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Ljrlk # 107 Failed to retain waste analysis on site for 3 years. Nov j Analytical results were given to Inspector at time of audit. Hard copy is now kept with the "Hazardous Materials Waste Handling" manifest files "Lab Test Alar .Material'. (June 8, 2011 from Argon Laboratories was emailed and attached to report findings.) PH Log of the discharge water before and after PH adjustment is attached. HAZ Waste Bioassay Analysis from previous company attached dated March of 2009. Hard copy is now kept with the"Hazardous Material Waste Handling" manifest file. # 108 Failed to determine if a waste is a hazardous waste. 1) Solvent soaked rags. The laundry service has been replaced by another that can handle the rags in an appropriate method. See Attached G&K Services print towel processing statement. Secondary Container has been removed no longer using this method. 55 gallon containers now have a pump for the Power Klene QUV and The MRC-85 Metering Roller Cleaner. Picture attached. # 108 Failed to determine if a waste is a hazardous waste. 2) Spill containment cleanup for"Power Klene QUV" and "MRC-85". Generator has determined this is a hazardous waste and shall be processed with G&K services as a hazardous waste. Cleaning of the Spill containments has been implemented as a daily activity.See training attached.Also signs have been applied. #301 Observation of solvent spilled. Rags are used to clean this type of spill as it is small and the new rag service handles the rags as hazardous material. For the spill witnessed an absorbent was used and disposed of in an ink and solvent solids container. #404 Observed two 55 gallon drums with hazardous waste in them not closed. Signs have been applied to waste areas.See attached training, and pictures. #603 Two 55 gallon drums with hazardous waste in them were not dated with accumulation start dates. As drums were only one day old and very little (Ink waste) product was placed in them,they were emptied into other drums and hauled on Manifest#004901530 see attached. #605 1)Twelve 5 gallons buckets of waste paint and five 55 gallon drums of hazardous waste in main hazardous waste storage area had no accumulation start date. This product was picked up with Manifest#004901530,see attached. #605 2) Labels not filled out with all hazardous properties. Training on labeling hazard waste containers has been completed regarding the following information 1.The words"hazardous waste" 2. Name and address of generator 3. Hazard properties 4. Physical state 5. Composition (contents) 6.Accumulation start date,see attached training. Training has been done and an Environmental Area Safety Observation is done weekly to review all waste containers plant wide. Check list attached. #703 Emergency Coordinators Contingency plan information has been modified and posted at all phone location in warehouse. Revision was posted at time of audit. Revised form is attached.