By Jessica Pennington, Regional Environmental Compliance Manager. | For The Purpose Of This Inspection Report, Only Areas Related To Used Oil Processing Are Included As Other Areas Fall Under The Follow Up Inspection Related To Lqg Operations.
The Tank Farm (Photo 1) Is A Partially Covered Area With Five Above Ground Storage Tanks (Ast’S) For Storing Used Oil And Pcb-Contaminated Oil. Three 8,400-Gallon Asts Are Used To Store Mineral Oil Before Treatment. Two Asts Are Used As Holding Tanks For Regenerated Oil With A Capacity Of 8,825-Gallons And 15,000-Gallons, Respectively. The Two Ast Tanks For Regenerated Oil Storage Are Only For Oil With Minimal Pcb Concentrations. The Tank Termed The “Red Dragon” Is For Oil With A Pcb Concentration Of Greater Than 50 Parts Per Million (Ppm).
Adjacent To The Tank Farm Is The Outside Storage (Photo 2) Area Where The Facility Stores Intermediate Bulk Container (Ibc) Totes That Are Either Empty Or Have Pcb-Laden Oil Too Contaminated For Regeneration. A Newly Installed Berm (Photo 3) Is Surrounding This Area And Serves As Secondary Containment. Engineering Plans Confirming Adequate Capacity Were Provided With No Concerns Noted By The Inspector.
At The Time Of Inspection This Area Was Currently Undergoing Routine Maintenance, Therefore Minimal Waste Was Present.
-------------------------------
Records
-------------------------------
The Following Records Were Reviewed On Site: Tank Inspections And Maintenance Logs, Annual Closing Cost Estimates, Tier Two Annual Submittal, Used Oil Registration, Shipping Manifests, And Arrangements With Local Authorities In Case Of Emergencies. No Deficiencies Were Noted During The Inspection.
| At This Time, Florida Transformer Appears To Be Operating In Compliance With State And Federal Regulations Regarding Used Oil Processing. |
|
|
09/27/2024 |
Site Inspection |
File Review; LQG (>1000 kg/month) On September 27, 2024, The Northwest District Of The Department Of Environmental Protection (Dep Or Department) Conducted A File Review For Florida Transformer Llc Regarding Previously Cited Violations. | The Initiating Inspection Was Conducted September 8, 2023, And Resulted In A Warning Letter Being Issued For Violations Regarding Used Oil Storage Requirements, Lack Of Records Management, And A Prior Refusal Of Access. Since The Initial Inspection, Jessica Pennington, Regional Environmental Compliance Manager, Has Worked With The Department To Rectify The Violations. Correspondence With The Facility Owner As Well As Follow Up Inspections Indicates That All Outstanding Violations Have Now Been Resolved. The Final Requirement Was Met On May 7, 2024 When Ms. Pennington Supplied The Department With Photos Showing The New Used Oil Containers And Their Appropriate Labels. | At This Time It Appears That Florida Transformer Llc Has Returned To State And Federal Requirements For Hazardous Waste Generators. |
|
|
01/14/2025 |
Enforcement Tracking |
Finished-01/14/2025 Sfco Executed And Signed, All Penalties Paid And Closed By Ogc On 1/3/25 |
|