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02/22/2011 |
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 The Parts & Service Managers Sandra Zeeman And Chris Duarte, Respectively. Each Granted Access To The Facility And Escorted Me Throughout Their Departments.
Used Oil Was Stored In Catch Pans And Portable Containers Throughout The Shops. Used Oil Catch Pans Were Not Labeled. The Cylinder Benches, Used For Working On Parts And To Drain Used Oil, Were Not Properly Labeled. Sludge From The Bottom Of Used Oil Catch Pans Is Cleaned Up Using Absorbent Pads. The Catch Pans Are Then Cleaned In The Wash Station Outside. All Of The Used Oil Containers Are Emptied Into One 3,000-Gallon Chamber Of A 15,000-Gallon Split Tank. The Tank Is Above-Ground, Double-Walled, Within Secondary Containment, And Registered With The Department. The Used Oil Chamber Was Not Properly Labeled. The Other Four 3,000-Gallon Chambers Contain Hydraulic Oil, Diesel Engine Oil, Transmission Oil, And One Is Empty. Disposal Receipts Were Reviewed Indicating Removal By Fcc Environmental. The Total Halogens Were Recorded At Less Than 1,000 Ppm. Mr. Duarte Provided Photos After The Inspection, Which Indicated All Containers Managing Used Oil Had Been Labeled "Used Oil."
Used Oil Filters Are Stored In A 15-Gallon Container, Labeled "Used Oil Filters," Inside The Shop. Drained Used Oil Filters Are Collected In This Container And Then Moved To The Used Oil Filter Crusher. The Used Oil Filter Crusher Has An Unlabeled Collection Container For Used Oil Beneath It And Is Located Near The Centralized Used Oil Filters Storage Area. Crushed Used Oil Filters Are Stored On Spill Containment Pallets In Two 55-Gallon Drums, Inside The Shop, Labeled "Used Oil Filters." Used Oil Filters Were Observed Draining On Mobile Used Oil Collection Containers In Various Locations Throughout The Shops. Disposal Receipts Were Reviewed Indicating Removal By Fcc Environmental.
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.
Used Antifreeze Was Stored Inside The Shop, On Spill Containment Pallets Next To The Used Oil Filters In Three 55-Gallon Drums Labeled "Used Antifreeze." Disposal Receipts Were Not Available For Review At The Time Of The Inspection; However, Following The Inspection A Letter From Onsite Antifreeze Recycling Was Provided, Indicating Removal Of The Facility'S Used Antifreeze.
Empty Aerosol Spray Canisters Are Crushed With The Used Oil Filter Crusher And Managed Inside The Shop On Spill Containment Pallets Next To The Used Oil Filters And Used Antifreeze In A 55-Gallon, Drum. The Crushed Canisters Are Removed With The Used Oil Filters By Fcc Environmental.
Used Absorbent Pads And Granular Material Is Managed In A 55-Gallon Drum, On Spill Containment Pallets With The Used Oil Filters. The Container Is Labeled "Non Hazardous Used Absorbent." The Facility Does Not Use Laundered Shop Rags. Only Absorbent Wipes Are Used And Added To The Drums Of Used Absorbent For Disposal. Aerosols Used Contain Only Petroleum Or F003 Listed Solvents. Disposal Receipts Were Reviewed Indicating Removal By Fcc Environmental.
The Facility Has Approximately 10 Parts Washers Spread Throughout. Mineral Spirits, With A Fp Of 105 Degrees F, Are Added To The Parts Wash |
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03/10/2011 |
Issue Non-Compliance Letter |
Sent for Issue Non-Compliance Letter-03/10/2011 ; Finished-03/10/2011 |
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11/14/2013 |
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 Evaluation Inspection Dealing With Resource Conservation And Recovery Act And Other Applicable State Regulations Was Conducted At Kelly Tractor Co., On November 14, 2013. A File Review Indicated That The Facility Had Previously Received A Hazardous Waste Inspection On February 22, 2011. | The Following Documentation Was Provided During The Inspection:
Lee County Cesqg Collection Flier
Fdep Managing Spent Fluorescent And High Intensity Discharge (Hid) Lamps Fact Sheet
Lee County Haulers' List
List Of Hazardous Waste Commonly Generated By Auto Repair Shops
Fdep Used Oil Management Fact Sheet
Used Oil Stencil
General Requirements For Spill Prevention, Control, And Countermeasure Plans
A Guide For Used Oil Transporters Training Program | Mike Isom, Safety And Environmental Manager Granted Me Access To The Facility And Escorted Me Throughout The Inspection. The Facility Owns The Property And Has Operated At This Location For 16 Years. Kelly Tractor Co., Utilizes 44 Employees. The Facility Is Connected To Municipal Water And Sewer.
The Facility Notified As A Small Quantity Generator Of Hazardous Waste, Used Oil Transporter, Used Oil Transfer, Used Oil Filters Transporter, And Used Oil Filters Transfer In 2013. The Facility Was Determined To Be A Used Oil Transporter, Used Oil Transfer, Used Oil Filters Transporter, Used Oil Filters Transfer, And Conditionally Exempt Small Quantity Generator Of Hazardous Waste; Generating Less Than 220 Pounds Of Waste Drained From Punctured Aerosol Spray Containers In A Single Month. The Facility Also Generates Used Oil, Used Oil Absorbent Media, Used Oil Filters, Used Antifreeze, Spent Parts Washer Solvent, Spent Lead-Acid Batteries, And Spent Fluorescent Lamps. The Following Areas Were Inspected: Parts Warehouse, Outside Storage, Service Department, Fuel Tank, Wash Pad, And Oil Tank.
Parts Warehouse
The Primary Function Of The Parts Warehouse Is Receiving, Storing And Selling Parts.
The Facility Owns A 7-Gallon Drum Mounted Parts Washer That Utilizes Oil Eater Cleaner Degreaser As Solvent. The Material Safety Data Sheet For The Product Is Maintained On Site And Was Reviewed During The Inspection. The Material Has A Ph Of 12.4 - 13 And Contains <5% Sodium Metasilicate; <5% 2-Butoxyethanol; And <5% Linear Alcohol Ethoxylated. The Facility Had Recently Started Using The Parts Washer And Has Not Generated Any Waste To Date. The Facility Was Advised To Verify That The Ph Level Of The Spent Parts Washer Solvent Was Below 12.5 To Ensure That It Was Not Corrosive. Fcc Environmental Is Contracted To Dispose Of The Spent Parts Washer Solvent. The Facility Had Been Using Parts Washers That Contained Mineral Spirits At The Time Of The February 22, 2011 Inspection. The Spent Mineral Spirits Were Co-Mingled With The Used Oil And Disposed By Fcc Environmental.
Spent Fluorescent Lamps Are Stored In Cardboard Cylinders Containers That Were Labeled "Universal Waste Mercury Containing Devices." The Containers Were Stacked On Top Of Each Other In A Precarious Manner. The Containers Were Stored In A Safer Manner That Would Prevent Breakage During The Inspection. Spent Fluorescent Lamps Are Disposed By Envirolight & Disposal Inc. Receipts Were Verified During The Inspection.
Outside Storage
Large Items That Can Be Stored Outside In The Weather Are Managed In This Area. No Issues Were Noted.
Service Department
The Service Department Provides Maintenance And Repairs To The Fleet Vehicles, Heavy Equipment, And Forklifts. The Service Department Has Eight Work Bays. The Facility Has Ten 30-Gallon Bench-Style Parts Washers That Utilize Oil Eater Cleaner Degreaser As Solvent. The Facility Has Not Generated Any Spent Parts Washer Solvent To Date. Fcc Environmental Is Contracted To Dispose Of The Spent Parts Washer Solvent.
Aerosol Spray Canisters Including Metalcote Brake Cleaner (Containing 7% Carbon Dioxide; 3.668% Ethylbenzene; 16% Xylene; And |
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01/02/2014 |
Informal Verbal Enforcement |
Finished-01/02/2014 |
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02/26/2020 |
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 Evaluation Inspection Was Conducted By Florida Department Of Environmental Protection (Fdep) Hazardous Waste Staff At Kelly Tractor (Facility) On 2-26-20 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 11-14-2013. 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 Lee County Property Appraiser, Kelly Tractor Co Owns The Property. The Facility Has Been Operating At This Location For About 23 Years, Has Approximately 44 Employees And Is On Municipal Water And Sewer.
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, 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 And Used Oil Filters Are Generated From Conducting Mobile Servicing Of Leased Equipment. It Was Indicated That Used Oil And Used Oil Filters Are Transported Back To The Facility Within Two Totally Enclosed Trucks. Both Trucks Were Out At Job Sites At The Time Of The Inspection. It Was Indicated That Used Oil Is Pumped From The Truck Tank(S) Into The Facility'S Used Oil Storage Tank At The End Of Each Service Day. Used Oil Filters Are Placed In A Drain Tray/Compartment Within The Truck(S). Used Oil That Collects In The Tray Is Pumped Into The Used Oil Storage Tank. The Facility Uses Fdep'S "Used Oil And Used Oil Filter Record Keeping Form" To Track The Locations And Quantities Of Used Oil/Filters Generated Off-Site. It Was Indicated That Both Trucks Are Equipped With Absorbent Pads And Spill Control Equipment In The Event Of A Spill Or Release. Drivers Receive Annual Training Including Spill 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 Portable Containers Labeled 'Used Oil' And Pumped Via Overhead Piping Into The Used Oil Storage Tank (See Photo). Used Oil Filters Are Drained And Collected In Labeled 55-Gallon Drums Maintained On Spill Containment Pallets Inside The Facility (See Photo). Disposal Documentation Reflects Heritage Crystal Clean (Hcc) Routinely Picks Up The Used Oil And Used Oil Filters. It Was Discussed The Facility May Want To Consider Utilizing A Used Oil Filter Crusher To Reduce The Number And Cost Of Used Oil Filter Drums Generated And Disposed.
Oily Shop Rags And Drip Pads Are Stored In Closed 55-Gallon Drums Labeled Non-Hazardous Used Absorbents And Picks Up For Disposal By Hcc. It Was Discussed The Facility May Want To Consider Options To Reduce/Recycle Oily Waste To Reduce Purchasing And Disposal Costs.
The Facility Owns And Maintains Approximately Ten Parts Washers In The Service Department And One Parts Washer In The Warehouse. 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 3 Months And Disposed With The Used |
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06/23/2020 |
Submittal Received By Department |
Finished-06/23/2020 ; Received-06/23/2020 |
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06/23/2020 |
Project Closed Letter |
Sent-06/23/2020 ; Finished-06/23/2020 |
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11/05/2024 |
Site Inspection |
Routine; SQG (100-1000 kg/month) - Routine; Used Oil Transporter - Routine; Used Oil Transfer Facility On November 5, 2024 (11/05/2024), Genevieve Grah (Inspector) With The Florida Department Of Environmental Protection (Dep) Conducted A Routine Compliance Evaluation (Cei) Inspection At Kelly Tractor Co, Located At 9651 Kelly Tractor, Fort Myers, Fl 33905. Kelly Tractor Co (Herein’ After “Kt” Or “Facility”) 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, 273, & 279 Adopted And Incorporated By Reference In Rule 62-710 & 62-730, Florida Administrative Code (F.A.C.). The Facility Was Inspected Due To A Complaint Alleging A Discharge Of Contaminated Water From The Facility’S Truck Wash System. The Inspector Was Accompanied By Martha Aliva And Alexandria Mcsurley From The Dep.
The Inspectors Were Escorted Around The Facility By Sandy Zeeman, Kt Product Support Representative, And David Parrish, Kt Service Manager. Upon Arrival At The Facility The Inspectors Presented Their Credentials And Explained The Purpose Of The Inspection.
Kt Occupies Approximately 78,058 Square Feet And Is Connected To City Water And Sanitary Sewer. The Facility Has Been Operating In Its Current Location Since 1996 And Employs Seventy-Five (75) Staff. The Facility Operates Monday Through Friday, 7:30 – 5 P.M.
Notification History:
Kelly Tractor Co Initially Notified With The Department As A Small Quantity Generator (Sqg) Of Hazardous Waste On August 9, 2010. The Facility Was Assigned The Epa Identification (Epaid) Number Flr000169177. The Facility Recently Re-Notified As A Small Quantity Generator (Sqg) And Used Oil Transporter On 05/06/2024.
An Sqg Of Hazardous Waste Generates Greater Than 100 Kilograms (220 Lbs.) But Less Than 1000 Kilograms (2,200 Lbs.) Of Hazardous Waste Within A Calendar Month.
Inspection History:
The Facility Was Previously Inspected By The Department On February 12, 2020, As A Vsqg 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 Co Provides Rental, Leasing, Sales And Service Of Construction And Industrial Equipment. Waste Generated From These Processes Include Used Oil, Used Oil Filters, Used Antifreeze, Oily Absorbents, Spent Lead-Acid Batteries, Universal Waste Spent Mercury Containing Lamps, Waste Paint, Solvent Liquid, And Solvent Contaminated Towels/Rags. This Waste Includes Flammable Liquids And Flammable Solids (Acetone, Toluene) Exhibiting A Hazardous Waste Characteristic Of Ignitability (Epa Waste Code D001), Which Is Also Listed As Epa Waste Code F003 And F005.
Parts Warehouse:
Kt Utilizes The Southeast Side Of The Building For The Storage Of Vehicle Parts And Storage Of Universal Waste Spent Mercury Containing Lamps And Spent Lead-Acid Batteries. At The Time Of Inspection, Inspectors Observed Two (2) Spent Lead-Acid Batteries, Not Properly Labeled With The Words, “Universal Waste – Batteries” Or “Used Batteries,” Located On The East Side Of The Parts Warehouse. Inspectors Also Observed One (1) 65-Gallon Container Of Spent Mercury Containing Lamps On The Southeast End Of The Warehouse. The Facility Contracts Envirolight To Pick Up Spent Mercury Containing Lamps And Interstate Batteries For The Spent Lead-Acid Batteries. The Department Requested From The Facility Documentation Proving The Universal Waste Has Not Accumulated On-Site For Longer Than One Year [40 Cfr 273.15(A & C)].
*Following The Inspection, Kt Provided Photo Documentation Of Records And Receipts For The Proper Disposal Of Spent Lead-Acid Batteries On 11/22/2024. In Addition, Photo Documentation Was Provided Of The Uw Spent Lead-Acid Batteries Properly Labeled With The Words, “Used Batteries.”
Service Bays:
The Facility Utilizes Seventeen (17) Service Bays For Routine Maintenance On The Leased Equipment, Sixteen (16) Bays Are Inside The Main Building, And One I |
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11/22/2024 |
Status Report |
Finished-11/22/2024 |
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11/25/2024 |
Submittal Received By Department |
Finished-11/25/2024 |
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11/25/2024 |
Submittal Received By Department |
Finished-11/25/2024 |
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11/25/2024 |
Submittal Received By Department |
Finished-11/25/2024 |
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11/25/2024 |
Submittal Received By Department |
Finished-11/25/2024 |
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12/18/2024 |
Site Photos |
Finished-12/18/2024 |
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03/21/2025 |
Submittal Received By Department |
Finished-03/21/2025 |
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04/08/2025 |
Informal Verbal Enforcement |
Return to Compliance Letter Sent (RCL)-03/26/2025 ; Finished-04/08/2025 |
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