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The following is an itemized list of hazardous waste violations that have not been <br /> addressed for SILVESTRES CONST MECH CO as of August 02, 2018. <br /> Violation#601 -Stored hazardous waste onsite greater than 180 days. <br /> Facilities who generate less than 1000 kg of hazardous waste per month and do not exceed 6000 kg of waste <br /> stored on site at any time may store waste on site up to 180 days. Containers of hazardous waste that did not have <br /> a start accumulation date: <br /> -A blue 55 gallon drum of used refrigeration oil in the mechanical room <br /> -A black 55 gallon drum of used refrigeration oil in the mechanical room <br /> -A black 5 gallon drum of used refrigeration oil in the mechanical room <br /> Since it cannot be determined how long the hazardous waste has been on site, immediately contact a licensed <br /> hazardous waste hauler to dispose of this waste under manifest. Submit a copy of the manifest to the EHD within 30 <br /> days. <br /> Violation#605-Failed to completely label containers or portable tanks of hazardous waste. <br /> Containers of hazardous waste not completely labeled: <br /> -A blue 55 gallon drum of used refrigeration oil in the mechanical room did not have label filled out completely <br /> -A black 55 gallon drum of used refrigeration oil in the mechanical room had no label <br /> -A black 5 gallon drum of used refrigeration oil in the mechanical room had no label <br /> All hazardous waste containers shall be marked with the following information: <br /> -the words"Hazardous Waste" <br /> -name and address of generator <br /> -hazardous properties <br /> -physical state <br /> -composition(contents) <br /> -accumulation startdate <br /> Immediately label these containers and ensure that all hazardous waste containers are marked with all the <br /> required information <br /> 08109118,SMCI Response to Voilation#601 and#605: Please see the attached pictures taken by Fatinah Zareef, REHS. The <br /> black 55 gallon drum did not contain USED refrigeration oil; it was sealed and had NEW OIL clearly marked along its side. The black <br /> 5 gallon drum also did not contain used refrigeration oil; it too can clearly be seen to be sealed.We have ordered vinyl NEW OIL <br /> labels to adhere to both drums in the mechanical room;those labels will arrive in 10 days. <br /> The blue 55 gallon drum of used refrigeration oil in the mechanical room, at the time, contained 3 to 5 gallons of oil. A new <br /> completed vinyl label has been adhered to the drum(please see pictures of label).We have called Ramos Environmental of West <br /> Sacramento and will have this waste dispose of under manifest, once our EPA ID is reactivated.We will submit a copy of the <br /> manifest to the EHD upon its receipt. <br /> Violation#608-Failed to properly manage used oil and fuel filters. <br /> 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 <br /> lading must be kept on site for at least three years. Immediately locate a copy of all bills of lading for used oil filters <br /> for the last three years, maintain them on site, and submit copies to the EHD. <br /> Three drained used oil filters on top of a hazardous waste drum in the mechanical room were not containerized, not <br /> labeled and had no start date. Used oil filters shall be drained of free-flowing oil, stored in a closed, rainproof <br /> container, labeled as"drained used oil filters," and marked with an accumulation start date. Immediately <br /> containerize, label the drained used oil filters and mark a start date and ensure that all used oil filters are managed <br /> in this way. <br /> 08109118,SMCI Response to Voilation#608: Our ammonia compressors do not use oil filters; instead they use simple wire mesh <br /> strainers.The oil filters Fatinah Zareef, REHS, photographed and reported were not for our compressors.They were oil filters for <br /> welder generator units that were there to be drained of oil. These filters are simple automotive filters that we turned in to AutoZone. <br /> SMCI does not have bills of landing for these oil filters.We have now modified our procedures and have used oil filters drained of <br /> free-flowing oil, stored in a closed, rainproof container, labeled as"drained used oil filters,"and marked with an accumulation start <br /> date.We will ensure that all used oil filters are managed in the proper manner. <br />