Florida Department of Environmental Protection

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1 Florida Department of Environmental Protection Central District 3319 Maguire Boulevard, Suite 232 Orlando, Florida Rick Scott Governor Carlos Lopez-Cantera Lt. Governor Jonathan P. Steverson Secretary September 28, In the matter of an Orange County - SW Application for Permit by: Triumvirate Environmental (Florida), Inc. Triumvirate Environmental, Inc. for 200 Inner Belt Road Treated Biomedical Waste & Recovered Plastics Somerville, MA WACS # Attention: Mr. John McQuillan, President & CEO DEP File No SO-IM This is the Department s Intent to Issue Permit No SO-IM. Enclosed is a Draft Permit for the project and file number noted above. If you have any questions or desire changes in the permit, contact Ms. Laxsamee Levin at or Laxsamee.levin@dep.state.fl.us. If we do not hear from you within 14 days, the Department will issue the permit. INTENT TO ISSUE The Department of Environmental Protection gives notice of its intent to issue a permit modification number SO-IM which replaces Permit No.: SO-31. This permit authorizes Triumvirate Environmental (Florida), Inc. Waste Processing Facility to add the processing of Treated Biomedical Waste & Recovered Plastics to its operations (copy of conditions attached) for the proposed project as detailed in the application specified above, for the reasons stated below. The applicant, Triumvirate Environmental, Inc. / John McQuillan, applied on June 16, 2015 to the Department of Environmental Protection, for a permit modification for Triumvirate Environmental (Florida), Inc. for Treated Biomedical Waste & Recovered Plastics in Orange County, Florida. The Department has permitting jurisdiction under Section (1), F.S. and Chapters 62-4, and , F.A.C. The project is not exempt from permitting procedures. The Department has determined that a permit is required. Executed in Orange County, Florida.

2 Mr. John McQuillan, President & CEO Triumvirate Environmental, Inc. Triumvirate Environmental (Florida), Inc. WACS ID # September 28, 2015 STATE OF FLORIDA DEPARTMENT OF ENVIRONMENTAL PROTECTION F. Thomas Lubozynski, P.E. For Jeff Prather, District Director Central District Florida Department of Environmental Protection FILING AND ACKNOWLEDGMENT FILED, September 28, 2015 pursuant to Section , F. S., with the designated Department Clerk, receipt of which is hereby acknowledged. Clerk September 28, 2015 Date CERTIFICATE OF SERVICE The undersigned duly designated deputy agency clerk hereby certifies that this NOTICE OF PERMIT and all copies were sent before the close of business on September 28, 2015 to the listed persons. Clerk TL/ll Enclosure: Draft Permit No SO-IM Copies furnished to: Samuel P. Vitello Triumvirate, svitello@triumvirate.com Victor L. San Agustin, P.E. FECC, vsanagustin@feccorporation.com Richard Tedder, P.E. DEP Tallahassee, Richard.Tedder@dep.state.fl.us Susan F. Eldredge DEP Tallahassee, Susan.F.Eldredge@dep.state.fl.us Robert Cook DEP Tallahassee, Robert.Cook@dep.state.fl.us John White DEP Central District, John.White@dep.state.fl.us Nathan Hess DEP Central District, Nathan.Hess@dep.state.fl.us Gloria DePradine DEP Central District, Gloriajean.depradine@dep.state.fl.us Gina Vallone-Hood DOH Tallahassee, Gina.Vallone@flhealth.gov Ivonne Rodriguez DOH Orange County, Ivonne.Rodriguez@flhealth.gov

3 Florida Department of Environmental Protection Central District 3319 Maguire Boulevard, Suite 232 Orlando, Florida Rick Scott Governor Carlos Lopez-Cantera Lt. Governor Jonathan P. Steverson Secretary Permit Issued to: Mr. John McQuillan, President & CEO Triumvirate Environmental, Inc. 200 Inner Belt Road Somerville, MA (617) Facility WACS ID No.: Facility Name: Triumvirate Environmental (Florida), Inc. Facility Address: Rocket Boulevard, Orlando Orange County, Florida Contact Person: Samuel P. Vitello 200 Inner Belt Road Somerville, MA (516) Solid Waste Permit Permit Modification No.: SO-IM Replaces Permit No.: SO-31 Permit Issued: 09/xx/2015 Permit Renewal Application Due Date: 10/04/2018 Permit Expires: 12/04/2018 Permitting Authority Florida Department of Environmental Protection Central District Office 3319 Maguire Boulevard, Suite 232 Orlando, Florida (407)

4 PERMITTEE NAME: Triumvirate Environmental, Inc. PERMIT NO.: SO-IM FACILITY NAME: Triumvirate Environmental (Florida), Inc. WACS Facility ID.: SECTION 1 - SUMMARY INFORMATION A. Authorization The permittee is hereby authorized to operate a solid waste processing facility in accordance with the specific and general conditions of this permit and any documents attached to this permit or specifically referenced in this permit and made a part of this permit. This solid waste operation permit is issued under the provisions of Chapter 403, Florida Statutes, and Florida Administrative Code Chapters 62-4 and This permit does not relieve the permittee from complying with any other appropriate local zoning or land use ordinances or with any other laws, rules or ordinances. Receipt of any permit from the Department does not relieve the applicant from obtaining other federal, state, and local permits and/or modifications required by law, including those from other sections within the Department of Environmental Protection (DEP) or of the Water Management District. B. Facility Location Triumvirate Environmental (Florida), Inc. is located at Rocket Boulevard, Orlando, in Section 11, Township 24 South, Range 29 East, in Orange County, Florida (Latitude 28 o and Longitude 81 o ). C. Facility Description Triumvirate Environmental (Florida), Inc. consists of two (2) buildings, #1 and #2. Building 1 Operation of a hazardous waste container storage and treatment units. The operation is regulated in accordance with Chapter , Florida Administrative Code (F.A.C.) by the Florida Department of Environmental Protection (DEP). The current permit is HO-008. References to hazardous waste within this solid waste permit is for hazardous waste outside of the scope of that which is authorized under the hazardous waste permit. Operation of the solid waste processing facility including transfer operations and volume reduction operations that do not involve hazardous waste. Page 2 of 7

5 PERMITTEE NAME: Triumvirate Environmental, Inc. PERMIT NO.: SO-IM FACILITY NAME: Triumvirate Environmental (Florida), Inc. WACS Facility ID.: Building 2 (To be constructed) Operation of the solid waste processing facility including transfer operations and volume reduction operations that do not involve hazardous waste or treated biomedical waste. Treatment of biomedical waste generated at health care, higher educational, and/or life science organizations. Treatment of biomedical waste is regulated in accordance with Chapter 64E-16, F.A.C., Biomedical Waste, by the Florida Department of Health (DOH). References to biomedical waste within this solid waste permit is for biomedical waste outside of the scope of that which is authorized under the biomedical waste permit. Solid waste processing facility, that is, processing of treated biomedical waste. The facility is regulated in accordance with Rule , F.A.C., Solid Waste Processing Facilities by the DEP. is permitted for the following operations. Acceptance, storage, and processing of treated biomedical waste (only in accordance with a variance granted by DEP Solid Waste Section, Division of Waste Management). (The acceptance, storage, and processing of un-treated biomedical waste is regulated by the DOH.) The majority of treated biomedical waste (by weight) is plastic. Other treated biomedical waste materials are metal (for example, scissors, and needles), glass, rubber, and fabric. o At this time, acceptance, storage, and processing treated biomedical waste is not authorized because a variance has not yet been granted by DEP Solid Waste Section, Division of Waste Management. When the variance is issued, the DEP Central District will issue a permit modification incorporating the requirements of the variance. o The is limited to accepting treated biomedical waste that was produced at the facility. It is not permitted to accept treated biomedical waste that has been treated elsewhere. Acceptance of recovered plastics. Triumvirate Environmental (Florida), Inc., must maintain its certification as a Recovered Materials Dealer by DEP Waste Reduction Section, Division of Waste Management. Operation of the solid waste processing facility including transfer operations and volume reduction operations that do not involve treated biomedical waste. Processing may involve consolidation and solidification of non-hazardous industrial solid waste for offsite disposal or recycling. The solid waste will be received in solid, liquid, or semi-liquid forms. Non-hazardous, non-biomedical wastes are received, sorted, processed, stored, and shipped off for disposal or recycling. Storage is for no longer than six (6) months. The waste may be in tanker trucks, drums, totes, dump trailers, roll-off containers, and storage tanks. Page 3 of 7

6 PERMITTEE NAME: Triumvirate Environmental, Inc. PERMIT NO.: SO-IM FACILITY NAME: Triumvirate Environmental (Florida), Inc. WACS Facility ID.: D. Appendices Made Part of This Permit APPENDI 1 - General Conditions APPENDI 2 List of Documents Incorporated into this Permit APPENDI 3 Site Plan E. Attachments for Informational Purposes Only [None] SECTION 2 - SPECIFIC CONDITIONS A. Administrative Requirements 1. Documents Part of This Permit. The permit application as finally revised, replaced or amended in response to the Department's Request(s) for Additional Information are contained in the Department's files and are made a part of this permit. Those documents that make up the complete permit application are listed in APPENDI Permit Modification. Any change to construction, operation or monitoring requirements of this permit may require a modification to this permit, in accordance with the provisions of Rule (4), F.A.C. 3. Permit Renewal. In order to ensure uninterrupted operation of this facility, a timely and sufficient permit renewal application must be submitted to the Department in accordance with Rule (10), F.A.C. A permit application submitted at least 61 days prior to the expiration of this permit is considered timely and sufficient. 4. Transfer of Permit or Name Change. In accordance with Rule (11), F.A.C., the Department must be notified in writing within 30 days: (1) of any sale or conveyance of the facility; (2) if a new or different person takes ownership or control of the facility; or (3) if the facility name is changed. B. Construction Requirements [N/A] C. Operation Requirements 1. General Operating Requirements. The Permittee shall operate the facility in accordance with the approved Operation Plan (provided as Attachment A reference 6 of Appendix 2). The Department shall be notified before any changes, other than minor deviations, to the approved Operation Plan are implemented in order to determine whether a permit modification is required. Authorized Waste and Material Types. The facility is authorized to manage the following non-hazardous solid wastes: a) Used Oil/Oily water as defined in Rule , F.A.C. Page 4 of 7

7 PERMITTEE NAME: Triumvirate Environmental, Inc. PERMIT NO.: SO-IM FACILITY NAME: Triumvirate Environmental (Florida), Inc. WACS Facility ID.: b) Anti-freeze c) Latex Paint d) Waste Water e) Industrial Solids f) Used Oil Filters g) Asbestos h) Empty Drums i) Consumer Products j) Alkaline Batteries k) Recovered Plastic l) Treated Biomedical Waste (not authorized until a variance is granted by DEP) m) Untreated Biomedical Waste if authorized by DOH. 2. Unauthorized Waste Types. The facility is not authorized to accept or manage any waste types not listed in C.2. above. Any unauthorized waste inadvertently received by the facility shall be managed in accordance with the approved Operation Plan. Maximum Storage Quantities. The maximum individual waste storage quantities are as follows: a) Used Oil/Oily water 25,000 gal b) Anti-freeze 5,000 gal c) Latex Paint 5,000 gal d) Waste Water 5,000 gal e) Industrial Solids 40 Tons f) Used Oil Filters 40 Tons g) Asbestos 20 Tons h) Empty Drums 20 Tons i) Consumer Products 20 Tons j) Alkaline Batteries 3 Tons k) Recovered Plastic 1,000,000 Pounds l) Treated Biomedical Waste 400,000 Pounds 3. The permittee shall not accept, store, or process treated biomedical waste at the facility until a variance is granted by DEP Solid Waste Section, Division of Waste Management. Once a variance is obtained, the DEP Central District will issue a permit modification. 4. If a solid waste variance to accept, store, or process treated biomedical waste is not granted, all treated biomedical waste shall be handled and disposed as required by Rule (5)(d), F.A.C. 5. Facility Capacity. If the facility has reached its permitted capacity for storage of solid wastes or recyclable materials, the permittee shall not accept additional waste for processing until sufficient capacity has been restored. Page 5 of 7

8 PERMITTEE NAME: Triumvirate Environmental, Inc. PERMIT NO.: SO-IM FACILITY NAME: Triumvirate Environmental (Florida), Inc. WACS Facility ID.: Contingency Plan and Notification of Emergencies. The Permittee shall notify the Department in accordance with the approved Contingency Plan. Notification shall be made to the Solid Waste Section of DEP s Central District Office at (407) Housekeeping. The facility shall be operated to control dust, vectors, litter, and objectionable odors. 8. Putrescible Wastes. Putrescible waste shall be removed for disposal within 7 days. The approved Operations Plan (Attachment A to Reference 6 in Appendix 2) states that putrescible waste shall be kept in closed containers. Bleach may be added to the waste to eliminate bacteria and odors. 9. Hazardous Waste. If any regulated hazardous wastes, which were not authorized by the facility s hazardous waste permit, are discovered to be deposited at the facility, the facility operator shall promptly notify the Department, the person responsible for shipping the wastes to the facility, and the generator of the wastes, if known. The area where the wastes are deposited shall immediately be cordoned off from public access. If the generator or hauler cannot be identified, the facility operator shall assure the cleanup, transportation, and disposal of the waste at a permitted hazardous waste management facility. In the event that hazardous wastes are discovered they shall be managed in accordance with the procedures provided in facility Operation Plan. 10. Leachate Control System. The approved Operations Plan (Attachment A to Reference 6 in Appendix 2) describes how liquid waste and leachate will be controlled. Therefore, no leachate collection system or groundwater monitoring plan is required. The DEP Central District hereby approves an alternate procedure per Rule (9), F.A.C., based upon the facility information provided in reference 6 of Appendix 2. D. Water Quality Monitoring Requirements [There are no water quality monitoring requirements for this facility.] E. Gas Management System Requirements [There are no gas management requirements for this facility.] F. Closure Requirements 1. General Closure Requirements. The Permittee shall close the waste processing facility in accordance with the provisions of the approved Closure Plan (Attachment D in Reference 6 of Appendix 2). The Department shall be notified before any changes, other than minor deviations, to the approved Closure Plan are implemented in order to determine whether a permit modification is required. 2. Notifications. The Permittee shall notify the Department prior to ceasing operations, and shall submit a written certification to the Department when closure is complete. Page 6 of 7

9 PERMITTEE NAME: Triumvirate Environmental, Inc. PERMIT NO.: SO-IM FACILITY NAME: Triumvirate Environmental (Florida), Inc. WACS Facility ID.: Decontamination. After the removal of all waste material, the container storage area shall be decontaminated in accordance with the approved Closure Plan. G. Financial Assurance and Cost Estimates 1. Financial Assurance Mechanism. The permittee shall maintain, in good standing, the financial assurance mechanisms established to demonstrate proof of financial assurance. Support documentation and evidence of inflation adjustment increases shall be submitted within the time frames specified in Rule , F.A.C. All submittals in response to this specific condition shall be sent to: Florida Department of Environmental Protection Financial Coordinator - Solid Waste Section Solid.Waste.Financial.Coordinator@dep.state.fl.us 2. Cost Estimates. a. The permittee shall submit closure cost estimates, including annual adjustments for inflation, in accordance with the requirements of Rule (3) and (4), F.A.C., and 40 CFR Part (a) and.144(a) using Form (28). b. An owner or operator using a letter of credit, guarantee bond, performance bond, financial test, corporate guarantee, trust fund or insurance shall submit the inflation adjusted cost estimate(s) between January 1 and March 1. All submittals in response to this specific condition shall be sent to the Central District Office (DEP_CD@dep.state.fl.us ) and a copy to Solid.Waste.Financial.Coordinator@dep.state.fl.us Executed in Orange County, Florida. STATE OF FLORIDA DEPARTMENT OF ENVIRONMENTAL PROTECTION F. Thomas Lubozynski, P.E., for Jeff Prather Director, Central District FILED, on this date, pursuant to Section , F.S. with the designated Department Clerk, receipt of which is hereby acknowledged. Clerk Date Page 7 of 7

10 APPENDI 1 General Conditions 1. The terms, conditions, requirements, limitations and restrictions set forth in this permit, are "permit conditions" and are binding and enforceable pursuant to Sections , , , or , Florida Statutes. The Permittee is placed on notice that the Department will review this permit periodically and may initiate enforcement action for any violation of these conditions. 2. This permit is valid only for the specific processes and operations applied for and indicated in the approved drawings or exhibits. Any unauthorized deviation from the approved drawings, exhibits, specifications, or conditions of this permit may constitute grounds for revocation and enforcement action by the Department. 3. As provided in subsections (6) and (5), F.S., the issuance of this permit does not convey any vested rights or any exclusive privileges. Neither does it authorize any injury to public or private property or any invasion of rights, nor any infringement of federal, State, or local laws or regulations. This permit is not a waiver of or approval of any other Department permit that may be required for other aspects of the total project which are not addressed in this permit. 4. This permit conveys no title to land or water, does not constitute State recognition or acknowledgment of title, and does not constitute authority for the use of submerged lands unless herein provided and the necessary title or leasehold interests have been obtained from the State. Only the Trustees of the Internal Improvement Trust Fund may express State opinion as to title. 5. This permit does not relieve the Permittee from liability for harm or injury to human health or welfare, animal, or plant life, or property caused by the construction or operation of this permitted source, or from penalties therefore; nor does it allow the Permittee to cause pollution in contravention of Florida Statutes and Department rules, unless specifically authorized by an order from the Department. 6. The Permittee shall properly operate and maintain the facility and systems of treatment and control (and related appurtenances) that are installed and used by the Permittee to achieve compliance with the conditions of this permit, are required by Department rules. This provision includes the operation of backup or auxiliary facilities or similar systems when necessary to achieve compliance with the conditions of the permit and when required by Department rules. 7. The Permittee, by accepting this permit, specifically agrees to allow authorized Department personnel, upon presentation of credentials or other documents as may be required by law and at reasonable times, access to the premises where the permitted activity is located or conducted to: (a) Have access to and copy any records that must be kept under conditions of the permit; (b) Inspect the facility, equipment, practices, or operations regulated or required under this permit; and (c) Sample or monitor any substances or parameters at any location reasonably necessary to assure compliance with this permit or Department rules. Reasonable time may depend on the nature of the concern being investigated.

11 General Conditions Page 2 of 2 8. If, for any reason, the Permittee does not comply with or will be unable to comply with any condition or limitation specified in this permit, the Permittee shall immediately provide the Department with the following information: (a) A description of and cause of noncompliance; and (b) The period of noncompliance, including dates and times; or, if not corrected, the anticipated time the noncompliance is expected to continue, and steps being taken to reduce, eliminate, and prevent recurrence of the noncompliance. The Permittee shall be responsible for any and all damages which may result and may be subject to enforcement action by the Department for penalties or for revocation of this permit. 9. In accepting this permit, the Permittee understands and agrees that all records, notes, monitoring data and other information relating to the construction or operation of this permitted source which are submitted to the Department may be used by the Department as evidence in any enforcement case involving the permitted source arising under the Florida Statutes or Department rules, except where such use is prescribed by Sections and , F.S. Such evidence shall only be used to the extent it is consistent with the Florida Rules of Civil Procedure and appropriate evidentiary rules. 10. The Permittee agrees to comply with changes in Department rules and Florida Statues after a reasonable time for compliance; provided, however, the Permittee does not waive any other rights granted by Florida Statutes or Department rules. 11. This permit or a copy thereof shall be kept at the work site of the permitted activity. 12. The Permittee shall comply with the following: (a) Upon request, the Permittee shall furnish all records and plans required under Department rules. During enforcement actions, the retention period for all records will be extended automatically unless otherwise stipulated by the Department. (b) The Permittee shall hold at the facility or other location designated by this permit records of all monitoring information (including all calibration and maintenance records and all original strip chart recordings for continuous monitoring instrumentation) required by the permit, copies of all reports required by this permit, and records of all data used to complete the application for this permit. These materials shall be retained at least three years from the date of the sample, measurement, report, or application unless otherwise specified by Department rule. (c) Records of monitoring information shall include: 1. the date, exact place, and time of sampling or measurements; 2. the person responsible for performing the sampling or measurements; 3. the dates analyses were performed; 4. the person responsible for performing the analyses; 5. the analytical techniques or methods used; 6. the results of such analyses. 13. When requested by the Department, the Permittee shall within a reasonable time furnish any information required by law which is needed to determine compliance with the permit. If the Permittee becomes aware the relevant facts were not submitted or were incorrect in the permit application or in any report to the Department, such facts or information shall be corrected promptly.

12 APPENDI 2 List of Documents Incorporated into this Permit List of Documents Associated with Permit SO Application to Construct, Operate or Modify a Waste Processing Facility, dated November 5, Received via November 7, 2013, DEP Central District. 2. Permit Application Complete Letter from DEP Central District dated November 25, Drawing depicting 200 foot setback, received via December 2, 2013, DEP Central District. List of Documents Associated with Permit SC/SO-IM 4. Triumvirate Environmental (Florida), Inc. s Intermediate Modification Application to the Solid Waste Permit SO-31, Triumvirate Environmental (Florida), Inc., Solid Waste Processing Facility, Rocket Boulevard, Orlando, Orange County, Florida and Prepared by: Victoriano L. San Agustin, Jr., P.E. of FECC, Inc., dated June 9, Received and stamped June 16, 2015, DEP Central District. 5. First Request for Additional Information (RAI) dated July 2, Response to RAI dated August 23, 2015 and received August 24, Permit Application Complete Letter from Central District DEP dated September 3, Correspondence and documentation proving that treated biomedical waste is not a characteristic hazardous waste. Received February 6, 2015, DEP Central District.

13 Attachment B - Site Map PROPOSED DEDICATED GREEN SPACE (TYP.) PROPOSED PARKING STALL (9' 18') (TYP.) PROPOSED 4' WIDE CONCRETE SIDEWALK (TYP.) PROPOSED PARKING LOT SCALE IN FEET project no. scale date 60 1" = 30' 06/20/2014 S SK TMA KAN TMR 0 SK graphic scale drawn checked EISTING FENCE designed LEGEND NOTE: LEGEND IS TYPICAL, NOT ALL OBJECTS IN LEGEND APPEAR IN PLAN. EISTING GATE EISTING STRUCTURE EISTING SEDIMENT BASIN EISTING DRIVEWAY ETENTS BUILDING 2 PROPOSED PAVED ROAD PROPOSED CONCRETE WALK PROPOSED SECURITY FENCE WITH BARBED WIRE PROPOSED WASTE STORAGE AREA PROPOSED REGULATED BIOMEDICAL WASTE TREATMENT FACILITY PROPOSED TYPICAL ADA PARKING STALL (9' 18') & 5' WIDE ACCESSIBLE AREA BUILDING 1 SK PROPOSED SPILL CONTROL STATION PROPOSED FIRE ETINGUISHER LOCATION PROPOSED VAN ACCESSIBLE PARKING STALL (9' 18') & 8' WIDE ACCESSIBLE AREA PROPOSED EMERGENCY SHOWER LOCATION PROPOSED EYE WASH STATION NO SMOKING SIGN SK S STOP SIGN V VISITOR CHECK IN SIGN Y EISTING FIRE HYDRANT EMERGENCY & PERSONNEL SAFETY EQUIPMENT CABINET SITE AND EQUIPMENT LAYOUT BUILDING SETBACK LINE FIRE ALARM OPERATOR NOTE 1. AUTHORIZED PERSONNEL ONLY SIGNS WILL BE AFFIED TO THE ETERIOR OF THE SECURITY FENCE. This drawing, its contents, and each component of this drawing are the property of and proprietary to ARM Group Inc. and shall not be reproduced or used in any manner except for the purpose identified on the Title Block, and only by or on behalf of this client for the identified project unless otherwise authorized by the express, written consent of ARM Group Inc. project title Y V S 1 STRETCHER drawing title DANGER AUTHORIZED PERSONNEL ONLY SIGN (SEE NOTE 1) P:\Triumvirate Environmental\ Orlando Facility\Drwg\Production\Concept\ CP-C-007.dwg Plotted: July 28, 2015 ORLANDO ORANGE COUNTY, FL PROPERTY BOUNDARY (NOT A RESULT OF FIELD SURVEY) SK TRIUMVIRATE ENVIRONMENTAL (FLORIDA), INC. EISTING FLOODWAY

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