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03/29/2022 |
Site Inspection |
Routine; CESQG (<100 kg/month) - Routine; Used Oil Transporter - Routine; Used Oil Transfer Facility - Routine; Used Oil Generator - Routine; VSQG (<100 kg/month) Cummins, Llc (Cummins, The Facility) Was Inspected On March 29, 2022. Cummins First Notified The Department In December 2019 As A Used Oil Transporter, Used Oil Generator And A Very Small Quantity Generator (Vsqg) Of Hazardous Waste. In January 2021 Cummins Renotified As A Used Oil Transporter And Transfer Facility, A Used Oil Filter Transporter And Transfer Facility, A Used Oil Generator, And A Vsqg Of Hazardous Waste. The Facility Has Never Been Inspected By The Department’S Hazardous Waste Program At This Location. Bill Powell (Operations Manager) And Dante Defrancesco (Service Advisor) Were Present Throughout The Inspection. Mitchell Kemp (Hse Leader) And Lynn Baker (Cummins Southern Group) Participated Via Phone In The Out-Brief.
Cummins Has Operated At This Location For Approximately 20 Years, But Has Only Recently Provided In-Field Service For Cummins-Brand Equipment. Cummins Has Approximately 20 Employees, And The Facility Operates Monday Through Friday, 7:30 Am To 5:00 Pm, And Infrequently On Weekends Depending Upon Customer Demand. The Facility Is Connected To City Water And Sewer, And Consists Of One Main Building That Includes Administrative Offices, Parts Storage, Maintenance Bays, Used Oil Storage And Waste Accumulation Area, And The Vehicle Wash Bay And Washwater Treatment Area. Areas Inspected Are Described Below.
| Mobile Servicing
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Cummins Is A Sales And Service Agent For Generators, Engines, And Parts. Maintenance Work On Cummins-Brand Equipment Is Performed Both In The Field And At The Facility. Maintenance Work On Other Manufacturer-Brand Equipment Is Performed In The Maintenance Bays Described Below. Cummins Transports Only Its Own Used Oil Generated At Its Own Non-Contiguous Operations To Its Own Central Collection Facility For Storage Prior To Having Its Used Oil Picked-Up By A Certified Used Oil Transporter. Cummins Operates Four Field Maintenance Trucks That Are Used To Transport Used Oil, Used Oil Filters And Antifreeze Generated During Field Servicing Activities Back To The Facility And Accumulated With The Wastestreams Generated At The Facility. The Used Oil, Used Oil Filters And Antifreeze Generated In The Field Are Added To The Facility'S Containers Located In The Used Oil And Waste Accumulation Area Described Below. Rarely, Cummins Is Required To Perform Maintenance On Generators That Contain 60 Gallons Of Product Oil. This Is An Area Of Concern. Cummins Operates As A Self-Transporter Of Used Oil That Is Defined In Both 40 Cfr 279 And 62-710, Florida Administrative Code (Fac), As Transportation Of Not More Than 55-Gallons At One Time. If Cummins Transports More Than This Quantity It Would No Longer Meet The Self-Transportation Definition, And Would Be Required To Meet All Used Oil Transporter Requirements Listed In These Regulations.
Maintenance Bays
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The Northern Portion Of The Main Building Is Used For Materials And Parts Storage. Maintenance On Heavy Equipment And Rvs Is Performed In The Middle Section Of The Main Building That Is Divided Into 16 Bays (Photo 1). Used Oil, Used Oil Filters, Oily Rags, Oily Absorbents, And Spent Antifreeze Are Generated In This Area. Used Oil Is Drained Into 5-Gallon Buckets Or Mobile Carts. All Used Oil Containers Observed In This Area Were Properly Labeled "Used Oil." Used Oil Containers Are Moved To The Used Oil And Waste Accumulation Area, Described Below, Where The Used Oil Is Pumped Into A 500-Gallon Single-Walled Aboveground Storage Tank (Ast). Used Oil Filters Are Transferred To 55-Gallon Drums Located In The Used Oil And Waste Accumulation Area. Oily Absorbents And Spill Cleanup Debris Are Transferred To 55-Gallon Drums Located In The Used Oil And Waste Accumulation Area. Waste Antifreeze Is Collected In Mobile Carts That Are Moved To The Used |
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