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RECEIVED Summary of list Violations and Responses NOV 04 2013 them readily available for review. Immediately locate a copy of all manifests and nPJ�RTMNE L last three years, maintain them on site, and submit copies of these records, includinWte@missing disposal receipts between 2009 and 2011 requested the October 2011 inspection to the EHD by 11/4/2013. Following the Environmental Health Department's inspection on October 20, 2011, STI began properly tracking stored hazardous waste accumulation times and using Evergreen Oil Inc (Evergreen) for our hazardous waste disposal. The first hazardous waste Evergreen collected from STI was in March 2012. Enclosed with this document are copies of STI's Uniform Hazardous Waste Manifests for 2012 and up to this point 2013. Due to several issues, STI's former controller was laid-off in early 2013. The former controller was tasked with managing STI's uniform hazardous waste manifests, consolidated hazardous waste manifests, and any waste or recycling material bills of lading. In an effort to comply with the inspection report demands, we searched all our records; however, we can not locate any hazardous waste disposal records prior to March 19, 2012. We will continue to search for those records and if found, will submit copies of them to your office for review. 128. (Repeat) Bills of lading for the recycling of used oil filters for the last three years were not found on site. A copy of each bill of lading must be kept on site for at least three years. Immediately locate a copy of all bills of lading for used oil filters for the last three years, maintain them on site, and submit copies from 2009 to present to the EHD by 11/4/2013. Since before 2009, the fleet of work trucks that STI performed onsite maintenance on has been reduced to one operational work truck. STI has generated very little used oil filters over the past four years since the other operational vehicles and equipment maintenance are performed offsite. The few used oil filters that were generated were given to Napa for recycling. While we have searched, we can not locate the bills of lading for recycled used oil filter records from 2009 through 2012 and we have not generated onsite any used oil filters in 2013. 301 . (Repeat) Absorbents on the Machine Shop floor. Facilities shall be maintained and operated to minimize the possibility of a fire, explosion, or release of hazardous waste to air, soil, or surface water which could threaten human health or the environment. Immediately, and manage according to Title 22 hazardous waste regulations. Submit a statement and supporting documentation explaining how this waste was managed by 11/4/2013. The vast majority of our numerous metal fabrication machines use lubrication oils which escape the machines designed containment. While we have considered several additional lubrication oil containment in an effort to avoid slip hazards, we have found that the most effective and cost efficient method for us to use granular absorbent to contain the accumulated oil coming for the machines. Following the Environmental Health Department's inspection on October 4, 2013, we developed and have review with STI personnel a procedure for proper care and removal of saturated absorbent used around our metal fabrication machines (see enclosed). 812. Universal waste disposal receipts for the last 3 years were not available for review during this inspection. A copy of the universal waste disposal records shall be retained on site for at least 3 years. Submit a copy of the disposal receipt from 2009 to current day, including the receipt of the universe waste lamps identified in the October 2011 inspection, to EHD by 11/4/2013. Page 3 of 4