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The following is an itemized list of hazardous waste violations that have not been addressed for SILVESTRES CONST MECH CO as of August 02, 2018. Open violations from August 05, 2016 inspection Violation#101 -Managed a hazardous waste without an identification number. This facility's hazardous waste ID number is inactive. A hazardous waste generator shall not treat, store, dispose of, transport or offer for transportation, hazardous waste without a hazardous waste ID number. Go to the DTSC web site http://www.dtsc.ca.gov/IDManifest/PERMHWID.cfm for the form to reactivate the ID number.Immediately reactivate your state ID number and submit evidence to the EHD. 08/09/18, SMCI Response to Voilation#101: Please see the attached application to renewal submitted to DTSC yesterday, Wednesday, 8/8/18(please attached application and fax transmittal results). Previously, SMCI renewed its EPA ID number on 04/14/17(please see history on DTSC's SMCI EPA Profile and our 04/14/17 application). Violation#110-Failed to keep signed copy of manifests from the designated facility for three years. Copies of uniform manifests for the disposal of hazardous waste for August 5, 2013 through August 5, 2016 were not found on site. Hazardous waste generators shall retain copies of all manifests signed off by the disposal facility and all receipts used in a consolidated manifesting procedure on site for three years and have them readily available for review. Immediately locate a copy of all manifests and receipts for the last three years, maintain them on site, and submit copies to the EHD. Violation#113-Failed to keep copies of consolidated manifesting receipts for three years. Copies of hazardous waste disposal records for August 5, 2013 through August 5, 2016 were not found on site. Hazardous waste generators shall retain copies of all manifests signed off by the disposal facility and all receipts used in a consolidated manifesting procedure on site for three years and have them readily available for review. Immediately locate a copy of all manifests and receipts for the last three years, maintain them on site, and submit copies to the EHD. 08/09/18,SMCI Response to Voilations#110 and#113: Please see the attached disposal receipt from E.F. Kludt&Sons, Inc. dated 08/07/14,which was the last time we had disposed of used refrigeration oil. Prior to then,we had disposed of used refrigeration oil on 07/23/09. We did not use a hazardous waste transporter at the time. Our service technician did not have our disposal receipt signed off by the disposal facility we used. We have two smaller Frick Screw Compressors produce close to 35-40 gallons of old or used oil after 25K hours, while the Mycom Reciprocating Compressor produces around 10 gallons of old or used oil after 1 OK hours.There is 8760 hours in a 365 day year. Silvestre, sometimes after heavy loads or seasons, changes the oil like last year 2017-that is why the blue 55 gallon drum is full and we are currently in need to be dispose it thru the proper channels like E.F. Kludts of Lodi or Ramos Environmental of West Sacramento, both in California. Our Mycom Reciprocating Compressor is only meant to be used in extremely heavy loads to the Refrigeration system and typically not used. At most the two smaller Frick Screw Compressors run 5 months a year running 24/7 alternatively in tandem. Since 2012, we been running the system for 21.4 weeks a year or producing 5.04 to 5.76 gallons a year minimum for the two smaller Frick Screw Compressors. Therefore,we having difficultly in accumulating enough used oil to fill a 55 gallon drum every 180 days, but based in the larger number of 5.76 gallons per year for the two smaller Frick Screw Compressors it would take up to 9.549 years minimum without heavy load or season oil changes(e.g.-2017)done at Silvestre's judgement and guarantee for proper equipment management. The solution is to have three 5 gallon drums to comply with the proper disposal of within every 180 days: one to be collected and disposed as a master collection bucket on top of the spill containment unit, and two to be used as oil drip buckets during normal equipment use, but then dump into the one master collection bucket within 180 days of Starting Accumlate Date. As of complete oil charges, one or two empty 55 gallon drum are to be used from reserve and properly labeled including with Starting Accumlate Date, but then to be immediately collected and disposed by the proper channels like E.F. Kludts of Lodi or Ramos Environmental of West Sacramento as soon as possible. Frick Screw 24/7 years to Compressor months weeks hours Gal per fill 55 G -w'h E I" Size per year per year per year 25K hrs Gal /yr drum E 4 } smaller 5 21.4 3600 35 5.04 10. 1 `� larger 5 21.4 3600 40 5.76 9.549 AUG 0 9 2018 ENVIRONMENTAL HEAL(I DEPARTMENT