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12/08/1987 |
Legacy Site Inspection |
Downloaded From Rcris On 18-Oct-96 Downloaded From Rcris On 18-Oct-96 |
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12/15/1987 |
Warning Letter Issued |
Downloaded From Rcris On 18-Oct-96 Downloaded From Rcris On 18-Oct-96 |
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08/07/1990 |
Compliance Evaluation Inspection |
Downloaded From Rcris On 18-Oct-96 Downloaded From Rcris On 18-Oct-96 |
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07/28/2010 |
Site Inspection |
Routine; CESQG (<100 kg/month) - Routine; VSQG (<100 kg/month) - Routine; Used Oil-Other The Last Hazardous Waste Inspection The Department Of Environmental Protection (Department) Conducted At This Facility Was In 1987. The Facility Is Serviced By City Water And Sewer, Has 25 Employees And Has Been At This Location Since 1933. The Properties Are Owned By Clewiston Motor Company, Located On The North And South Sides Of The Intersection Of Esperanza Ave And Sugarland Hwy (Sr 27).
The Facility Was Previously Notified As Being A Small Quantity Generator Of Hazardous Waste (Sqg) And Had Recently Submitted An Updated Notification As A Non-Handler. The Facility Was Determined To Potentially Be A Conditionally Exempt Small Quantity Generator Of Hazardous Waste, Generating Spent Parts Washer Fluids And Solids From The Equipment Wash Down Station. If Documentation Is Provided That Indicates These Waste Streams Are Not Hazardous, The Facility Would Be Considered A Non-Handler Of Hazardous Waste. Additionally The Facility Generates Used Oil, Used Oil Filters, Used Fuel, Spent Lead-Acid Batteries, Oily Absorbent Rags, And Spent Fluorescent Lamps.
| I Arrived At The Site And Reviewed The Purpose Of The Inspection With Dan Hansen And Mike Borko. Mr. Borko Granted Access To The Facility And Mr. Hansen Escorted Me Throughout. The Inspection Consisted Of The Parts Department, Located In The Same Building As Equipment Sales; The Maintenance Shop And Storage Tanks; And The Equipment Wash Down Area.
Used Oil Was Stored In Outside The Maintenance Building In A 1,000-Gallon, Above-Ground Tank, Labeled "Waste Oil." The Tank Is Registered With The Department And The Registration Is Up To Date. The Tank Is Protected From The Weather And Within Adequate Secondary Containment. Used Oil Is Pumped Into The Tank. Inside The Building Used Oil Was Stored Two 55-Gallon Drums, One Was Labeled "Used Oil" And The Other Was Not. Used Oil Catch Pans Were Not Properly Labeled. Disposal Receipts Were Reviewed Indicating Removal By Fcc Environmental. The Total Halogens Were Recorded At Less Than 1,000 Ppm.
Used Oil Filters Are Stored Outside The Maintenance Building In Three 55-Gallon Closed Drums Labeled "Used Oil Filters." The Surface Beneath The Drums Was Not Sealed With An Oil-Impermeable Sealant. Inside The Building Used Oil Filters Are Crushed. The Filter Crusher Had A Few Inches Of Used In The Bottom And Was Not Labeled. Used Oil Is Removed From The Crusher With A Hose That Pumps To The Used Oil Tank. The Crushed Used Oil Filters Are Stored In A 55-Gallon, Open Drum Labeled "Used Oil Filters" Inside The Shop Until The Drum Is Full, At Which Time It Is Moved Outside With The Rest Of The Drums. Disposal Receipts Were Reviewed Indicating Removal By Fcc Environmental.
The Facility Does Not Generate Used Antifreeze.
Oily Absorbent Wipes Are Stored In An Open 55-Gallon Drum, Labeled "Non-Hazardous Absorbents." Disposal Receipts Were Reviewed Indicating Removal By Fcc Environmental.
Used Fuel Was Stored In A 55-Gallon, Partially Full, Unlabeled, Closed Drum. The Fuel Can Be Reused In The Equipment. There Was An Additional 35-Gallon, Unlabeled, Closed Drum Of Diesel That Had Sugar Added. This Is Going To Be Used At The Truck Wash Area In A Steam Cleaner.
There Were Three Parts Washers That Use Mineral Spirits. The Fluids Are Changed Out And Added To The Used Oil For Disposal. There Was No Analytical Indicating The Flash Point Of The Spent Fluids Or Rcra Metal Content.
The Facility Uses Only Low Voc Brake Cleaner Which Contains Only Xylene And Acetone. Empty Aerosol Canisters Are Punctured And Crushed And Stored In A 55-Gallon, Open, Unlabeled Drum. The Crushed Aerosols Are Then Removed By Fcc Environmental With The Used Oil Filters.
Oily Mop Water Is Emptied Into The Truck Wash Station, Which Has An Oil-Water Separator. The Wash Down Station Recycles Out The Water And Had A Skimmer That Pulls Up Into A 55-Gallon, Open, Unlabeled Drum. The Drum Is Protected From The Weather But Must Re |
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08/12/2010 |
Issue Non-Compliance Letter |
Sent for Issue Non-Compliance Letter-08/12/2010 ; Finished-08/12/2010 |
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09/02/2010 |
Submittal Received By Department |
Received for SUBMITTAL RECEIVED BY DEPARTMENT-08/26/2010 ; Finished-09/02/2010 |
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02/17/2011 |
Site Inspection |
Routine; CESQG (<100 kg/month) - Routine; Used Oil Transporter - Routine; Used Oil Transfer Facility - Routine; Used Oil Generator - Routine; VSQG (<100 kg/month) I Arrived At The Site And Reviewed The Purpose Of The Inspection With Dan Hansen. Mr. Hansen Granted Access To The Facility And Escorted Me Throughout.
Used Oil Is Generated From Servicing Equipment Onsite As Well As Through Mobile Servicing Of Leased Equipment. The Used Oil Is Stored Outside, In A 1,000-Gallon, Above-Ground, Storage Tank That Is Situated Within Secondary Containment, Labeled "Used Oil," And Registered With The Department. Some Used Oil Catch Pans Were Properly Labeled, Others Were Not. The Most Recent Disposal Receipt, Indicating Removal By Fcc Environmental Was Reviewed At The Time Fo The Inspection. The Total Halogens Were Documented At <1,000 Ppm.
Used Oil Filters Are Crushed And Stored Inside The Facility In Two 55-Gallon Drums That Are Labeled "Used Oil Filters." Prior To Crushing, The Used Oil Filters Are Drained Into A 55-Gallon, Unlabeled Drum, Inside The Shop. Two Full, Labeled, Closed Containers Of Used Oil Filters Were Observed Outside, On An Unsealed Concrete Surface. Disposal Receipts Were Not Available For Review At The Time Of The Inspection, As The Manager Was Out Of The Office.
The Facility Transports Only The Used Oil And Used Oil Filters Generated Through The Mobile Servicing Of Their Own Equipment, Which Is Leased To Other Facilities For Use. As Such, The Facility Is Not Subject To Rule 62-710.600, F.A.C., With The Exception Of (2)(E) For Financial Responsibility. As The Facility Transports Its Own Used Oil And Used Oil Filters To Its Own Central Collection Facility For Storage Prior To Having The Used Oil Picked Up By A Certified Used Oil Transporter (Fcc Environmental), It Is Also Not Subject To The Additional Record Keeping And Reporting Requirements Of Rule 62-710.510, F.A.C. The Exclusion From These Requirements Were Confirmed With Aprilia Graves Of The Department'S Hazardous Waste Regulation Permitting Section, Prior To The Inspection.
Oily Absorbent Is Stored Inside The Facility In A 55-Gallon Drum Labeled "Non-Hazardous Waste, Used Absorbents." There Was A Full 55-Gallon, Closed, Labeled Drum Of Oily Absorbents Stored Outside Next To The Used Oil Filters. Disposal Receipts Were Not Available For Review At The Time Of The Inspection, As The Manager Was Out Of The Office.
The Fluids From The Three Parts Washers Are Periodically Added To The Used Oil For Disposal. The Fluids Added To The Parts Washer Are Mineral Spirits.
Empty Aerosol Containers Are Crushed And Stored In A 55-Gallon, Container Inside The Shop, Labeled "Used Oil Filters." The Empty Aerosol Containers Are Removed By Fcc Environmental With The Used Oil Filters, However Disposal Receipts Were Not Available For Review At The Time Of The Inspection, As The Manager Was Out Of The Office.
The Sediment From The Wash Down Station Has Not Been Removed, However An Analytical Was Provided Following The Inspection, Indicating The Soil Does Not Contain An Excess Of Rcra Metals. The Soil Will Be Removed By Fcc Environmental In The Future. The 55-Gallon Drum Used To Collect Used Oil And Oily Waste From The Wash Down Station Oil-Water Separator Was Labeled "Used Oil." The Drum Is On A Concrete Surface That Is Protected From The Weather And Is Located In A Manner That Would Not Cause A Discharge To The Environment.
Spent Lead-Acid Batteries Are Stored In The Parts Department, Inside The Warehouse On A Pallet. The Cores Are Exchanged Out By The Fort Myers Kelly Tractor. No Receipts Or Transport Records Were Available For Review.
Spent Fluorescent Lamps Are Stored In The Warehouse Next To The Parts Department In Two Containers That Are Labeled "Spent Mercury Containing Lamps." There Were No Disposal Receipts Available For Review.
| The Last Hazardous Waste Inspection The Department Of Environmental Protection (Department) Conducted At This Facility Was July 28, 2010. The Basic Facility Information Has Not Changed Since That Inspection.
Since The Last Inspection The Facility Has Re |
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02/21/2011 |
Issue Non-Compliance Letter |
Finished-02/21/2011 ; Sent for Issue Non-Compliance Letter-02/21/2011 |
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03/18/2011 |
Submittal Received By Department |
Received for SUBMITTAL RECEIVED BY DEPARTMENT-03/17/2011 ; Finished-03/18/2011 |
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04/21/2015 |
Site Inspection |
Routine; CESQG (<100 kg/month) - Routine; Used Oil-Other - Routine; Used Oil Transporter - Routine; Used Oil Transfer Facility - Routine; VSQG (<100 kg/month) Kelly Tractor Company Has Been At This Location Since 1933 And Was Previously Inspected In 1987, 2010, And 2011. The Property Is On Municipal Water And Sewer And Currently Has Approximately 30 Employees. The Facility Has A Current Registration (Insurance And Registration Are Up To Date) As A Used Oil Transporter And Transfer Facility And A Used Oil Filter Transporter And Transfer Facility. The Facility Notified As A Small Quantity Generator Of Hazardous Waste In 1987.
A Compliance Evaluation Inspection Was Conducted At Kelly Tractor On April 21, 2015. The Purpose Of The Inspection Was To Determine Compliance With State And Federal Regulations Associated With The Resource Conservation And Recovery Act (Rcra). Kelly Tractor Was Determined To Be A Conditionally Exempt Small Quantity Generator (Cesqg) Of Hazardous Waste Including Solvent Contaminated Wipes And Residue From Aerosol Can Puncturing (F005) At The Time Of The Inspection. A Cesqg Generates Less Than 220 Pounds Of Hazardous Waste In Any Calendar Month And Never Accumulates Greater Than 2,200 Pounds At Any One Time. The Facility Also Generates Used Oil, Used Oil Filters, Oily Absorbents, Oily Waste, Spent Lead-Acid Batteries, Oily Shop Rags, Excluded Solvent Contaminated Wipes, Sediment From Wash Down Station, And Spent Fluorescent Lamps.
| Kelly Tractor Provides Rentals, Leasing, Sales And Service Of Construction And Industrial Equipment.
Kelly Tractor Generates Used Oil While Conducting Mobile Servicing Of Leased Equipment. Used Oil (Typically Around 110 Gallons) Is Brought Back To The Facility In Tanks Built In To A Totally Enclosed Service Truck. Mr. Borko Said The Tanks Of Product And Used Oil Are Labeled. Used Oil Is Pumped From The Truck Tanks Into The Facility'S Used Oil Storage Tank At The End Of Every Service Day. The Facility Uses The "Used Oil And Used Oil Record Keeping Form" To Track The Locations And Quantities Of Oil Generated Off-Site. The Facility Has Not Provided Mobile Service For The Past Six Months As Their Mobile Mechanic Has Been Out On Extended Medical Leave.
Used Oil Is Also Generated From Servicing Equipment On-Site. Used Oil Is Collected In Drain Pans Labeled "Used Oil" And Is Pumped From The Work Bays Directly To The Used Oil Tank Outside Via Overhead Piping. Used Oil Filters Are Drained Prior To Placing In Drums. At The Time Of The Inspection There Were Six Closed Drums Labeled "Used Oil Filters". One Drum Labeled "Used Oil" Had A Drum Top Drain Funnel In The Bung And Was Being Used To Drain Used Oil Filters At The Time Of The Inspection. An Open Drum Labeled "Used Oil" Is Situated Underneath A Grate Where The Pump Nozzle Is Stored To Catch Incidental Drips. All Drums Are Stored Indoors And Protected From The Weather.
The Facility Generates Oily Shop Rags And Drip Pads Which Are Stored In A Closed 55-Gallon Drum Labeled "Non-Hazardous Used Absorbents".
Until A Little Over A Year Ago, The Facility Used Mineral Spirits For Parts Washing. In 2010 The Facility Had Parts Washer Waste Analyzed For Heavy Metals And The Results Were All Well Below Tclp. Spent Mineral Spirits Were Managed With Used Oil.
The Facility Now Owns And Maintains Four Aqueous Parts Washers. Maintenance Is Performed As Needed When The Mechanics Determine A Unit Is No Longer Cleaning Properly. The Service Date Is Written On A Label On The Side Of The Unit. The Units Were Observed To Have Dates Ranging From July 2014 To February 2015. The Solids Are Drained And Placed Into A Drum Labeled "Oily Sludge". The Service Manager Estimates A Few Gallons Of Waste Is Generated At A Time From Each Unit, Never Exceeding 10 Gallons A Month. The Facility Has Not Yet Disposed Of This Waste Stream. Mr. Borko Will Work With Heritage Crystal Clean Regarding Disposal Of This Waste Stream.
The Facility Uses Crc Brakleen No. 05088 Which Contains Methanol, Acetone, And 15-25% Toluene. Disposable Wipes Potentially Contaminated With This |
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05/01/2015 |
Issue Non-Compliance Letter |
Compliance Assistance Offer Written for Issue Non-Compliance Letter-05/01/2015 ; Sent for Issue Non-Compliance Letter-05/01/2015 ; Response Received for Issue Non-Compliance Letter-05/11/2015 ; Finished-05/12/2015 |
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05/12/2015 |
Submittal Received By Department |
Received for SUBMITTAL RECEIVED BY DEPARTMENT-05/11/2015 ; Finished-05/12/2015 |
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02/12/2020 |
Site Inspection |
Routine; CESQG (<100 kg/month) - Routine; Used Oil Transporter - Routine; Used Oil Transfer Facility - Routine; Used Oil Generator - Routine; VSQG (<100 kg/month) A Compliance Inspection Conducted Was Conducted By Florida Department Of Environmental Protection (Fdep) Hazardous Waste Staff At Kelly Tractor (Facility) On 2-12-2020 To Verify The Facility'S Compliance Status With State And Federal Hazardous Waste, Used Oil And Universal Waste Rules And Regulations. The Facility Was Previously Inspected On 04-21-2015. The Following Is A Summary Of My Observations.
Kelly Tractor Is Currently Registered As A Used Oil/Used Oil Filter Transporter And Transfer Facility; And A Small Quantity Generator Of Hazardous Waste. According To The Hendry County Property Appraiser, Clewiston Motor Co Owns The Property At 801 E Sugarland Hwy., Clewiston. Previous Inspection Reports Reflect The Property Is On Municipal Water And Sewer. The Facility Has Been Operating At This Location Since 1933 And Currently Has Approximately 30 Employees.
The Facility Was Determined To Be A Very Small Quantity Generator (Vsqg) Of Hazardous Waste At The Time Of The Inspection. A Vsqg Generates Less Than 220 Pounds Of Hazardous Waste In Any Calendar Month And Never Accumulates Greater Than 2,200 Pounds Of Hazardous Waste At Any One Time. The Facility Generates Hazardous Waste Including Solvent Contaminated Wipes And Aerosol Can Residual. The Facility Also Generates Used Oil, Used Oil Filters, Used Antifreeze, Oily Absorbents, Oily Waste, Spent Lead-Acid Batteries, Waste Diesel, Sediment And Wastewater From Wash Rack, Spent Parts Washer Solvent And Spent Fluorescent Lamps. | Kelly Tractor Provides Rental, Leasing, Sales And Service Of Construction And Industrial Equipment. Used Oil Is Generated From Conducting Mobile Servicing Of Leased Equipment. Used Oil Is Transported Back To The Facility In A 130-Gallon Labeled Tank Within A Totally Enclosed Truck. Used Oil Is Pumped From The Tank/Truck Into The Facility'S Used Oil Storage Tank At The End Of The Day. When Not In Use, The Truck Is Parked By The Tank Farm. Used Oil Filters Are Placed In A Drain Tray/Compartment Within The Truck (See Photo). Used Oil That Collects In The Tray Is Pumped Into The Used Oil Storage Tank. Fdep'S "Used Oil And Used Oil Filter Record Keeping Form" Is Utilized To Track The Locations And Quantities Of Used Oil/Filters Generated Off-Site And Transported To The Facility. One Designated Truck/Driver Is Utilized For Conducting Preventive Maintenance And Transporting Used Oil And Filters. The Truck Is Equipped With Absorbent Pads In The Event Of A Spill Or Release. The Driver Receives Annual Training Including Spills Response, Safety And Hazardous Waste Training.
Used Oil And Used Oil Filters Are Also Generated From Servicing Equipment On-Site. Used Oil Is Collected In Drain Pans Labeled 'Used Oil', Transferred Into A Drain Table/Basin And Pumped Directly Into The Used Oil Storage Tank. Used Oil Filters Are Drained Prior To Placing Into Closed, Labeled 55-Gallon Drums (See Photo). Disposal Documentation Reflects Heritage Crystal Clean (Hcc) Routinely Picks Up The Used Oil And Used Oil Filters.
Oily Shop Rags And Drip Pads Are Stored In Closed 55-Gallon Drums Labeled 'Non-Hazardous Used Absorbents' And Picked Up For Disposal By Hcc.
The Facility Owns And Maintains Four Aqueous Parts Washers. Tnt Degreaser Is Used In The Parts Washers. The Label On The Container Indicates It Is Biodegradable, Non-Flammable, And Contains No Naphthas, Chlorinated Solvents Or Benzenes. The Safety Data Sheet (Sds) Reflects The Product Has A Ph Of 10 And Contains 10% Sodium Hydroxide, Nonyl Phenol Ethoxylate, Sodium Metasilicate, Water And Non Active Ingredients. The Parts Washers Are Equipped With Filters Which Are Changed Approximately Every 2-3 Months And Disposed With The Used Oil Filters; And Spent Solvent Is Changed Approximately Every Two Weeks And Disposed In The Wash Rack Water At The Truck Wash Area. A File Review Reflected The Spent Solvent Was Last Characterized/Profiled In 2015. It Was Discussed The Facility Will Need To Conduct Waste Deter |
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04/13/2020 |
Submittal Received By Department |
Received-02/20/2020 ; Finished-04/13/2020 |
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04/13/2020 |
Project Closed Letter |
Finished-04/13/2020 ; Sent-04/13/2020 |
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07/24/2024 |
Site Inspection |
Routine; SQG (100-1000 kg/month) - Routine; Used Oil Transporter - Routine; Used Oil Transfer Facility - Routine; Used Oil Generator A Routine Compliance Evaluation Inspection (Cei) Of Kelly Tractor Co (Hereinafter, “Kelly Tractor” Or “Facility”) Was Conducted On July 24, 2024 (07/24/2024) By Pamela Coffin With The Florida Department Of Environmental Protection (Department, Or Dep). The Facility Is Located At 801 E Sugarland Hwy, Clewiston, Hendry County, Florida. The Facility Was Inspected To Determine Its Compliance With The State And Federal Hazardous Waste, Used Oil, And Universal Waste Rules And Regulations Described In Title 40, Code Of Federal Regulations (Cfr) Parts 260-268, 279, And 273, Adopted And Incorporated By Reference In Rule 62-730, 62-710, Florida Administrative Code (F.A.C.). The Inspector Was Accompanied By Ashley Giron, Dep Environmental Specialist.
The Inspectors Were Escorted Around The Facility By Mike Irey, Service Manager. Upon Arrival At The Facility, Inspectors Presented Credentials And Explained The Purpose Of The Inspection.
The Kelly Tractor Facility Occupies And Operates On Approximately 2.4 Acres Over Four Parcels Within Clewiston. Facility Offices And Storage Are Located At 801 E Sugarland Hwy. The Maintenance Shop Is Located Across The Street From The Office Building At 815 E Esperanza Ave. The Wash Rack Is Located On The 821 E Esperanza Ave Parcel, And The Outdoor Equipment Storage Area Is Located At 841 E Esperanza Ave.
The Facility Is Connected To Municipal Water And Sanitary Sewer. The Facility Has Been Operating At Its Location Since 1933 And Employs Approximately 25 Staff. The Facility Operates From 7:30 A.M. – 5 P.M., Five Days A Week.
Notification And Inspection History:
Kelly Tractor Notifies Annually With The Department As A Used Oil Generator, Used Oil Transporter, Used Oil Transfer Facility, And Small Quantity Generator Of Hazardous Waste - Epa Identification (Epaid) Number Fld981926488. Their Current Registration Is Valid Until 06/30/2025. The Facility’S Certificate Of Liability Insurance With Liberty Mutual Fire Insurance Company Expires 03/01/2025.
At The Time Of Inspection, The Facility Was Determined To Be A Very Small Quantity Generator (Vsqg) Of Hazardous Waste. A Vsqg Generates Less Than 220 Pounds Of Hazardous Waste In Any Calendar Month And Never Accumulates Greater Than 2,200 Pounds Of Hazardous Waste At Any One Time. The Facility Generates Hazardous Waste Including Solvent Contaminated Wipes And Aerosol Can Residual. The Facility Also Generates Used Oil, Used Oil Filters, Used Antifreeze, Oily Absorbents, Oily Waste, Spent Lead-Acid Batteries, Waste Fuel, Waste Tires And Tracks, And Sediment And Wastewater From Wash Rack.
The Facility Was Previously Inspected By The Department On 02/12/2020 And Was Found To Be In Compliance At The Time Of Inspection.
Personal Protective Equipment (Ppe) Was Not Required To Enter The Facility. Department Personnel Were Equipped With Steel-Toed Boots.
| Kelly Tractor Provides Rental, Leasing, Sales And Service Of Construction And Industrial Equipment. Used Oil Is Generated From Conducting Mobile Servicing Of Leased Equipment. Used Oil Is Transported Back To The Facility In A Labeled Tank Within A Totally Enclosed Lube Truck With A 360-Gallon Capacity. Used Oil Is Pumped From The Tank/Truck Into The Facility'S Used Oil Storage Tank At The End Of The Day. The Facility Is Not Required To Submit Dep'S "Annual Report By Used Oil And Used Oil Filter Handlers” Form 62-710.901(3) Because They Are A Self-Transporter Facility. One Designated Truck/Driver Is Utilized For Conducting Preventive Maintenance And Transporting Used Oil. The Truck Is Equipped With Absorbent Pads In The Event Of A Spill Or Release. The Driver Receives Annual Training Including Spills Response, Safety And Hazardous Waste Training.
Used Oil And Used Oil Filters Are Also Generated From Servicing Equipment On-Site. Used Oil Is Collected In Large Drain Tables Labeled “Used Oil” (Photo 1) And Pumped Directly Into The Used Oil Storage Tank (Photo 2). Used Oil Filters Are Drained Prior To Placing Into |
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07/25/2024 |
Site Photos |
Finished-07/25/2024 |
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07/25/2024 |
Status Report |
Finished-07/25/2024 |
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08/13/2024 |
Submittal Received By Department |
Finished-08/13/2024 |
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08/13/2024 |
Submittal Received By Department |
Finished-08/13/2024 |
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08/13/2024 |
Submittal Received By Department |
Finished-08/13/2024 |
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08/13/2024 |
Submittal Received By Department |
Finished-08/13/2024 |
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08/14/2024 |
Submittal Received By Department |
Finished-08/14/2024 |
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08/15/2024 |
Informal Verbal Enforcement |
Return to Compliance Letter Sent (RCL)-08/14/2024 ; Finished-08/15/2024 |
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