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03/24/2022 |
Site Inspection |
File Review; Hazardous Waste Transporter Safety-Kleen Systems, Inc. (Sk-Denton), Located At 1722 Cooper Creek Road In Denton, Texas Is A Registered Transporter Of Hazardous Waste With The Florida Department Of Environmental Protection (Dep Or Department). Sk-Denton Is Registered To Transport Their Own Waste And Commercial Waste Over Highways In Florida.
This Inspection Report Serves As A File Review Conducted By The Department To Address An Unmanifested Waste Report Submitted By Safety-Kleen Systems, Inc. (Sk-Tallahassee) In Which Sk-Denton Is Identified As The Hazardous Waste Transporter.
| On February 22, 2022, Sk-Tallahassee Submitted, To The Department, An Unmanifested Waste Report. This Report Stated Sk-Tallahassee Accepted Hazardous Waste From A Large Quantity Generator On Eleven Occasions From January 1, 2019 Through February 15, 2022 Without A Manifest. The Waste Was Described As Spent Parts Washer Solvent With The Transactions Completed On Shipping Documents That Include The Proper Waste Description And Waste Codes; Copies Of These Documents Were Included. The Shipments Occurred On: February 15, 2022, September 15, 2021, June 25, 2021, January 6, 2021, October 2, 2020, July 13, 2020, April 16, 2020, February 25, 2020, November 12, 2019, July 16, 2019, And April 24, 2019 And Indicated Each Time Twelve Gallons Of Waste Combustible Liquid (Petroleum Naphtha) With Federal Waste Code D039 Was Removed. The Identified Generator Of The Hazardous Waste Was Corteva Agriscience Llc (Gad000813691) Located At 2509 Rocky Ford Rd. In Valdosta, Georgia (31601) And The Identified Hazardous Waste Transporter Was Saftey-Kleen Systems, Inc. (Sk-Denton) (Txr000081205) Located At 1722 Copper Creek Plaza In Denton, Texas (76207).
In An Email Dated March 1, 2022, Mr. Jeff Curtis (Safety-Kleen Systems, Inc.) Provided Additional Information Clarifying How The Incident Occurred. Mr. Curtis Explained The Generator’S Account Was Set-Up Initially Identifying Them As A Very Small Quantity Generator. Recently, The Safety-Kleen Account Manager Visited The Generator Facility To Discuss Additional Lines Of Business; During This Visit The Generator Mentioned Generating Other Hazardous Waste Streams And Operating As A Large Quantity Generator. The Safety-Kleen Account Manager Reported The System Discrepancy And Lack Of Hazardous Waste Manifests Immediately To Mr. Curtis.
On March 24, 2022, Mr. Curtis Explained The Transporter Id Is The Safety-Kleen National Transporter Id Utilized By All Safety-Kleen Facilities To Transport Waste. This Waste Was Transported By A Sk-Tallahassee Route Driver.
Per Sk-Tallahassee’S Current Operating Permit (009207-011-Ho) In Part Ii Subpart A: (2.) The Permittee Shall Comply With The Manifest Requirements Of 40 Cfr 264.71 And 264.72. The Permittee Must Document The Reconciliation Of Any Manifest Discrepancies; And (4.)(A)(1) The Permittee Shall Submit An Unmanifested Waste Report To The Department Within 15 Days Of Receipt Of Unmanifested Waste. The Unmanifested Waste Report Was Not Submitted Within 15 Days Of Receipt Of The Waste Except For The February 15, 2022 Waste. Per Section 403.727(1)(C), Fs It Is Unlawful For Any Hazardous Waste Generator, Transporter, Or Facility Owner Or Operator To: Fail To Comply With A Permit.
Per 40 Cfr 263.20(A)(1), ‘A Transporter May Not Accept Hazardous Waste From A Generator Unless The Transporter Is Also Provided With A Manifest Form…’.
On March 28, 2022, Via A Microsoft Teams Meeting, Dep Personnel: Monica Hardin And Cliff Richardson Discussed With Mr. Curtis And Mr. Youngman The Unmanifested Waste Report And The Process Moving Forward To Resolve The Identified Issues. We Discussed The Expectation Of The Corrective Action Outlined In The Compliance Assistance Offer (Cao) And Inspection Reports To Prevent Future Occurrences Of Incorrect Generator Statuses In Their System Along With An Audit To Ensure Current Customers Are Identified In Their System With The Correct Generator Status.
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06/24/2022 |
Site Inspection |
File Review; Hazardous Waste Transporter Safety-Kleen Systems, Inc. (Sk-Denton), Located At 1722 Cooper Creek Road In Denton, Texas Is A Registered Transporter Of Hazardous Waste With The Florida Department Of Environmental Protection (Dep Or Department). Sk-Denton Is Registered To Transport Their Own Waste And Commercial Waste Over Highways In Florida.
This Follow-Up Inspection Report Serves As A File Review Conducted By The Florida Department Of Environmental Protection (Dep Or Department) To Address The Potential Violation Cited In The March 24, 2022 File Review Inspection Report Related To The Transport Of Unmanifested Hazardous Waste. The Department Issued A Compliance Assistance Offer (Cao) To Sk-Denton On April 4, 2022; Responses To The Cao Were Received On April 15 And June 14, 2022.
| 40 Cfr 263.20(A)(1)
On Eleven Occasions, February 15, 2022, September 15, 2021, June 25, 2021, January 6, 2021, October 2, 2020, July 13, 2020, April 16, 2020, February 25, 2020, November 12, 2019, July 16, 2019, And April 24, 2019, The Transporter Removed Hazardous Waste From A Large Quantity Generator Under The Presumption The Generator Was A Very Small Quantity Generator (Exempt From Manifest Requirements Per 40 Cfr 262.14(A)).
At The Request Of The Department, Safety-Kleen Systems, Inc. Conducted An Internal Audit Of Their Customer Database To Verify Generator Statuses In Their Account Management System. This Audit Allowed Safety-Kleen Systems, Inc. To Identify Additional Generators/Circumstances Where Hazardous Waste May Have Been Shipped Without Being Manifested. Safety-Kleen Systems, Inc. Has Updated The Generator Statuses Of Their Customers As Appropriate To Ensure Hazardous Waste Is Manifested When Required. Customers Are Also Required To Confirm And Certify Their Generator Status Each Time A Driver Visits A Facility; Sk-Denton Intends To Continue This Practice.
| At The Close Of This File Review, It Appears Sk-Denton (And Sk-Tallahassee) Has Returned To Compliance With The Applicable State And Federal Hazardous Wastes Regulations.
*Checklist Items Marked As N/A Were Not Reviewed During This File Review.
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