From: Griffith, John
Sent: Thursday, April 22, 2004 10:16 AM
To: 'Garrity, Michael J'; 'bosekj@cleanharbours.com'
Cc: Knauss, Beth; Tam, Stanley; Outlaw, Douglas; Kothur, Bheem; Redig,
Michael; Ray, Steve; Clarke, Raoul; Price, John L.; Posner, Augusta
Subject: Deficiencies in the 2003 Biennial Hazardous Waste Report for
Clean Harbors Bartow

John Bosek
General Manager
Clean Harbors - Bartow Facility

I received your revised submission of the 2003 Biennial Hazardous Waste Report for Clean Harbors Bartow today. The re-submission consisted of one file out of five that needed to be revised and re-submitted. This level of non-compliance with my request for revised information indicate a serious problem in your waste tracking and reporting capabilities. This inaccurate reporting attempt received from Clean Harbors Bartow indicates a failure to create a satisfactory accounting of the hazardous waste passing through the Clean Harbors Bartow facility. As a permitted treatment storage and disposal site, Clean Harbors Bartow should have the ability to produce the required report in a satisfactory and timely manner. Adequate recordkeeping is a requirement of your permit and the rules of RCRA. 

Your original report shows that you took over ownership of the facility on 09/06/2004. I hope this lack of attention to detail is restricted to your paperwork submission practices and is not indicative of your waste handling practices.

Please submit a COMPLETELY REVISED report, with all errors corrected, within two weeks of the date of this letter. Failure to correctly report on your hazardous waste activities in a timely manner will be viewed by this Department as a Violation of your Permit requirements and may subject you to enforcement.  Please retain all manifests and related materials used in the preparation of this report in anticipation of a possible audit of your record keeping.

Training on the completion of the Biennial Hazardous Waste Report was offered in Tampa on Dec. 16, 2003 and Tallahassee on Dec. 10, 2003. No effort was made by your compliance staff to attend either session. You may find it helpful to use these Department software and training materials in completing the report. Please call me at the number below if I can assist in expediting your corrected submission. 

http://www.dep.state.fl.us/waste/categories/hazardous/pages/BRS_data.htm


Jack Griffith
Florida Department of Environmental Protection
MS 4555
2600 Blair Stone Road
Tallahassee FL, 32399-2400
850-245-8748