# Mower Repair Center



## midwestFCO (Jul 23, 2012)

Sorry so long; trying to be thorough.

I have a lawn mower/small equipment repair facility in our jurisdiction that has changed the way they empty and refill fuel since their 2011 inspection.  It just happens that O S H A was out for an inspection (unrelated issue) and came across the new operation before we did their 2012 inspection and contacted us to do the violations of the fire code.  The new process involves emptying the oil and/or gasoline (some 2-cycle some 4) into an oil pan then into a 30-gallon drum during the day which is then suctioned into a used (waste) oil tank inside the building - approximately 660 gallon tank.  They also sometimes keep a drum (about 30 gallons) in a flammable liquids cabinet if it is not full enough to suction.  When the 660-gallon tank is full, they have a company come suction it to dispose.

They then use an air fed refueling dispenser near a self-contained (wood) fueling area, approximately 2'w x 4'l and 8'h.  There is no electric to the dispensing unit itself (or the suction unit for the spent fuel) as it is all air-driven.  There are electric receptacles in the vicinity, maybe 6 feet or so away.  Ceilings in the facility are approximately 15' high.  There is no special ventilation around the dispensing/collection areas.  Building is unprotected type 2 with full sprinkler system and fire alarm, S-1 use group (for now).

Here is what I have so far:

1 - Tanks need permits.  Both tanks are inside and appear to be steel, but no visible UL listing/rating or capacity information.  No spill protection or secondary containment.  We permit all tanks in our city and they would not be approved as they are now.

2 - The have exceeded their maximum allowable quantity, even with the increases for sprinkler protection and flammable cabinets (they store some used oil in a drum in a cabinet).

3 - They are grounding 55-gallon drums to the sprinkler riser.

4 - Unlisted and likely non-allowed dispensing within the building.

I think they are going to be classified as H use group based on the quantity they have.  This will cause them to likely build a special area - maybe exhausted enclosure or maybe an attached addition.

Can anyone think of anything I am missing based on this very basic overview?  I am trying to keep their costs down, but I really do not see a way for them to keep the same operation without constructing a room for this purpose. That would be cheaper than making the whole space H2.

Thanks!


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## cda (Jul 23, 2012)

How many sq ft is the actual shop area ????

1. The waste liquid might at the most be class II and might even be closer to  class III.

That operation is almost equal to a car lube facility

2. Would you approve these tanks in a lube shop???

3. Do not understand the second operation are they dispensing gas or something else???

4. Do not have the book but think they get double for sprinklers and maybe double again for the cabinet

5. Need to answer those before can say if dispensing is good

6. And are they only dispensing a gallon or so at a time???

7. You say lawn mower small engine any more example??


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## midwestFCO (Jul 24, 2012)

I read my post again and was less than clear on a few things while trying to be concise.

The total shop area is about 38,000 square feet.  It is partitioned off into different functional areas, but no true separation.

2. Would you approve these tanks in a lube shop???

_I have no issue with the used fuel tanks, per se, but the gasoline tank inside does not meet what is required in IFC 27/34 as it stands.  The used fuel tank still needs a permit and needs spill containment, markings, etc._

3. Do not understand the second operation are they dispensing gas or something else???

_Yes, dispensing gasoline back into the equipment when they finish the repair.  If the equipment uses two cycle, they have that pre-mixed in a 30-gallon drum and refill from that.  When that needs filled, they dispense from the larger tank._

4. Do not have the book but think they get double for sprinklers and maybe double again for the cabinet

_You're correct - I considered that amount in the MAQ._

6. And are they only dispensing a gallon or so at a time???

_In general, yes._

7. You say  lawn mower small engine any more example??

_The majority of their repairs are walk behind mowers, so very little fuel capacity.  They also repair riding mowers, weed eaters, chain saws, trimmers, edgers ---lawn type stuff.  At any given time, there are probably 100-500 mowers in this place.  I was there on a "slow week" for this inspection and they had about 150._

I think my biggest question deals with what ventilation and/or electrical precautions are needed.  Those are the areas I am least familiar with as it relates to this.  I know in our local lube-n-go they have classified equipment in the lower area (beneath the vehicle) and a pretty hefty ventilation system.  I think the Building Department will handle most this, but at least want to be able to identify the need.

Thanks again!


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## cda (Jul 24, 2012)

so sorry to ask again on the refueling tanks

one container of premixed thirty gallons, how do the refill this one??

and how big is the container that they fill the thirty gallon with??

and there must be a container of straight gasonline??  how big??? how do they refill this one??

""""The new process involves emptying the oil and/or gasoline (some 2-cycle some 4) into an oil pan then into a 30-gallon drum during the day which is then suctioned into a used (waste) oil tank inside the building - approximately 660 gallon tank. They also sometimes keep a drum (about 30 gallons) in a flammable liquids cabinet if it is not full enough to suction. When the 660-gallon tank is full, they have a company come suction it to dispose."""

maybe I am adding to the original question????  do you want to restate it??   is the only new/ different operation the waste oil operation??? or is it also the refueling operation??

3404.3 Container and portable tank storage. Storage of

flammable and combustible liquids in closed containers that do

not exceed 60 gallons (227 L) in individual capacity and portable

tanks that do not exceed 660 gallons (2498 L) in individual

capacity, and limited transfers incidental thereto, shall comply

with Sections 3404.3.1 through 3404.3.8.5.

3404.3.1 Design, construction and capacity of containers

and portable tanks. The design, construction and capacity

of containers for the storage of Class I, II and IIIA liquids

shall be in accordance with this section and Section 9.4 of

NFPA 30.

3404.3.1.1 Approved containers. Only approved


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