Florida Department of Environmental Protection

Hazardous Waste Facility Compliance History


Activity History Listing


Activity History for:

EPAID: FL0001000611, Hagan Holding Company dba Howco Environmental Services


Note: ETA links to Enforcement Tracking Activity
Date Done Activity Type Activity Comments ETA Link
05/24/1999 Compliance Evaluation Inspection Epa Oversight Inspection Epa Oversight Inspection
12/06/2000 Legacy Site Inspection See Violation Screen See Violation Screen
12/13/2000 Non-Compliance Letter Issued Response Due 12/29 Response Due 12/29
12/26/2000 File Review Response Indicating Violations/Aoc Will Be Addressed Within 60 Days. Response Indicating Violations/Aoc Will Be Addressed Within 60 Days.
02/21/2001 Letter Ltr. Asked For Information Not Received Ltr. Asked For Information Not Received
02/26/2001 Legacy Site Inspection
02/26/2001 File Review Rec'D Response From Howco Rec'D Response From Howco
02/26/2001 Meeting Meeting Requested By Dave Thompson Of Howco To Discuss Dep'S Ltr/Howco'S Response Meeting Requested By Dave Thompson Of Howco To Discuss Dep'S Ltr/Howco'S Response
02/28/2001 Non-Compliance Letter Issued
03/12/2001 Meeting Meeting Requested By Dave Thompson To Discuss Proposed Work For Storage Tanks/Response To Dep'S 2/28/01 Ltr Meeting Requested By Dave Thompson To Discuss Proposed Work For Storage Tanks/Response To Dep'S 2/28/01 Ltr
04/02/2001 File Review Ltr From Howco Proposing Work Schedule To Install Liner Inside Tanks Ltr From Howco Proposing Work Schedule To Install Liner Inside Tanks
04/24/2001 Compliance Schedule Evaluation
04/25/2001 Compliance Schedule Evaluation
04/26/2001 Compliance Schedule Evaluation
05/30/2001 Legacy Site Inspection Rec'D Tank Upgrade Report And Analytical Results. Sludge From Tank 3 Hw For Benzene And Tetrchloroethene. Rec'D Tank Upgrade Report And Analytical Results. Sludge From Tank 3 Hw For Benzene And Tetrchloroethene.
05/30/2001 Significant Non-Complier - Yes
05/30/2001 Enforcement Project Initiated
06/13/2001 File Review Rec'D Ltr From Howco Rec'D Ltr From Howco
07/17/2001 File Review Rec'D Fax From Howco Indicating Drums Will Be Managed As Used Oil Sludge - Non-Haz Rec'D Fax From Howco Indicating Drums Will Be Managed As Used Oil Sludge - Non-Haz
07/26/2001 File Review Ltr From Howco Ltr From Howco
07/27/2001 File Review Rec'D Btu Results Rec'D Btu Results
08/13/2001 Letter Ltr To Howco Ltr To Howco
09/13/2001 File Review Ltr From Howco Atty - Drums Are Used Oil Sludge Ltr From Howco Atty - Drums Are Used Oil Sludge
09/24/2001 Letter Ltr To Howco Atty Ltr To Howco Atty
09/27/2001 Letter Ltr To Howco Ltr To Howco
09/28/2001 Compliance Evaluation Inspection
10/11/2001 Legacy Site Inspection See Violation Screen See Violation Screen
10/25/2001 Warning Letter Issued Mtg Scheduled For 11/7/01 Mtg Scheduled For 11/7/01
11/02/2001 Interdepartmental Memo Memo To File Memo To File
11/05/2001 File Review Rec'D Fax Rec'D Fax
11/06/2001 Legacy Site Inspection See Violation Screen See Violation Screen
11/07/2001 Enforcement Meeting Proposed Draft Model Co For Clean-Up Proposed Draft Model Co For Clean-Up
11/13/2001 Letter Ltr To Howco Ltr To Howco
11/29/2001 File Review Rec'D Response To 11/6 Inspection Rec'D Response To 11/6 Inspection
12/03/2001 File Review Rec'D Response Ltr To 11/6 Inspection Rec'D Response Ltr To 11/6 Inspection
12/06/2001 Model Consent Order Issued Response Requested By 12/28/01 Response Requested By 12/28/01
12/14/2001 File Review Rec'D Assessment From Hsa For Temporary Drum Storage Area Rec'D Assessment From Hsa For Temporary Drum Storage Area
12/17/2001 File Review Rec'D Fax Ltr Rec'D Fax Ltr
12/20/2001 Technical Review Review Assessment Report Review Assessment Report
12/21/2001 Letter Comments Re Assessment Report. Response Requested By 1/15/02 Comments Re Assessment Report. Response Requested By 1/15/02
01/03/2002 File Review Rec'D Faxed Hw Disp Manifest Rec'D Faxed Hw Disp Manifest
01/17/2002 Letter Ltr Informing Howco Case Is Being Referred To Ogc Ltr Informing Howco Case Is Being Referred To Ogc
01/18/2002 File Review Rec'D Response Ltr To Dep Comment Ltr Re Assessment Rec'D Response Ltr To Dep Comment Ltr Re Assessment
02/04/2002 File Review Rec'D Ltr From Howco Re Proposed Co Rec'D Ltr From Howco Re Proposed Co
02/26/2002 Letter Ltr To Consultant Ltr To Consultant
06/19/2002 Case Referred To Epa Teleconference With Epa, Tally, Ogc, District. Teleconference With Epa, Tally, Ogc, District.
07/15/2002 File Review Ltr From Epa Confirming They Have Assumed Enforcement Lead Ltr From Epa Confirming They Have Assumed Enforcement Lead
09/23/2002 File Review Ltr From Epa Indicating Epa Plans To Issue A Complaint & Compliance Order To Howco Ltr From Epa Indicating Epa Plans To Issue A Complaint & Compliance Order To Howco
09/25/2002 Final Order Issued Consent Agreement And Final Order Issued By Epa To Howco Consent Agreement And Final Order Issued By Epa To Howco
09/25/2002 Significant Non-Complier - No
09/26/2002 File Review Cafo Executed. $4000 Paid. Case Closed By Epa Cafo Executed. $4000 Paid. Case Closed By Epa
10/05/2005 Legacy Site Inspection
10/06/2005 Telephone Conversation
10/06/2005 Submittal Received By Department Training Records Training Records
10/07/2005 Telephone Conversation
10/07/2005 Submittal Received By Department Certification And Registration Certification And Registration
10/13/2005 Non-Compliance Letter Issued
10/18/2005 Telephone Conversation Schedule Appt Schedule Appt
11/08/2005 Non-Compliance Letter Issued See Violation Screen See Violation Screen
11/23/2005 Submittal Received By Department Response To Ncli Response To Ncli
11/30/2005 Letter Further Info/Clarification Needed Further Info/Clarification Needed
12/12/2005 Submittal Received By Department Response Letter/Logs Response Letter/Logs
12/13/2005 Compliance W/O Formal Enforcement Action Return To Compliance Return To Compliance
12/14/2005 Project Closed Letter No Letter Sent No Letter Sent
12/14/2005 Case Closed By District
10/12/2011 Site Inspection Routine; Non-Handler - Routine; Used Oil Transporter - Routine; Used Oil Transfer Facility The Last Hazardous Waste Inspection The Department Of Environmental Protection (Department) Conducted At This Facility Was In October 2005. The Facility Has 1+ Local Employees, Is Associated With A Larger Facility In St. Petersburg, Fl, And Has Been At This Location Since Approximately 1991. The Property Is Owned By Bruce & Candace Ryan. The Facility Notified As A Used Oil And Used Oil Filter Transporter And Used Oil And Used Oil Filter Transfer Site. This Was Confirmed At The Time Of The Inspection. The Facility Generates Used Oil Absorbent/Debris. Used Oil, Used Oil Filters, Used Antifreeze, And Used Oil Absorbent/Pads/Soil Is Removed From Generators And Taken To This Site For Consolidation And Eventual Transport To The Main Facility In St. Petersburg, Fl (Epa Id No. Fld152764767). | We Arrived At The Site And Reviewed The Purpose Of The Inspection With Dave Thompson. Mr. Thompson Granted Access To The Facility And Escorted Us Throughout. All Transporter And Transfer Facility Records Are Stored At The Mailing Address In St. Petersburg. The Facility Operates As A Used Oil And Used Oil Filter Transporter And Transfer Facility. Used Oil, Used Oil Filters, Petroleum Contact Water, Used Antifreeze, And Used Oil Absorbent/Soil Are Removed From Individual Generators And Consolidated At This Location. At The End Of Each Day Used Oil, Petroleum Contact Water, And Used Antifreeze Are Pumped Into One Of Four Specified Tanks. Each Tank Is A Vertical Above-Ground, Single-Walled Tank That Is 20,000-Gallons In Capacity. Each Tank Is Labeled According To The Contents And Numbered 1-4. Tanks 1 & 2 Contain Used Oil, 3 Contains Petroleum Contact Water, And 4 Contains Used Antifreeze. The Tanks Are Measured In Gallons Per Inch With 1" Equaling 42-50 Gallons Depending On The Tank. Each Day The Tanks Are Measured Before And After Fluids Are Deposited. At The Time Of The Inspection, Tank 1 Contained 9'41/4" Tank 2 Contained 32'8" Tank 3 Contained 7'3/4" And Tank 4 Contained 13'81/4." The Secondary Containment Structure Did Not Appear To Be Sealed With An Oil-Impermeable Sealant. Upon Review Of The Lee County Tank Inspector'S Report For September 2011, The Facility Was Cited With A Potential Violation For Necessary Repairs, Including Resealing Of The Secondary Containment And Repair/Repainting Of One Of The Tanks That Was Beginning To Rust. The Secondary Containment Is Inside Of A Larger Containment Unit That Includes Tanks Operated By Ryan Petroleum. A Sump Connects To The Larger Containment Unit To Be Manually Controlled In The Event Rainwater Needs To Be Evacuated. There Were No Signs Of Discharges Around The Containment Structure And No Standing Water Was Observed. A Spill Kit Is Located In A Drum Outside Of The Used Oil Containment Structure. The Collection Truck Is Always Stored Empty And Is Parked On Broken Asphalt/Gravel. Inside The Passenger Side Compartment Of The Truck A 5-Gallon, Unlabeled Bucket Is Stored For Collection Of Used Oil Discharges That May Occur From The Pump. In Another Compartment On The Other Side Of The Truck, One Length Of Absorbent Boom Was Observed. There Were No Used Oil Spill Pads, Granulated Absorbent, Or Other Types Of Spill Control Equipment Observed In The Truck. The Insurance Documents Were Reviewed And Indicated The Insurance For Sufficient Amounts And Was Up To Date, Expiring On 7/2/12. Drums Of Used Oil Filters And Used Oil Absorbent/Soil Are Labeled According To Their Contents, Dated For The Pick-Up Date And Manifest And Stored In An Enclosed Tractor Trailer Onsite. The Drums Are Closed And Protected From The Weather, However, The Surface Of The Trailer Is Wooden And Is Not Oil-Impermeable. The Trailer Is Parked On A Broken Asphalt/Gravel Surface With Used Oil Discharges Beneath It. Mr. Thompson Indicated The Trailer Is Not Always Parked In The Same Place And The Staining On The Ground May Not Be Evident Of A Discharge From The Trailer. The Trailer
11/17/2011 Issue Non-Compliance Letter Finished-11/17/2011 ; Sent for Issue Non-Compliance Letter-11/17/2011
07/24/2012 Electronic Communication Finished-07/24/2012
08/09/2012 Site Inspection Follow-Up; Used Oil Transporter - Follow-Up; Used Oil Transfer Facility - Follow-Up; Used Oil Generator This Is A Follow-Up Inspection To The Hazardous Waste Compliance Evaluation Inspection Performed On 10/12/11. The Facility Was Determined To Be An Used Oil Transfer/Transporter Facility. The Facility Generates Used Oil Absorbent Material. Used Oil, Used Oil Filters, Used Antifreeze, Used Oil Absorbent Material Is Removed From Generators And Transported To Their Main Facility In St. Petersburg, Florida (Epa Id No. Fld152764767). | The Purpose Of The Inspection Was Reviewed With George Morgan, Petroleum Recovery Specialist. Mr. Morgan Granted Us Access To The Facility. The Facility Leases The Property From Bruce & Candace Ryan, Has Operated At This Location Since 1991, Utilizes 1 Employee And Is Connected To City Water And Sewer. The Primary Operation Of The Facility Is Collecting And Transporting Used Oil, Used Oil Filters, Petroleum Contact Water, Used Antifreeze, And Used Oil Absorbent Material. 40 Cfr 279.46(A) & (B) Used Oil Tracking. (A) Acceptance. Used Oil Transporters Must Keep A Record Of Each Used Oil Shipment Accepted For Transport. Records For Each Shipment Must Include: (1) The Name And Address Of The Generator, Transporter, Or Processor/Re-Refiner Who Provided The Used Oil For Transport; (2) The Epa Identification Number (If Applicable) Of The Generator, Transporter, Or Processor/Re-Refiner Who Provided The Used Oil For Transport; (3) The Quantity Of Used Oil Accepted; (4) The Date Of Acceptance; And (5)(I) Except As Provided In Paragraph (A)(5)(Ii) Of This Section, The Signature, Dated Upon Receipt Of The Used Oil, Of A Representative Of The Generator, Transporter, Or Processor/Re-Refiner Who Provided The Used Oil For Transport. (Ii) Intermediate Rail Transporters Are Not Required To Sign The Record Of Acceptance. (B) Deliveries. Used Oil Transporters Must Keep A Record Of Each Shipment Of Used Oil That Is Delivered To Another Used Oil Transporter, Or To A Used Oil Burner, Processor/Re-Refiner, Or Disposal Facility. Records Of Each Delivery Must Include: (1) The Name And Address Of The Receiving Facility Or Transporter; (2) The Epa Identification Number Of The Receiving Facility Or Transporter; (3)The Quantity Of Used Oil Delivered; (4) The Date Of Delivery; (5)(I) Except As Provided In Paragraph (A)(5)(Ii) Of This Section, The Signature, Dated Upon Receipt Of The Used Oil, Of A Representative Of The Generator, Transporter, Or Processor/Re-Refiner Who Provided The Used Oil For Transport. (Ii) Intermediate Rail Transporters Are Not Required To Sign The Record Of Acceptance. At The Time Of The 10/12/11 Inspection, The Records Provided By The Facility Did Not Meet The Requirements Listed Above. The Facility Has Recently Switched To An Electronic Handheld Printer To Print Manifests. The New System Does Not Indicate The Actual Receiving Facility But Instead Lists All 3 Of The Howco Environmental Services Locations. The Facility Notified The Department In The Response To The Pending Violation That They Are Working To Correct This And Were Instructed By The Department That The Following Information Should Be Clearly Indicated On The Receipts: Generator Id; Transporter Id; The Epa Identification Number Of The Receiving Facility Or Transporter As Well As The Name And Address Of The Receiving Facility Or Transporter; Amount Of Used Oil Delivered; Receipt Date; And Receiving Transporter'S Signature. The Original Inspection Citing The Violation Was Provided To Mr. Morgan During The Follow-Inspection As Well As Copies Of The Facility'S Corrective Actions And The Department'S Responses. F.A.C. Rule 62-710.850 Used Oil Filter Prohibition. The General Requirements For The Storage Of Used Oil Filters Is As Follows: All Persons Storing Used Oil Filters Shall Store Used Oil Filters In Above Ground Containers Which Are Clearly Labeled "Used Oil Filters," And Which Are In Good Condition (No Severe Rusting, Apparent Structural Defects Or Deterioration) With No Visible Oil Leakage. The Containers Shall Be S
08/10/2017 Site Inspection Routine; Used Oil Transporter - Routine; Used Oil Transfer Facility A Compliance Evaluation Was Conducted At Howco Environmental Services (Facility) On August 10, 2017. The Following Is A Summary Of My Observations. A File Review Reflects The Facility Is Currently Registered With Fdep As A Used Oil Transporter For Hire, Transfer Facility, Filter Transporter And Filter Transfer Facility. The Registration Expires On 6-30-18. The Facility Submitted A Certificate Of Liability Insurance Acord On 7-17-17 Which Was Issued On 6-28-17 And Expires On 6-28-18. The Storage Tank System (Facility Id 9300283) Was Last Inspected By Lee County Division Of Natural Resources On 9-29-15. According To The Storage Tank Registration, Howco Environmental Services Is The Owner/Operator Of Four Aboveground Steel Storage Tanks Installed Within Secondary Containment On 5-1-93. Storage Tank Registration Placard No. 497444, Issued 4-23-17/Expires 6-30-18 Reflects There Are Three Regulated Substance Containing Tank Systems. The Facility Was Last Inspected By Fdep Hazardous Waste On 8-9-12. According To Previous Inspection Reports, This Facility Has Been Operating At This Location Since 1991. The Property Is Owned By Bruce & Candace Ryan; And Howco Leases A Portion Of The Bulk Storage Area From Ryan Petroleum. All Records Associated With The Facility Are Maintained At Howco Environmental Services In St. Petersburg, Fl. Prior To The Inspection, Greg Bradley, Operations Manager, Was Contacted Regarding The Inspection. Mr. Bradley Granted Me Permission To Conduct The Inspection, Unescorted, And Agreed To Provide All Requested Documentation By E-Mail. Upon Arriving At The Facility, I Met With Mr. Ryan Of Ryan Petroleum And Reviewed The Purpose Of The Inspection With Him. It Was Discussed That Greg Bradley Was Aware Of The Inspection And Had Granted Me Permission To Conduct The Inspection. Mr. Ryan Concurred With Granting Me Access And Permission To Conduct The Inspection. Mr. Ryan Indicated That The Howco Tanks Are Situated On Two Layers Of Poured Concrete. A File Review Reflects Howco Provided Documentation On 2-22-01 Stating That The Area Beneath The Gravel Of Each Storage Tank Is Poured Concrete On Top Of Poured Concrete Related To The Larger Containment Area. Additional Documentation Reflects That The Tank Farm Concrete Surfaces Were Sealed And Rendered Impervious To Any Potential Releases And That An Interior Lining System Was Installed Inside The Base And Walls Of Each Tank In April/May 2001. Further Review Reflects Fdep Recommended Opening The Concrete Ring Surrounding Each Storage Tank To Prevent Rainwater From Accumulating Under The Tanks And Allowing Drainage Away From The Gravel/Tanks After Rain Events. | The Facility Primarily Operates As A Used Oil And Used Oil Filter Transporter And Transfer Facility. Used Oil, Used Oil Filters, Used Antifreeze And Oily Water Is Picked Up From Generators And Transported To This Site For Consolidation And Eventual Transport To The Howco Facility In St. Petersburg, Fl (Epa Id No. Fld152764767). According To Mr. Bradley, The Facility Maintains One Truck And One Driver For Pick-Ups. The Truck Has Three Compartments: 3,000-Gallons For Used Oil, 1,000-Gallons For Used Antifreeze, And 1,000 Gallons For Oily Water. The Truck Is Also Equipped To Transport Used Oil Filter Drums. According To Mr. Bradley, The Transporter Registration Form And Epa Identification Number Are Maintained In The Truck. It Was Indicated That The Facility Picks Up Approximately 12,000-15,000 Gallons Of Fluids Per Week. At The Time Of The Inspection, The Truck And Driver Were Not At The Facility. According To Mr. Bradley, The Truck Is Off-Loaded Every Day And Pumped Into The Specified Tanks. The Driver Offloads Waste Fluids By Connecting A Hose To A Valve Header Which Is Situated Within The Containment Structure. According To Mr. Bradley, The Driver Places A Bucket Beneath The Hose To Catch Any Drips Outside The Containment Structure. What Appeared To Be Staining Was Noted On The
09/07/2017 Issue Non-Compliance Letter Sent-09/07/2017 ; Compliance Assistance Offer Written-09/07/2017 ; Response Received-09/22/2017 ; Finished-12/15/2017
12/15/2017 Submittal Received By Department Received-09/22/2017 ; Finished-12/15/2017
12/15/2017 Request For Extension Received-11/17/2017 ; Finished-12/15/2017
12/15/2017 Submittal Received By Department Received-12/13/2017 ; Finished-12/15/2017
12/15/2017 Project Closed Letter Sent-12/15/2017 ; Finished-12/15/2017
08/31/2021 Site Inspection Routine; Used Oil Transporter - Routine; Used Oil Transfer Facility A Compliance Evaluation Inspection Was Conducted By Florida Department Of Environmental Protection (Fdep) Hazardous Waste Staff At Howco Environmental Services (Facility) On 08-31-2021 To Verify The Facility'S Compliance Status With State And Federal Hazardous Waste, Used Oil And Universal Waste Rules And Regulations. The Following Is A Summary Of My Observations. A File Review Reflects The Facility Is Currently Registered With Fdep As A Used Oil Transporter For Hire, Transfer Facility, Filter Transporter And Filter Transfer Facility. The Registration Expires On 06-30-2022. A Certificate Of Liability Insurance Acord Was Submitted And Is Valid From 06-28-2021 To 06-28-2022. The Storage Tank System (Facility Id9300283) Was Last Inspected By Lee County Division Of Natural Resources Staff On 04-21-2021. According To The Inspection Report, The Three Regulated Aboveground Storage Tanks Were In Good Condition And The Secondary Containment Was Clean, Well-Sealed And Free Of Debris. The Facility Was Last Inspected By Fdep Hazardous Waste Staff On 08-10-2017. According To Previous Inspection Reports, The Facility Has Been Operating At This Location Since 1991. Lee County Property Appraiser Records Identify Kenneth Ryan As The Current Property Owner Of 2650 Edison Ave., Fort Myers, Fl. Howco Leases A Portion Of The Bulk Storage Area From Ryan Petroleum. The Facility Is Unmanned. All Records Associated With The Facility Are Maintained At The Howco Environmental Services In St. Petersburg, Fl. Prior To The Inspection, Prima Mull, Operations Manager, Was Contacted Regarding The Inspection. Ms. Mull Granted Permission To Conduct The Inspection, Unescorted, And Agreed To Provide All Requested Documentation Electronically. Upon Arriving At The Facility, I Met With A Representative Of Ryan Petroleum And Was Granted Permission To Conduct The Inspection. | This Facility Primarily Operates As A Used Oil And Used Oil Filter Transporter And Transfer Facility. Used Oil, Used Oil Filters, Used Antifreeze And Oily Water Is Picked Up From Generators And Transported To This Site For Consolidation And Eventual Transport To The Howco Environmental Facility In St. Petersburg (Epa Id No. Fld152764767). According To Ms. Mull, This Facility Has One Truck And One Driver For Pick-Ups; And Operates Monday To Thursday. The Truck Has Three Compartments: 3,000-Gallons For Used Oil, 1,000-Gallons For Used Antifreeze, 1,000-Gallons For Oily Water And Is Equipped To Transport Up To Thirteen 55-Gallon Drums Of Used Oil Filters. Ms. Mull Verified That The Fdep Used Oil Transporter Registration Is Maintained In The Truck. It Was Estimated The Facility Picks Up Approximately 8,000-9,000 Gallons Of Fluids Per Week. Ms. Mull Also Verified That Spill Control Equipment Including Dry Absorbent, Boom, Absorbent Pads, Etc. Is Maintained On The Truck. At The Time Of The Inspection, The Truck And Driver Were Not At The Facility. According To Ms. Mull, The Truck Is Off-Loaded Every Day And Pumped Into The Designated Storage Tanks. Before Off-Loading Waste Fluids, The Driver Measures The Before (And End) Volume Of The Storage Tanks. The Driver Then Connects A Hose To A Valve Header Which Is Situated Within The Containment Structure (See Photo). Beneath The Valve Header Is A Metal Box To Collect Drips, Etc. From The Hoses. Drivers Open The Lid When Loading/Off-Loading Fluids. At The Time Of The Inspection, The Lid Was On The Box Which Prevents Rainwater From Collecting, And Was Not Inspected. Fluids That Collect In The Box Are Removed And Properly Managed. What Appeared To Be Weathered Staining Was Noted On The Outside Of The Containment Wall, Adjacent To The Valve Header (See Photo). Ms. Mull Was Provided A Photo. *Immediately Following The Inspection, Documentation Was Provided Reflecting The Wall Had Been Repainted. Each Storage Tank Is A Vertical Aboveground, Single-Walled Tank That Is 20,000-Gallons In Capacity. The Tanks Are Labeled Accor
10/04/2021 Submittal Received By Department Received-09/07/2021 ; Finished-10/04/2021
10/04/2021 Submittal Received By Department Received-09/08/2021 ; Finished-10/04/2021
10/04/2021 Submittal Received By Department Received-09/20/2021 ; Finished-10/04/2021
10/04/2021 Submittal Received By Department Received-09/27/2021 ; Finished-10/04/2021
10/04/2021 Project Closed Letter Sent-10/04/2021 ; Finished-10/06/2021
11/29/2023 Site Inspection Routine; Used Oil Transporter - Routine; Used Oil Transfer Facility Hagan Holding Company Dba Howco Environmental Services (Hereinafter, “Howco” Or “Facility”) Located At 2650a Edison Ave, Fort Myers, Lee County, Florida Was Inspected By The Florida Department Of Environmental Protection (Dep) On November 29, 2023 (11/29/2023), To Determine The Facility’S Compliance With The State And Federal Hazardous Waste Regulations Described In Title 40, Code Of Federal Regulations (Cfr) Parts 260-268, 40 Cfr Part 273, And 40 Cfr 279, Adopted And Incorporated By Reference In Chapters 62-710 And 62-730, Florida Administrative Code (F.A.C.). The Facility Is Unmanned. All Records Associated With Howco Are Maintained By Prima Mull, Howco Operations Manager In Saint Petersburg, Florida. Prior To The Inspection, Ms. Mull Was Contacted Regarding This Inspection. Ms. Mull Granted Permission To Conduct The Inspection Unescorted, And Agreed To Provide All Requested Documentation Electronically. Upon Arrival At The Facility The Inspectors Were Met And Escorted Around The Facility By Sean Mcnabb, Plant Manager For Ryan Petroleum. The Inspector Was Accompanied By Genevieve Grah, Dep Environmental Specialist. Notification History: A File Review Reflects The Facility Initially Notified And Registered With The Dep As A Used Oil And Used Oil Filter Transporter And Transfer Facility In January 1995. The Facility Was Assigned The Epa Identification (Epa Id) Number Fl0001000611. The Facility Most Recently Registered With The Dep In September 2023. The Registration Expires On 06/30/2024. As Part Of Their Registration, Howco Submitted An Annual Report For January – December 2022 Which Reflects 456,169 Gallons Of Used Oil And 233,200 Used Oil Filters Were Collected At The Facility, And 433,394 Gallons Of Used Oil And 236,900 Used Oil Filters Were Transported From This Facility To The Howco Environmental Services Facility In Saint Petersburg (Epa Id: Fld152764767). A Certificate Of Liability Insurance Acord Was Submitted And Is Valid From 06/28/2023 To 06/28/2024. Inspection History: The Facility Was Last Inspected By Dep Hazardous Waste Staff On 08/31/2021. According To Previous Inspection Reports, The Facility Has Been Operating At This Location Since 1991. Lee County Property Appraiser Records Identify Kenneth E Ryan As The Current Property Owner Of 2650 Edison Ave, Fort Myers, Florida. Ryan Petroleum Operates A Bulk Storage Facility, Which Includes Thirteen (13) Aboveground Storage Tanks And Howco Leases A Portion Of The Bulk Storage Area Including Four (4) Vertical Aboveground Storage Tanks. Howco Maintains Financial Assurance For The Tank System And Was Verified To Be Current Through 06/28/2024. A Spill Prevention, Control And Countermeasures (Spcc) Plan For The Site Is Maintained By Ryan Petroleum. The Facility Is Surrounded By A Chain-Link Fence Secured With Two Access Gates. The Gates And Fence Appeared To Be In Good Condition. The Storage Tank System (Facility Id9300283) Was Last Inspected By Lee County Division Of Natural Resources Staff On 04/21/2021. According To The Inspection Report, The Three Regulated Aboveground Storage Tanks Were In Good Condition And The Secondary Containment Was Clean, Well-Sealed, And Free Of Debris. Personal Protective Equipment (Ppe) Was Required To Enter The Facility. Inspectors Were Equipped With Steel-Toed Boots. | The Howco Facility Primarily Operates As A Used Oil And Used Oil Filter Transporter And Transfer Facility. Used Oil, Used Oil Filters, Used Antifreeze, And Oily Water Is Picked Up From Generators And Transported To This Site For Consolidation And Eventual Transport To The Howco Environmental Facility In St. Petersburg (Epa Id: Fld152764767). According To Ms. Mull, This Facility Has One Truck And One Driver For Pick-Ups; And Operates Monday To Thursday. The Truck Has Three Compartments: 2,300-Gallons For Used Oil, 1,000-Gallons For Used Antifreeze, 700-Gallons For Oily Water And Is Equipped To Transport Up To Thirteen 55-Gallon Drums Of Used Oil Filters. It Was Esti
12/11/2023 Site Photos Finished-12/11/2023
12/14/2023 Status Report Finished-12/14/2023
01/11/2024 Submittal Received By Department Finished-01/11/2024
01/11/2024 Submittal Received By Department Finished-01/11/2024
01/16/2024 Informal Verbal Enforcement Finished-01/16/2024

Violation History:

Vio# Area Regulation Opened By Date Determined Completed ETA Act Act Date Regulation Text Excerpt
(mouse over for full text)
1 279.E 279.45(e)(2) Bayly_K 12/06/2000 05/30/2001 8012 12/06/2000 The entire containment system, including walls and floors, must be sufficiently impervious to used oil to prevent any used oil released into the containment system from migrating out of the system to the soil, groundwater, or surface water.
2 279.E 279.45 Bayly_K 02/26/2001 05/30/2001 8185 02/26/2001 Used oil storage at transfer facilities. Used oil transporters are subject to all applicable Spill Prevention, Control and Countermeasures (40 CFR part 112) in addition to the requirements of this subpart. Used oil transporters are also subject to th
10 262.C 262.34(a)(1)(i) Bayly_K 05/30/2001 09/26/2002 8362 05/30/2001 In containers and the generator complies with the applicable requirements of subparts I, AA, BB, and CC of 40 CFR part 265; and/or
3 265.C 265.31 Bayly_K 10/11/2001 09/26/2002 8614 10/11/2001 Maintenance and operation of facility. Facilities must be maintained and operated to minimize the possibility of a fire, explosion, or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents to air, soil, or surf
4 UNKNOWN Bayly_K 10/11/2001 09/26/2002 8614 10/11/2001 Unknown - insufficient data from import to identify rule.
5 UNKNOWN Bayly_K 10/11/2001 09/26/2002 8614 10/11/2001 Unknown - insufficient data from import to identify rule.
6 262.C 262.34(a)(1)(i) Bayly_K 10/11/2001 09/26/2002 8614 10/11/2001 In containers and the generator complies with the applicable requirements of subparts I, AA, BB, and CC of 40 CFR part 265; and/or
7 XXS 62-730.160(7) Bayly_K 10/11/2001 09/26/2002 8614 10/11/2001 Generators shall maintain adequate aisle space between containers of hazardous waste to allow for inspection of the condition and labels of the individual containers.
8 262.A 262.11 Bayly_K 11/06/2001 09/26/2002 8516 11/06/2001 Hazardous waste determination. A person who generates a solid waste, as defined in 40 CFR 261.2, must determine if that waste is a hazardous waste using the following method:
9 XXS 62-761.500(3)(c) Bayly_K 11/06/2001 09/26/2002 8516 11/06/2001 Steel tanks coated with a fiberglass reinforced plastic composite shall be constructed in accordance with UL-58 and either UL 1746, STI ACT 100¿ (F894), or certified by a nationally recognized laboratory that one of these standards is met.
11 XXS 376.302 Wilson_Km 10/05/2005 11/23/2005 10875 10/05/2005 Prohibited acts; penalties.--
12 279.C 279.22(c) Wilson_Km 10/05/2005 11/23/2005 10875 10/05/2005 Labels.
13 279.E 279.46(a), 279.46(b) Dubois_A 10/12/2011 02/17/2012 155155 10/12/2011 Acceptance. Used oil transporters must keep a record of each used oil shipment accepted for transport. Records for each shipment must include:, Deliveries. Used oil transporters must keep a record of each shipment of used oil that is delivered to ano
14 XXS 62-710.850 Dubois_A 10/12/2011 02/17/2012 155155 10/12/2011 Management of Used Oil Filters.
15 279.C 279.22 Dubois_A 10/12/2011 02/17/2012 155155 10/12/2011 Used oil storage. Used oil generators are subject to all applicable Spill Prevention, Control and Countermeasures (40 CFR part 112) in addition to the requirements of this Subpart. Used oil generators are also subject to the Underground Storage Tank
16 279.E 279.45(e)(2) Dubois_A 10/12/2011 02/17/2012 155155 10/12/2011 The entire containment system, including walls and floors, must be sufficiently impervious to used oil to prevent any used oil released into the containment system from migrating out of the system to the soil, groundwater, or surface water.
17 XXS 62-710.510 Dubois_A 10/12/2011 02/17/2012 155155 10/12/2011 Record Keeping and Reporting.
18 279.E 279.45(e)(2) Bayly_K 08/10/2017 12/13/2017 180831 08/10/2017 The entire containment system, including walls and floors, must be sufficiently impervious to used oil to prevent any used oil released into the containment system from migrating out of the system to the soil, groundwater, or surface water.
19 279.E, XXS 62-710.401(6), 279.45(g)(1) Coffin_P 11/29/2023 01/11/2024 196402 11/29/2023 No person may store used oil in tanks or containers unless they are clearly labeled with the words "used oil" are in good condition (no severe rusting, apparent structural defects or deterioration), and not leaking (no visible leaks). If tanks or con