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11/21/2012 |
Site Inspection |
Compliance Assistance Site Visit; SQG (100-1000 kg/month) - Compliance Assistance Site Visit; Used Oil Transporter - Compliance Assistance Site Visit; Used Oil Transfer Facility - Compliance Assistance Site Visit; Used Oil Generator Kelly Tractor (Kelly) Is A Business Which Provides Rental, Sales, And Servicing Of Heavy Equipment. The Facility Is Approximately 50 Acres In Size And Is Located In A Commercial Area. There Are Approximately 250 Employees. The Facility Is Connected To Public Utilities, And Has Been In Operation At The Current Location Since The 1970'S.
Kelly Is Located Just West And Contiguous To Pan Tropic Power (Ptp) Epa Id# Fld982091787. Ptp Was Inspected By The Department On January 24, 2012. It Was Also Stated That Ptp Runs The Service Building On The Back Property Directly Behind Kelly.
Compliance History
The Facility Has Never Been Inspected By The Department And Notified As A Small Quantity Generator, Small Quantity Handler, Used Oil Transporter, Used Oil Transfer Facility, Used Oil Transporter, And Used Oil Filter Transfer Facility On May 10, 2012. The Notification Was Properly Posted At The Facility. | The Facility Was Not In Compliance At The Time Of Inspection. An Exit Interview Was Provided At The End Of The Inspection Discussing The Possible Violation (S) Mentioned Above. The Inspector Provided Department Handouts, And Stencils For Proper Handling, Labeling And Disposal Of Hazardous Waste For Paint And Body Shops, And A Guide To Handling And Disposal Of Hazardous Waste For Small Quantity Generator'S (Sqg). | As A Result Of Processes Conducted At The Facility Waste Streams Include Used Oil, Batteries, Used Oil Filters,
Used Antifreeze, Mercury Bulbs, Paint Related Waste, Used Rags, Aerosol Can Waste, And Mineral Spirits. The Facility Consists Of Four Building. Building One, Is The Far West Building That Contains The Large Accessory Equipment Storage. Building Two, Is A Smaller Building Just East Of The Accessory Equipment Building, That Appears To Also Contain Large Parts Storage. Building Three, Is The Southern Most And Largest Building Containing Offices, Parts And Product Storage, And The Workshop. The Fourth Building, To The Northeast, Contained The Paint Booth And Equipment Wash Rack.
Building One
No Hazardous Waste Appeared To Be Generated In This Area.
Building Two:
Storage Area
The Facility Is Using A Gray Quickpac Qp 100 Oil Filter Crusher To Crush Aerosol Cans. The Unit Does Not Have A Filtration Apparatus To Capture The Propellant Release When The Aerosol Cans Are Crushed. Aerosol Cans That Are Crushed By The Facility Include Caterpillar Brake Cleaner, Napa Crc Brakleen, Caterpillar Yellow Paint, And Caterpillar Penetrating Oil. The Liquid That Is Squeezed Out In The Process Appears To Be Dripping Out Of A Side Faucet That Has A Open Bucket Hanging From It. The Facility Representative Stated That There Is An Absorbent Pad Inside The Hanging Bucket To Capture The Liquid. The Absorbent Pad Is Then Discarded With The Facility'S Oily Absorbent Waste; The Facility Had Not Performed Waste Determinations On Discarded Absorbent Pads Prior To Discarding As Oily Waste. The Facility Had Not Performed A Waste Determination On The Aerosol Cans And Their Contents To Determine The Proper Method Of Management And Disposal. The Facility Was Advised That The Oil Filter Crusher Was Not Being Used For Its Intended Purpose Nor In Accordance With Manufacturer Instructions. The Crushed Aerosol Cans Are Then Added To The Facility'S Scrap Metal For Recycling.
The Facility Has Three (3) Sodium Hydoxide Solution Parts Washers In The Main Shop And Approximately Fourteen (14) Mineral Spirits Parts Washers Spread Throughout. Each Parts Washer Unit Has A Filtration Device On The Back Of The Unit; Therefore, The Fluids Are Only Changed Out If They Are Extremely Dirty. The Spent Solvent From The Parts Washers Is Transferred To A System One Parts Washer, So That It Can Be Treated For Reuse.The Inspector Discussed That The Amount Of Spent Solvent Removed From These Machines To Be Treated In The System One Unit, Needs To Be Documented Since The Quantities Count Towards Their Status Upon Removal From Use And Prior To Treatment. The R |
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01/09/2013 |
Submittal Received By Department |
Finished-01/09/2013 |
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01/09/2013 |
Department Comments |
Finished-01/09/2013 |
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01/31/2013 |
Status Report |
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01/31/2013 |
Submittal Received By Department |
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01/31/2013 |
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01/31/2013 |
Status Report |
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01/31/2013 |
Submittal Received By Department |
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01/31/2013 |
Submittal Received By Department |
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Submittal Received By Department |
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01/31/2013 |
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01/31/2013 |
Submittal Received By Department |
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01/31/2013 |
Submittal Received By Department |
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01/31/2013 |
Submittal Received By Department |
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01/31/2013 |
Submittal Received By Department |
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01/31/2013 |
Submittal Received By Department |
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01/31/2013 |
Submittal Received By Department |
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01/31/2013 |
Submittal Received By Department |
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02/12/2013 |
Site Inspection |
Routine; SQG (100-1000 kg/month) - Routine; Used Oil Transporter - Routine; Used Oil Transfer Facility - Routine; Used Oil Generator Kelly Tractor (Kelly) Is A Business Which Provides Rental, Sales, And Servicing Of Heavy Equipment. The Facility
Is Approximately 50 Acres In Size And Is Located In A Commercial Area. There Are Approximately 250
Employees. The Facility Is Connected To Public Utilities, And Has Been In Operation At The Current Location Since
The 1970'S.
Kelly Is Located Just West And Contiguous To Pan Tropic Power (Ptp) Epa Id# Fld982091787. Ptp Was
Inspected By The Department On January 24, 2012. The Kelly Forklift Division Is Located At The Ptp Address. The Inspection Of The Forklift Division Was Conducted Separately On February 26, 2012.
Compliance History
Notified With The Department As A Small Quantity Generator, Small Quantity Handler, Used Oil Transporter, Used Oil Transfer Facility, Used Oil Transporter, And Used Oil Filter Transfer Facility On May 10, 2012. The Notification Was Properly Posted At The Facility.
A Compliance Assistance Site Visit (Casv) Was Conducted On November 21, 2012. | As A Result Of Processes Conducted At The Facility Waste Streams Include Used Oil, Batteries, Used Oil Filters, Used Antifreeze, Mercury Bulbs, Paint Related Waste, Used Rags, Aerosol Can Waste, And Mineral Spirits.
The Facility Consists Of Four Building. Building One, Is The Far West Building That Contains The Large Accessory
Equipment Storage. Building Two, Is A Smaller Building Just East Of The Accessory Equipment Building, That Appears To Also Contain Large Parts Storage. Building Three, Is The Southern Most And Largest Building Containing Offices, Parts And Product Storage, And The Workshop. The Fourth Building, To The Northeast, Contained The Paint Booth And Equipment Wash Rack.
Building One
No Hazardous Waste Appeared To Be Generated In This Area.
Building Two:
Storage Area
The Facility Has Purchased An Aerosolv System To Puncture The Aerosol Cans. The Crushed Aerosol Cans Are Then Added To The Facility'S Scrap Metal For Recycling.
The Facility Has Three (3) Sodium Hydroxide Solution Parts Washers In The Main Shop And Approximately
Fourteen (14) Mineral Spirits Parts Washers Spread Throughout. Each Parts Washer Unit Has A Filtration Device
On The Back Of The Unit; Therefore, The Fluids Are Only Changed Out If They Are Extremely Dirty. The Parts Washers Labeled "Wash" Have 15 Micron Filters On The Back That Are Changed Out About Every 2 To 3 Months. The Parts Washers Labeled "Finish" Have 6 Micron Filters On The Back That Are Changed Every 2 Weeks. The Used Filters Are Added To The Facility'S Used Oil Filters Handled By Fcc Environmental. The Facility Is In The Process Of Changing The Solvent In The Parts Washers To A Non-Hazardous Degreaser.
Eight (8) Drums Of Hazardous Waste Was Observed In This Area. All Of The Drums Were Labeled, Dated, And Stored Properly.
Building Three:
Spec Shop
Two Large Sodium Hydroxide Parts Washers Are In This Area. Fcc Environmental Services (Fcc) Removes The Waste From These Parts Washers As Hazardous Waste.
Main Shop 1
Nine Parts Washers Are Spread Out Throughout The Shop Area.
Main Shop 2
The Facility Has A Small Sand Blast Room With Bead Blast Media. It Has Been Several Years Since The Machine Has Been Used Or Media Has Been Disposed; Therefore, There Were No Historical Receipts Or Analysis Available For Review. The Inspector Discussed The Necessity Of A Waste Determination On The Material Prior To The Disposal Of Blast Media.
On The Other Side Of The Paint Booth There Is A Large Sand Blast Room That Uses Aluminum Oxide Media. Three (3) In-Use 55-Gallon Drums Sit Under The Filter Bank Labeled "Hazardous Waste". A Past Sample Of The Media Indicated That It Was Hazardous Waste Due To Chromium.
A Large Paint Booth Is Also Located In This Area. Two 55-Gallon Drums Of Paint Waste Were Observed Stored On Secondary Containment Pallets Just Outside The Paint Booth. One Drum Was Labeled "Paint Rag Waste" Dated 11-02-2012 And One Drum Was Labeled "Paint Related Waste |
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02/26/2013 |
Site Inspection |
Routine; SQG (100-1000 kg/month) - Routine; Used Oil Generator On February 26, 2013, A Representative Of The Florida Department Of Environmental Protection (Dep) Conducted A Hazardous Waste And Used Oil Compliance Evaluation Inspection At Kelly Tractor Company (Kelly). This Was A Focused Inspection Covering The Forklift Division Shop And The Small Paint Booth Associated With The Shop. The Oil Analysis Laboratory Was Also Part Of This Inspection. Kelly'S Main Facility Was Last Inspected On February 12, 2013, As A Small Quantity Generator And Was Determined To Be In Compliance.
Note: Kelly Tractor'S Main Facility Address Is 8255 Nw 58th St, Doral, Florida 33166-3493; However, The Forklift Division'S Address Is 8205 Nw 58th Street, Which East And Contiguous With The Main Facility. Pantropic Power, Inc. Is Also Co-Located At 8205 Nw 58th Street, But Operates Under Epa Id #Fld982091787.
Kelly Tractor Was Previously Inspected On 02/12/13 As A Sqg And Used Oil Transporter. Previous Inspections Did Not Included The Forklift Division And It Paint Booth Or The Oil Analysis Laboratory.
| The Inspector Toured The Forklift Division With Mr. Isom And Mr. Plamondon And Observed The Following Waste Management Units And Procedures:
Forklift Repair And Maintenance Shop:
One Safety-Kleen Recycle Kleen Parts Washer Serviced By Sk Every Six Weeks.
Lead/Acid Batteries Are Recycled Through Battery Sales In Hialeah. Industrial Batteries Are Recycled Through American Battery.
Red Shop Rags Are Picked Up By Aramark.
Used Oil, Used Oil Filters And Oily Absorbents Are Picked Up By Fcc.
The Floor Cleaning Machine Water And The Mop Water Are Disposed Of In Kelly'S Equipment Wash Rack.
The Facility Recently Acquired A 275-Gallon Steel Double Walled Aboveground Tank For Used Oil. The Tank Had Not Been Installed In The Facility And Was Not In Use.
The Inspector Observed The Following Containers Inside The Forklift Shop:
>Four, 55-Gallon Drums Of Used Oil, Labeled Waste Oil, Stored On Secondary Containment.
>Two, 55-Gallon Drums Of Used Oil Filters, Labeled Used Oil Filters.
>Two, 55-Gallon Drums Of Oily Absorbents, Labeled Non-Hazardous Used Absorbents Only.
Kelly Was Using Crc Heavy Duty Degreaser In Aerosol Cans To As Solvent To Clean Parts. Paper Towels Are Used To Wipe Down The Parts And Absorb Degreaser. The Waste Paper Towels Were Being Disposed Of In The Regular Shop Trash Which Is Then Picked Up By Kelly'S Maintenance Personnel And Placed In The Facility'S Regular Trash Dumpster. Mr. Plamondon Estimated That About One Box Of Paper Towels Is Used Every Two Weeks. No Solvent Contaminated Paper Towels Were Observed In The Trash At The Time Of The Inspection. A Review Of The Msds For The Degreaser Showed It Contains Tetrachloroethylene (Perc) 50%-60% By Weight And Trichloroethylene (Tce) 40%-50% By Weight. Based On The Concentrations Of Perc And Tce, The Waste Solvent Contaminated Paper Towels Would Meet The F002 Hazardous Waste Listing And May Exhibit The Toxicity Characteristic Leaching Procedure (Tclp) For Tetrachloroethylene (D039) And Trichloroethylene (D040).
Forklift Division Paint Booth:
This Small Paint Booth Is Located North Of The Forklift Repair And Maintenance Shop And Adjacent To The Waste Antifreeze Storage Area For Pantropic Power. The Paint Booth Has 18, 15" X 15" Pet Filters That Are Managed Has Hazardous Waste When Changed. The Paint Booth Is Operated By An Independent Contractor, But The Hazardous Wastes Are Disposed Of By Kelly. Lacquer Thinner Is Used On Paper Towels To Wipe Down Parts And The Paper Towels Are Disposed Of In The Regular Trash In The Forklift Shop. Typical Spent Lacquer Thinner Meets The F003/F005/D001 Hazardous Waste Codes.
The Inspector Observed The Following Containers Outside The Paint Booth:
>One, 55-Gallon Drum 1/3 Full Of Waste Thinner, Labeled Hazardous Waste, Closed Using A Closed Funnel Installed In The Drum'S Lid, Dated 12/12/12 And Stored On A Plastic Secondary Containment Pallet.
>One, 55-Gallon Satellite Accumulation Drum Of Us |
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03/26/2013 |
Submittal Received By Department |
Finished-03/26/2013 |
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08/09/2013 |
Issue Non-Compliance Letter |
Sent for Issue Non-Compliance Letter-08/09/2013 ; Finished-02/26/2014 |
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09/09/2013 |
Site Photos |
Finished-09/09/2013 |
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08/25/2022 |
Site Inspection |
Routine; SQG (100-1000 kg/month) - Routine; Used Oil Transporter - Routine; Used Oil Generator On August 25th, 2022 (08/25/2022) Michele De Freitas With The Florida Department Of Environmental Protection (Fdep) Conducted A Routine Compliance Evaluation Inspection For Hazardous Waste And Used Oil At Kelly Tractor Company (Hereinafter Kelly Tractor Or Facility), Located At 8255 Nw 58th Street Doral, Florida, 33166. Kelly Tractor Was Inspected To Determine The Facility’S Compliance With State And Federal Hazardous Waste Regulations Described In Title 40 Code Of Federal Regulations (Cfr) Parts 260-268, And 279 Adopted And Incorporated By Reference In Rule 62-710, And 62-730 Florida Administrative Code (F.A.C.). The Inspector Was Accompanied By Tarin Tischler, Environmental Specialist Ii, Johanna Polycart, Environmental Specialist Ii And Esther Thorne, Environmental Specialist I With Fdep.
The Inspectors Were Escorted Around The Facility By Roy Subia, Safety And Environmental Manager, And Ana Franchi-Alfaro, Facilities Manager Of Kelly Tractor. Upon Arrival At The Facility, The Inspectors Presented Their Credentials And Explained The Purpose Of The Inspection.
Kelly Tractor Has Been Operating At This Location Since 1971. The Facility Occupies An Approximately 40–42-Acre Lot And Has Two Buildings On The Property Lot, One Is The Aforementioned, Which Has A Total Of 105,460 Square Feet And The Other Is 8205 Nw 58th St, Doral, Florida, 33166. They Are Connected To The City Of Doral Water And Sewer And Employ Approximately 200 Employees. The Facility Operates Monday To Friday From 6:00 Am To 6:30 Pm.
Notification History:
Kelly Tractor Originally Notified With The Department As Small Quantity Generator (Sqg) Of Hazardous Waste And Used Oil Transporter On 11/13/2019. The Facility Was Assigned An Epa Identification (Epaid) Number Fld981925811. The Facility Most Recently Re-Notified With The Department Via Submittal Of The 8700-12fl Form On 05/19/2022 And An Annual Report And Certificate Of Liability Insurance On 03/07/2022. The Facility Is Registered As A Small Quantity Generator Of Hazardous Waste, Used Oil Generator, Transporter, And Generator Of Universal Waste, Used Oil Transporter, Used Oil Transfer Facility, Used Oil Filter Transporter, And Used Oil Filter Transfer Facility.
Inspection History:
The Facility Was Last Inspected By The Department On 02/26/2013 And Was Found To Be Out Of Compliance With State And Federal Regulations For Failure To Conduct A Proper Waste Determination, Failure To Provide Copies Of Hazardous Waste Manifests, Failure To Have All Employees Trained In The Handling Of Hazardous Waste And Failure To Have Land Disposal Restriction Forms Attached To The Disposal Manifests. An Area Of Concern Was Listed In The Previous Report Dated 02/26/2016 Which Was Failure To Label Satellite Accumulation Containers In The Oil Analysis Lab With The Words “Hazardous Waste”. The Facility Was Out Of Compliance At The Close Of The Inspection Report Dated 02/26/2013. A Compliance Assistance Offer Letter Was Sent To The Facility On 08/09/2013 And The Case Was Closed Without Formal Enforcement.
Steel-Toed Boots And Masks Were The Only Personal Protective Equipment (Ppe) Required To Enter The Facility. | Kelly Tractor Is The Caterpillar Heavy Equipment Dealer In The South Florida Area. They Provide Rentals, Leasing, Sales, And Servicing For All Types Of Construction And Industrial Equipment To The Following Markets: Highway And Bridge Building, Water And Sewer, Land Development, Housing, Aggregate Quarries, Agriculture, Warehousing, Seaports, Marinas, And Other Markets. They Are Also The Dealer For Caterpillar Oil.
Kelly Tractor Operates As A Hazardous Waste And Used Oil Generator, Used Oil Transporter, Used Oil Filter Transporter, Universal Waste Transporter, And Used Oil And Used Oil Filter Transfer Facility. They Generate Their Own Used Oil From Maintenance On Their Own Equipment And Transport It Themselves To The Designated Disposal Facility. They Do Not Transport Any Used Oil From Third-Party Customers. They Also |
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09/21/2022 |
Site Photos |
Finished-09/21/2022 |
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09/21/2022 |
Status Report |
Finished-09/21/2022 |
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09/21/2022 |
Submittal Received By Department |
Finished-09/21/2022 |
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09/21/2022 |
Submittal Received By Department |
Finished-09/21/2022 |
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