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08/07/2024 |
Site Inspection |
Routine; Used Oil Transporter Ntec Was Inspected As A Florida Universal Pharmaceutical Waste Transporter (Upw), For Hire Transporter For Universal Waste Mercury-Containing Lamps/Devices, Petroleum Contact Water (Pcw) Transporter, Commercial Hazardous Waste Transporter (Tra), Used Oil Transporter (Uot), And Used Oil Filter Transporter (Uoft) And Found To Be Out Of Compliance For Maintaining Used Oil Acceptance Logs With Required Information [40 Cfr 279.56(A)] And Exceeding 24-Hour Storage Time Limit [40 Cfr 263.12(A), Rule 62-730.171(2)(A) F.A.C.].
An Exit Interview Was Sent Out On 08/13/2024 And Was Provided A Deadline Of 08/27/2024. On 08/14/2024, 08/20/2024, And 08/21/2024 The Facility Submitted Documentation Of Corrective Actions And Incorporation Of Guidance For Once The Facility Begins Operations As A Universal Waste, Hazardous Waste Transporter, And Transfer Facility For Used Oil. All Corrective Actions Have Been Made And The Facility Will Receive A Return To Compliance Letter.
| Ntec Is An Emergency Response Clean-Up Transporter. The Facility Receives Calls About Clean-Up Sites From Emergencies, Collects The Waste On-Site, And Either Stores On-Site Overnight Or Brings Directly To A Tsd. The Facility Picks Up Any Waste On Site That Is Either Hazardous, Universal, Used Oil, Or Used Oil Filters. Ntec Maintains One Truck And 2 Stationary Shipping Containers On Facility Site For Over Night Storage. The Truck Has Maintenance Done Through A Third Party. The Facility Transports Waste Generated From Third Party Customers And Does Not Generate Any Waste On-Site Or Through Their Operations.
The Following Areas Were Observed During The Inspection:
Warehouse:
Located In The Back Of The Facility. The Warehouse Is Occasionally Rented Out, But When It Isn’T The Facility Uses It As A Storage Space For Spill Control Material And New Drums That Come In. At The Time Of The Inspection The Warehouse Was Empty. Available Records Were Reviewed In This Area.
Stationary Shipping Containers:
Located To The Right Of The Warehouse. The Shipping Containers Are Temperature Controlled And The Floors Are Lined With Wooden Platforms. The Representative Informed Inspectors That They Have Only Done One Pickup Of Used Oil And Stored In In The Shipping Containers Overnight. Representative Informed Inspectors It May Be Used For Any Of The Hazardous Waste. Universal Waste Or Used Oil They Pick Up If Late At Night. At The Time Of The Inspection No Waste Was Observed In This Area. Fire Extinguisher And Spill Control Material Was Observed In The Shipping Containers.
The Shipping Containers Are Kept Closed; However, Inspectors Did Not Observe A Secondary Containment Within To Prevent A Release If The Doors Were To Be Opened. Compliance Assistance Was Provided On-Site And In The Exit Interview As A Suggestion For Best Management Practice To Place A Secondary Containment Inside The Shipping Containers Near The Doors Such As Dikes, Berms, Or Retaining Wall To Prevent A Release If The Doors Are Opened.
Records Review:
Manifests:
At The Time Of The Inspection The Facility Had Only Made One Acceptance And Delivery Of Used Oil. The Facility Transports Waste From Cleanup Sites And Are Not Provided A Manifest Form (Epa Form 8700-22, And If Necessary, Epa Form 8700-22a) Signed By The Generator And Transporter With Date Of Pickup, Transfer To Other Transporter, Or Designated Facility [40 Cfr 263.22(A)]. The Representative Created Their Own Used Oil Acceptance/Delivery Form And Provided It To Inspectors At The Time Of The Inspection. Additionally, Inspectors Observed That The Facility Does Maintain Digital Delivery Records From Their Transporter Safety Kleen. The Acceptance Record Had The Following:
- Title: “Oil Waste Pick Up Log”
- Date: 04/30/224
- Quantity: 3, 55-Gal Barrels
- Company: Safety Kleen
The Representative Informed Inspectors The Waste Was Picked Up On 04/28/2024 And Stored On-Site Until Safety Kleen Picked It Up. Based On The Manifest Records, The Facility Operates As A Transpor |
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