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07/21/2021 |
Site Inspection |
Routine; CESQG (<100 kg/month) - Routine; Hazardous Waste Transporter - Routine; Used Oil Generator - Routine; VSQG (<100 kg/month) Alpha-Omega Training & Compliance (Aotc, The Facility) Was Inspected By The Department'S Hazardous Waste Program On July 21, 2021. A Site Visit Was Also Conducted For The Records Review On September 1, 2021. Aotc Has Never Been Inspected At This Location; However, Its Former Location As 25370 Nw 8th Lane (Flr000167635) Was Last Inspected By The Department On August 10, 2017. That Location Ceased Operations And Closed In Early 2021. Aotc Has Been In Operation At Its Current Location Since April 2021. Mr. Daniel “Clint” Daugherty, Aotc Operations Manager, And Ms. Julie Pocklington, Alachua County Epd, Were Present Throughout The Inspection And The Records Review.
Aotc Is A Registered Hazardous Waste Transporter And A Very Small Quantity Generator (Vsqg) Of Hazardous Waste. Aotc Primarily Provides Emergency Response Services For Transportation Accidents And Small Industrial Facilities That Are Typically Very Small Quantity Generators Of Hazardous Waste. No Other Transportation Services Are Currently Provided, But Mr. Daugherty Said That Aotc Wants To Expand Its Transporter Services In The Near Future To Add Used Oil And Universal Wastes, And Also Operate As A Transfer Facility For These Additional Wastes And Hazardous Waste. Aotc Has Eight Employees And Operates Monday Through Friday From 8:30 Am To 5:00 Pm And Is On-Call 24/7 To Perform Emergency Response Services.
In April 2021 Aotc Closed Its Former Location At 25370 Nw 8th Lane (Flr000167635) And Began Operations At Its Current Location At 25207 Nw 8th Lane. The Facility Consists Of A Main Building That Includes Offices, Three Enclosed Vehicle Bays And An Open Bay That Will Be Used As A Maintenance/Wash Rack Area (Photo 1). A Second Building At The Facility Is An Open Warehouse Structure That Is Used For Staging Of Hazardous Wastes During Transport Activities Performed By Aotc (Photo 2). The Remainder Of The Property Is Used For Storage Of Supplies, Emergency Response Materials, And Heavy Equipment (Photo 3).
The Main Building Is Connected To City Water And City Sewer. Aotc Operates One Vacuum Truck, Two Emergency Response Trailers, And Various Trailers For Hauling Heavy Equipment. The Facility’S Vehicles Are Currently Maintained Off-Site By A Third-Party Vendor But Mr. Daugherty Said That Aotc Plans To Start Performing Routine Maintenance Of Its Equipment In The Open Bay Maintenance/Wash Rack Area In The Next Few Months.
| Hazardous Waste Transporter Operations
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At The Time Of The Inspection, Aotc Had Collected On-Site Two Containers Totaling 160 Pounds Of D002 Corrosive Hazardous Waste From Sysco-Baugh, A Vsqg, Located In Alachua, And Two Containers Totaling 105 Pounds Of D002 Corrosive Hazardous Waste From A Vehicle Accident That Involved Pool Cleaning Chemicals (Photo 4). The Containers Were Closed And Properly Labeled. All Four Containers Had Been On-Site At The Facility For Several Weeks. Mr. Daugherty Explained That Aotc Had Been Authorized By The Department To Consolidate Vsqg Waste Generated From Its Emergency Response Operations And From Other Facilities And As Part Of That Authorization It Was Allowed Additional Time To Manage And Dispose Of The Vsqg Waste. Further Research Into The Vsqg Consolidation Authorization Revealed That The Department Had Granted Aotc Authorization For Consolidation Of Vsqg Waste Beginning In 2010. However, That Authorization Was Granted Under Aotc’S Former Epa Id#Flr000167635 At Its Former Location At 25370 Nw 8th Lane. When Aotc Moved Operations In April 2021 It Did Not Request New Authorization To Continue Its Vsqg Consolidation Activities Under Its New Epa Id#Flr000238139. Aotc Failed To Notify Of A Change To Its Regulated Waste Activities [62-730.150(2)(B), Fac].
Records Review
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Aotc Is Currently Operating As A Hazardous Waste Transporter And A Very Small Qua |
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08/22/2024 |
Site Inspection |
Routine; Non-Handler - Routine; Hazardous Waste Transporter - Routine; Used Oil Transporter - Routine; Used Oil Transfer Facility - Routine; Used Oil Generator Alpha-Omega Training & Compliance (Aotc, The Facility) Was Inspected By The Department'S Hazardous Waste Program On. A Site Visit Was Also Conducted For The Records Review On October 2, 2024. Aotc Was Previously Inspected By The Department’S Hazardous Waste Program On July 21, 2021. Mr. Derek Free, Operations Manager, Was Present Throughout The Inspection.
Aotc Has Been In Operation At Its Current Location Since April 2021 And Notified The Department In April 2024 As A Hazardous Waste Transporter, A Petroleum Contact Water (Pcw) Transporter, Used Oil And Used Oil Filter Transporter And Transfer Facility, A Universal Waste Transporter, And A Very Small Quantity Generator (Vsqg) Of Hazardous Waste. Additionally, On November 12, 2021, The Department Granted Aotc The Authorization To Consolidate Hazardous Waste From Vsqgs. Aotc Has Eight Employees And Operates Monday Through Friday From 8:30 Am To 5:00 Pm And Is On-Call 24/7 To Perform Emergency Response Services. Aotc Operates One Vacuum Truck, Two Emergency Response Trailers, And Has Various Trailers That Are Used For Additional Supplies And/Or Transportation For Heavy Equipment.
The Facility Consists Of A Main Building That Includes Offices, Three Enclosed Vehicle Bays (Photo 1), And An Open Bay That Was Designed To Be Used As A Maintenance/Wash Rack Area With An Oil/Water Separator. Mr. Free Stated That Vehicles Are Infrequently Washed In This Area. The Main Building Is Connected To City Water And City Sewer. A Second Building At The Facility Is An Open Warehouse Structure That Serves As The Primary Waste Transfer Area And Is Used For Staging Of Transportation Wastes As Well As Aotc-Generated Waste (Photo 2). The Remainder Of The Property Is Used For Storage Of Supplies, Emergency Response Materials, And Heavy Equipment.
| Main Building And Vehicle Wash Area
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Aotc Generates Spent Aerosol Cans During Vehicle Maintenance. The Spent Aerosol Cans Are Managed As Universal Waste. There Were Two 55-Gallon Drums Of Waste Aerosol Cans Accumulating Inside The Building (Photo 3). The Drums Were In Good Condition, Were Properly Labeled, And Had Been Accumulating For Less Than One Year. Fluid Changes For Aotc Vehicle Are Performed On-Site, But Mr. Free Stated That Aotc Plans To Start Performing All Its Routine Maintenance Off-Site By A Third Party In The Near Future. At The Time Of The Inspection, There Was One 55-Gallon Drum Of Used Oil Accumulating In The Vehicle Wash Area (Photo 4). The Drum Was Closed But Was Not Properly Labeled “Used Oil” And Did Not Have Adequate Secondary Containment Because The Containment Could Not Contain 110% Of The Largest Container [40 Cfr 279.22(C)(1), 62-710.401(6), Florida Administrative Code (Fac)].
Hazardous Waste And Pcw Transporter Operations
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Mr. Free Stated That Aotc Typically Operates As The Emergency Response Cleanup Contractor, And A Broker Arranges For The Transportation And Waste Disposal Activities So Aotc Is Not Transporting Hazardous Waste Generated During Emergency Response Operations. If Hazardous Waste Will Be Generated During Spill Response Activities, Aotc Cleans-Up The Spilled Debris, Containerizes The Waste, And Leaves The Containers At The Customer And/Or Spill Location. At The Time Of The Inspection, No Hazardous Waste Was Stored In The Open Waste Transfer Area Building. There Were Two 250-Gallon Totes Labeled Non-Hazardous Waste, Four 85-Gallon Overpack Drums, Approximately 40-50 Metal And Poly 55-Gallon Drums Labeled Non-Hazardous Waste, Five 5-Gallon Buckets Labeled Non-Hazardous Waste, And Several Empty Drums. Although The Drums Had Non-Hazardous Waste Labels On The Containers, Many Of The Drums Were Oriented So The Labels Could Not Be Read Without Moving The Drum, And Many Of The Labels Were Not Legible Becau |
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