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08/30/2017 |
Site Inspection |
Routine; Transporter - Routine; Used Oil Transporter Tg Oil Services, Inc. Notified And Was Granted Status As A Used Oil And Hazardous Waste Transporter Effective June 21, 2017. The Company Is Mainly An Elevator Service And Repair Contractor, Operating Under Certificate Of Competency #3526 For Elevator Repair. Mr. (Juan) Carlos Touzan Provided Information During This Inspection. The Company Notified In Order To Be Able To Transport More Than 55 Gallons Of Used Hydraulic Oil And Oily Waste Water At A Time. The Company Appears To Have Notified As A Hazardous Waste Transporter In Error, As It Does Not Transport Hazardous Waste And Is Not Registered With The Usdot To Transport Hazardous Materials. Used Hydraulic Oil And Oily Waste Water Are Not Usdot Hazardous Materials, As The Flash Point Of This Material Is Over 200 Degrees F. It Was Recommended That Mr. Touzan Delete Hazardous Waste Transporter Registration When His Used Oil Registration Renewal Is Due. The Company Operates Two Vehicles, A Van And A Box Truck. No Used Oil Was On Site, And Mr. Touzan Said That He Had Not Yet Brought Any Oily Waste Back To The Facility. Therefore, This Inspection Was Mainly Devoted To Providing Compliance Assistance And Training To Mr. Touzan. | The Company'S Major Waste Stream Is Oily Waste Water, Generated When Cleaning Out And Sealing Elevator Pits. Used Hydraulic Oil Is Also Sometimes Generated. The Company Only Uses Water Based Detergents, Simple Green, Drylok And Grout For Cleaning And Waterproofing. No Hazardous Solvents Are Used, And Hazardous Waste Is Not Generated. The Concrete In The Pits May Be Ground To A Clean Surface Prior To Waterproofing, And The Dust Is Collected And Disposed Of As Oily Debris.
These Wastes Are Packaged In 55 Gallon Plastic Drums. The Facility Has Constructed Racks For Storing Full And Empty Drums Within The Facility. Previously, The Company Made Arrangements With Another Used Oil Transporter To Pick Up These Wastes At The Generator Location, But Wanted To Be Able To Collect The Material And Transport It Off Site As A Service To Their Customers. As The Company May Have Several Jobs A Day, More Than 55 Gallons Of Waste May Need To Be Transported At A Time. Applicable Recordkeeping Requirements Were Discussed For Oil Generation And Transport. Mr. Touzan Was Informed Of The Secondary Containment Requirement For Used Oil Stored Indoors In Containers Of More Than 55 Gallons, And For Any Size Of Container Stored Outdoors. He Was Also Provided With Stencils For Labeling Containers Of Used Oil.
The Company Has Been Generating Used Oil Transport Records Since August, As A Means To Document Disposal For Each Generation Site. The Forms Used For The Customer Site Are Tracked As Incoming Oil, And Include Fields For The Name And Address Of The Oil Provider And Transporter, The Transporter Epa Id Number, The Quantity And Type Of Oil And Fields For Information On How The Company Complies With The Rebuttable Presumption. As The Company Is The Co-Generator Of The Oil, They Are Able To State That The Waste Is Not Mixed With Hazardous Waste Based On Process Knowledge. The Form Usually Includes Additional Information Specifying Which Elevator At The Generator Site Was Being Serviced. The Oil Transport Form Includes Several Options For The Type Of Oil, As It Was Adopted From A Form Used By Another Transporter. The Differences Between Used Oils Based On Usdot Hazardous Materials Classification And Flash Point Were Discussed. It Was Noted That In A Number Of Cases, No Representative Of The Oil Provider Had Signed The Receipts. Mr. Touzan Was Requested To Maintain Documentation That The Company Was Authorized To Sign The Receipts As Co-Generator Of The Oil. If The Oil Is Transported By Tg, The Company Also Needs To Sign As The Transporter. At This Time, Each Receipt From A Job Is Attached To The Receipt For The Outgoing Oil. Tg Has Been Using Jam Environmental And Vacuum Service For Oil Disposal. Copies Of These Records Were In Order.
Mr. Touzan Was Provided With Co |
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08/15/2019 |
Site Inspection |
Routine; CESQG (<100 kg/month) - Routine; Used Oil-Other - Routine; Used Oil Transporter - Routine; Used Oil Transfer Facility - Routine; VSQG (<100 kg/month) A Compliance Evaluation Inspection Was Conducted On Tg Oil Services Inc (Tg) And Performed By Environmental Specialist I, Juliana Reis (Inspector), On Behalf Of The Florida Department Of Environmental Protection (Dep) On May 29, 2019. The Inspector Was Accompanied By Dep Representatives Justin Stark, Environmental Specialist Ii; Romina Lancellotti; Environmental Specialist Ii; And Tg Representative Erik Valiente, Safety Director. The Facility Is Situated On Approximately 1,300 Square Feet Of Property, Has 15 Employees, And Is On Public Water And Sewer. The Facility Has Been Operating At This Location For One (1) Year.
Notification History:
08/23/19 – Notified As Used Oil Transporter (Uot) And Transfer Facility And As Used Oil Filter Transporter (Uotf) And As Transfer Facility.
08/05/19 - Notified As A Hazardous Waste Transporter (Hwt), Used Oil Transporter And Used Oil Filter Transporter; However, During The Inspection, The Inspectors Observed The Facility Was Also Operating As A Transfer Facility. Compliance Assistance Was Given Advising Tg To Re-Notify The Department Adding The Transfer Facility Status.
03/17/18 - Notified As Hazardous Waste Transporter And As Used Oil Transporter. This Notification Expired On 06/30/19. On 07/19/19, The Department Received Tg'S Re-Notification. The Facility Transported Used Oil And Used Oil Filters For 19 Days Without A Valid Registration.
08/08/17 - Notified As Hazardous Waste Transporter And As Used Oil Transporter.
Inspection History:
The Department Has Never Inspected This Facility At This Location. Tg Just Moved From 7815 W 2nd Ct, Unit #2, Hialeah, Fl 33014, Which Is The Current Address But Different Unit (#7). The Previous Location Was Inspected By Dep On 06/21/17 And The Facility Was In Compliance.
No Ppe Was Required But Department Personnel Were Equipped With Steel Toe Boots. | Tg Is Registered As A Transporter For Used Oil (Uo), Used Oil Filters (Uof) And Hazardous Waste. It Mainly Services Elevator Companies By Draining Oily Water, Repairing And Impermeabilizing The Elevator Pits. Also, It Sells Oil To Hydraulic Elevators. Additionally, Tg Transports Uo From Small Auto Shops And Uo Transporters Mainly Considered As Vsqg'S And Sqg'S.
Upon Arriving At The Facility, The Inspectors Presented Tg Representatives Their State Issued Credentials, As Required. The Inspectors Toured The Facility With Tg Representative, Mr. Valiente.
The Inspectors Toured Three (3) Areas Of The Facility. At The Administrative Offices, No Hazardous Waste Was Observed. Additionally, The Oil Storage And The Water Proofing Department Were Inspected. These Two Departments Are Located Across From Each Other And The Office Is In The Middle Of These Two Warehouses.
The Oil Storage
At This Area Tg Stores Uo, Uof, Oily Water And Product Oil.
At The Oil Department The Inspectors Observed:
>One (1) Vacuum Truck With The Capacity Of 2,400 Gallons (Us Dot 3011682). Since This Truck Container Is Divided Into Different Compartments, It Was Filled With Approximately 700 Gallons Of Product Oil (Hydraulic Fluid Aw32) And 240 Gallons Of Uo.
The Truck Collects The Uo, Oily Water And Oily Sludge From Picked-Up Drums And It Stores It In The Truck Container. After The Truck Is Full, Tg Transports It To Two (2) Designated Disposal Sites: Raider Environmental Services (Epad Id Flr000143891) Which Is Currently Registered As An Uo Processor And Accepts The Uo, Oily Water, Uo Filters And Uo Sludge; And World Petroleum Corp. (Epa Id Fld980709075) Which Is Currently Registered As Uo Processor And Accepts Uo And Oily Water. Tg Stated That, Depending On The Demand, It Takes One (1) To Two (2) Weeks For This Uo Truck To Be Filled And Taken To Disposal Facilities.
The Delivery Records Reviewed During The Inspection Demonstrated The Epa Id From The Transporter Was Missing On The Delivery Records [Per 40 Cfr 279.74(A)]. Compliance Assistance Was Given, Requesting The Insertion Of The Transporter Epa Id On These Records.
The Foll |
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10/09/2019 |
Warning Letter |
Sent-10/09/2019 ; Finished-01/14/2020 |
186651 |
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11/12/2019 |
Site Inspection |
File Review; CESQG (<100 kg/month) - File Review; Transfer Facility - File Review; Used Oil Transporter - File Review; VSQG (<100 kg/month) On November 12, 2019 (11/12/2019), Juliana Reis With The Florida Department Of Environmental Protection (Fdep) Conducted A File Review As A Supplement To An On-Site Inspection Conducted On 08/15/2019 At Tg Oil (Tg), Located At 7815 W. 2nd Ct. Unit 7, Hialeah, Fl 33014. Tg Oil Was Inspected To Determine The Facility’S Compliance With The State And Federal Hazardous Waste Regulations Described In Title 40, Code Of Federal Regulations (Cfr) Parts 260 Through 268, And 279 Adopted And Incorporated By Reference In Rule 62-730 & 62-760, Florida Administrative Code (F.A.C.). The Inspector Was Assisted By Fdep Staff Members Norva Blandin And Justin Stark.
Tg Oil Occupies Approximately 1,300 Square Feet Of Property And Is Connected To Public Water And Sewer. Tg Oil Has Been Operating At Its Current Location Since January 2019 And Employs 15 Staff. The Facility Operates Monday Trough Friday, From 8:00 A.M. To 5 P.M.
Inspection History:
The Facility Was Previously Inspected By The Department On 08/15/2019 As A Very Small Quantity Generator (Vsqg) Of Hazardous Waste, Used Oil Transporter And Used Oil Transfer Facility And Was Found To Be Out Of Compliance At The Time Of Inspection For Failure Provide The Following: Notification To The Department Used Oil Transporter And Used Oil Transfer Facility, Rebuttable Presumption, Spill Prevention, Control And Countermeasures Plan (Spcc Plan), Record Keeping, Secondary Containment For Stored Used Oil, And Employee Training Records. The Case Was Closed As Major Out Of Compliance.
| The Department Received A Submittal On 08/23/2019 That Included The Following Documentation:
>A Copy Of The Notification Email Sent To The Department, Prior To The Expiration Of The Used Oil Transporter Notification [40 Cfr 279.42(A), 62.710.500(1), F.A.C.].
>Rebuttable Presumption [40 Cfr 279.44(A)].
>Spcc Plan [40 Cfr 279.45].
>Records Associated With: Used Oil Burning And Used Oil Transporter And Transfer Facility Operations [40 Cfr 279.74(A)].
>Records Associated With Used Oil Manifests.
This Submittal Corrected The Outstanding Violations Listed Above.
After Further Review Of Tg Submittals, It Was Confirmed That The Facility Does Not Operate As A Used Oil Burner; Therefore, The Citation 40 Cfr 279.74(A) Is Not Applicable. The Appropriate Citation For The Record Keeping Violation Is 40 Cfr 279.46(A)(2), Which Refers To Used Oil Transporters And Transfer Facilities.
It Was Determined That The Facility Failed To List Its Epa Id On The Used Oil Transporter Manifests On 07/26/2019. It Was Also Discovered That The Raider Environmental Services Inc. Logo Was Being Used On Tg'S Used Oil Manifests. Additional Information Was Requested On 09/11/2019. In A Submittal Dated 09/13/2019, Tg Provided A Copy Of The Facility’S Updated Used Oil Transporter Manifest Which Reflected The Addition Of Tg’S Epa Id, The Epa Id Of The Designated Facility, Raider Environmental Services, Inc., And The Correction Of Tg’S Company Logo On The Used Oil Manifest. This Submittal Corrected The Violation Pertaining To 40 Cfr 279.46(A)(2).
Prior To The 11/12/2019 Meeting, It Was Discovered That The Facility Operated Without Valid Used Oil Transporter Registration From 07/01/2019 To 07/19/2019. The Submittals Following The Inspection Also Revealed That Tg Had Been Operating As A Transfer Facility Since March 2018 Without Submitting Registration To The Department. Additionally, It Was Determined That The Facility Was Operating Without A Valid Spill Prevention, Control And Countermeasure Plan (Spcc Plan) Implemented On-Site During The Inspection. These Findings Were Discussed During The 11/12/2019 Meeting.
In The 11/12/2019 Meeting, The Department Discussed The Corrected Violations, The Outstanding Violations, And The Additional Violation Related To 40 Cfr 279.46(A). To Correct The Remaining Violations, The Department Requested The Facility Provide The Following Corrections To The Manifests:
>Proof Of Secondary Containment For The 715 Gallons Of U |
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11/13/2019 |
Meeting |
Finished-11/13/2019 |
186651 |
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12/18/2019 |
Short Form Consent Order |
Issued-12/18/2019 ; Sent-12/18/2019 ; Finished-01/14/2020 |
186651 |
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01/03/2020 |
Short Form Consent Order |
Executed-01/03/2020 ; Finished-01/14/2020 Sfco Was Executed And Penalties Were Paid In Full On 1/9/2020. No Further Actions Are Needed. |
186651 |
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01/14/2020 |
Informal Hearing |
Finished-01/14/2020 The Document Was Uploaded Under Document Related Activities For Your Reference. |
186651 |
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01/14/2020 |
Penalty |
Finished-01/14/2020 Final Penalty- Signed And Approved By Sed Director. |
186651 |
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01/14/2020 |
Project Closed Letter |
Finished-01/14/2020 |
186651 |
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01/22/2020 |
Project Closed Letter |
Sent-01/22/2020 ; Finished-05/08/2020 |
186651 |
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03/16/2020 |
Site Photos |
Finished-03/16/2020 Site Photos Were Inserted To Oculus On 09/06/19. |
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03/16/2020 |
Status Report |
Finished-03/16/2020 |
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03/16/2020 |
Submittal Received By Department |
Requested-08/19/2019 ; Received-08/30/2019 ; Finished-03/16/2020 |
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03/16/2020 |
Penalty |
Finished-03/16/2020 |
186651 |
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03/16/2020 |
Submittal Received By Department |
Finished-03/16/2020 |
186651 |
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05/08/2020 |
Letter |
Finished-05/08/2020 The Facility Paid In Full All The Penalties Associated To Sfco On 01/09/2020. |
186651 |
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05/08/2020 |
Penalty |
Finished-05/08/2020 |
186651 |
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05/08/2020 |
Letter |
Finished-05/08/2020 |
186651 |
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09/09/2020 |
Enforcement Tracking |
Finished-09/09/2020 The Facility Has Returned To Compliance And Has Paid The Penalties In Full, Therefore No Further Action Is Needed. |
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03/17/2021 |
Site Inspection |
Routine; Used Oil Transporter - Routine; Used Oil Transfer Facility On March 17, 2021, Justin Stark With The Florida Department Of Environmental Protection (“Fdep”) Conducted A Compliance Evaluation Inspection (“Cei”) At Tg Oil Services Inc (Hereinafter “Tg” Or “Facility”), Located At 7815 W 2nd Ct Unit 7, Hialeah, Florida 33014. Tg Was Inspected To Determine The Facility’S Compliance With The State And Federal Hazardous Waste Regulations Described In Title 40, Code Of Federal Regulations (“C.F.R.”) Parts 260-268, 273, And 279, Adopted And Incorporated By Reference In Rule 62- 710, 62- 730, And Rule 62-737, Florida Administrative Code (“F.A.C.”).
Notification History:
Tg Initially Notified The Department As A Used Oil Transporter On 05/12/2017. This Notification Assigned The Epa Id Flr000222836. The Facility Most Recently Notified On 2/18/2021 As A Used Oil Transporter/Transfer Facility And Used Oil Filter Transporter/Transfer Facility. This Used Oil Transporter Registration Is Valid Until 06/30/2022.
Inspection History:
The Facility Was Previously Inspected By The Department On 8/15/2019 As A Used Oil Transporter And Was Found To Be Out Of Compliance At The Time Of Inspection For Failure Provide The Following: Notification To The Department Used Oil Transporter And Used Oil Transfer Facility, Rebuttable Presumption, Spill Prevention, Control And Countermeasures Plan (Spcc Plan), Record Keeping, Secondary Containment For Stored Used Oil, And Employee Training Records. The Violations Were Resolved With Formal Enforcement Action (Ogc# 19-1867).
Personal Protective Equipment (Ppe) Was Not Required To Enter The Facility. Department Personnel Were Equipped With Steel-Toed Boots And A Facial Mask. | Tg Is Registered As A Transporter For Used Oil (Uo), Used Oil Filters (Uof). It Mainly Services Elevator Companies By Draining Oily Water, Repairing And Impermeabilizing The Elevator Pits. Also, It Sells Oil To Hydraulic Elevators. Additionally, Tg Transports Uo From Small Auto Shops.
The Facility Consistent Of Three Areas. Two Warehouses And An Administrative Office.
No Hazardous Waste Or Used Oil Was Observed In The Administrative Office.
Warehouse One:
Warehouse One Is Located To The Left Of The Administrative Office And Is Used To Store One Vacuum Truck With The Capacity Of 2,400 Gallons And Uo, Uof, Oily Water And Oil.
The Following Was Observed:
> One 55-Gallon Poly Drums Of Uo, Labeled, Closed, With Secondary Containment (Photo #1).
> Spill Kits
> Fire Extinguishers
Warehouse Two:
Warehouse One Is Located To The Right Of The Administrative Office And Is Used To Store Equipment And Tools Such As: Waterproof Paints, Seal Foam Chemical And Concrete Mixer. No Hazardous Waste Or Used Oil Was Observed.
Record Review
Due To The Person In Charge Of Records Not Onsite During The Inspection And Cdc Guidelines For Covid-19. Records Were Requested Via Email.
>Acceptance And Delivery Records - Pcw, Oily Water And Uo Are Taken To Raider Environmental Services (Epa Id: Flr000143891) And World Petroleum Corps (Epa Id:Flr980709075), Both Are Registered With The Fdep As Permitted Used Oil Processor, Hazardous Waste, Uo, And Uof Transporter.
Based Off 5 Non-Hazardous Waste Manifests, Oily Sludge Is Occasionally Transported From The Elevators They Repair. Process Knowledge Was Used On Oily Sludge To Determine If Its Non-Hazardous Or Hazardous Waste. Since Tg Fully Services Elevators (Replaces And Drains Oil, Repairs, Etc) They Are The Co-Generator Of Any Waste Generated From These Process. Tg Shall Ensure Any Sludge Not Generated From The Elevator Repairs (Other Clients) Undergo A Waste Determine By The Generator In Order To Ensure Hazardous Waste Is Not Transported.
>Employee Training Records - All Employees Receive Initial And Annual Training On The Proper Management Of Used Oil, Including Handling, Storage, And Spill Response And Cleanup. The Facility Maintains These Records On-Site For 3 Years In Accordance With Rule 62-710.600(2)(B) F.A.C.
>Rebuttable Presumption Records - The Facility T |
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04/15/2021 |
Letter |
Sent-04/15/2021 ; Finished-10/20/2021 |
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10/20/2021 |
Status Report |
Finished-10/20/2021 |
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10/20/2021 |
Site Photos |
Finished-10/20/2021 |
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04/17/2024 |
Site Inspection |
Routine; Used Oil Transporter - Routine; Used Oil Transfer Facility On April 17, 2024, Kaitlyn Taylor With The Florida Department Of Environmental Protection (Dep) Conducted A Routine Compliance Evaluation Inspection (Cei) Tg Oil Services Inc. (Hereinafter “Tg” Or “Facility”), Located At 7815 W 2nd Ct Unit 7, Hialeah 33014. Tg Was Inspected To Determine The Facility’S Compliance With The State And Federal Hazardous Waste And State Used Oil Regulations Described In Title 40, Code Of Federal Regulations (Cfr) Parts 260- 268, And 279, Adopted And Incorporated By Reference In Rule 62-730 And 62-710 Florida Administrative Code (F.A.C.).
The Inspectors Were Escorted Around The Facility By Jasmine Guzman, Office Manager, And Eddie Moreda, Operations Manager. Upon Arrival At The Facility The Inspectors Presented Their Credentials And Explained The Purpose Of The Inspection.
Tg Occupies 2,600 Square Feet And Is Connected To Public Water And Sewer. The Facility Has Been Operating At Its Current Location Since 2009. The Facility Employs 10 Staff And Operates 8am – 5pm, Monday – Friday.
Notification History:
Tg Initially Notified With The Department As A Used Oil Transporter On 05/12/2017. The Facility Was Assigned The Epaid Flr000222836. The Facility Most Recently Notified On 3/21/2024 As A Used Oil And Used Oil Filter Transporter/Transfer Facility.
Inspection History:
The Facility Was Most Recently Inspected On 08/30/2018 As A Vsqg And A Used Oil Transporter, Generator, Transfer Facility, And Marketer And Was Found To Be In Compliance.
Personal Protective Equipment (Ppe) Was Required To Enter The Facility. The Department Inspectors Were Equipped With Steel-Toed Boots, Hard Hat, And Safety Glasses.
| Tg Services Elevators By Pumping Out Used Oil And Oily Sludge From The Elevator Pits. The Waste Transported From This Process Is Used Oil, Oily Sludge, And Used Oil Filters. Inspectors Were Informed That Used Oil Filters Are Normally Unloaded Into The Storage Area And Transported From The Facility On The Same Day. Used Oil And Oily Sludge Are Transported In 55-Gallon Drums Or Transported In The Vacuum Truck And Then Pumped Into 55-Gallon Drums When They Arrive At The Facility.
The Facility Also Offers Elevator Waterproofing Services. Inspectors Were Informed That No Waste Is Generated By This Process.
The Facility Has Six Vans, Three Box Trucks, And Two Vacuum Trucks (2,400-Gallons). All Vehicles Are Dot Certified With The Dot Number Posted On The Side.
Tg Consists Of An Office Space, A Storage Room For Elevator Waterproofing Supplies, And A Main Storage Area Where All Used Oil, Used Oil Filters, Oily Sludge, And Empty Drums Are Stored. Inspectors Observed The Following In The Main Storage Area:
- Approximately 20 55-Gallon Drums Labeled “Used Oil”.
- Approximately 20 55-Gallon Drums Labeled “Oily Sludge”.
- Shelves Lining The Two Side Walls For New And Empty Drum Storage.
- One Spill Kit, Eye Wash, Fire Alarm, And Fire Extinguisher.
All Used Oil And Oily Sludge Drums Were Properly Labeled, Closed, And On Secondary Containment. No Deficiencies Were Observed At The Time Of The Inspection.
Record Review:
• Acceptance And Delivery Records – All Waste Is Taken To Raider Environmental Services (Epa
• Id: Flr000143891) And World Petroleum Corps (Epa Id: Flr980709075).
• Halogen Screening Is Conducted For New Customers Of Tg Oil Services. Process Knowledge Is Used At Facilities Tg Oil Has Tested Previously Or When Knowledge Is Sufficient For The Waste Being Removed From The Elevator Pit [62-710.901(2-3)].
• The Facilities Spill Prevention, Control, And Countermeasure Plan (Spcc) Was Available For Review On-Site [40 Cfr 279.45].
• The Facility Could Demonstrate Liability Insurance With James River Insurance Company For $5,000,000, Policy Number 00150122-0, Expiring 11/20/2024. [62-710.600(2)(E), Fac]
• The Facility Could Provide Training To Employees To Be Familiar With State And Federal Used Oil Transporter Regulations (62-710.600(2)(B), Fac).
• The Facility Submitted An Annual Report For Used Oil And |
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04/19/2024 |
Status Report |
Finished-04/19/2024 |
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04/19/2024 |
Site Photos |
Finished-04/19/2024 Site Photos Were Uploaded To Oculus On 4/19/2024 |
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05/13/2024 |
Submittal Received By Department |
Finished-05/13/2024 All Other Requested Documentation Was Submitted To The Department Office In Person On 5/1/2024. |
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