From: Kothur, Bheem

Sent: Tuesday, September 21, 2010 2:19 PM

To: 'Richard Dillen'; 'Tim Rudolph'

Cc: Dregne, James; Tripp, Anthony; Martin, Lee

Subject: Howco St. Petersburg, UO Permit application

Dear Dillen,

Please review the below comments and revise these attachments as appropriate and submit the responses ASAP, so that we can send a draft permit for your review and comment before we issue the Intent in timely manner.

We have founded these additional shortcomings in the Permit application:

ATTACHMENT 6, Para 3.0, page 16.

The application has a paragraph titled “Emergency Equipment Available”, but does not list the equipment.  The paragraph must list the type of emergency equipment available, the amount of each item, where it is located, and how often the emergency equipment is inspected. A record of the inspections must be maintained. There should also be a statement saying that equipment that is used will be cleaned and items consumed will be replaced after an emergency.

ATTACHMENT 7, page 23

The current permit application does not have any specifics on the information to be recorded as part of the container inspections, and doesn’t specify inspecting some things at all (e.g. the yard, solid waste processing area, storage areas, parking areas, etc).  The application should include the frequency of inspections and provide a copy of the inspection log/checklist.  

Application states that AST’s will be inspected in accordance with Rule 62-762.600.  This paragraph has been repealed.  Should be 62-762.601.

If you have any questions, please let me know.

Thanks.

That’s all

Bheem R. Kothur, P.E., DEE

Professional Engineer III

DWM/BS&HW/HW Regulation Section

Florida Department of Environmental Protection

MS# 4560, 2600 Blair Stone Road

Tallahassee, Florida 32399-2400

Tel: 850-245-8781, FAX: 850-245-8810

Email: Bheem.Kothur@dep.state.fl.us