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Jan 04 2019 11:10AM Dave Robinson 209-751-2157 page 5 <br /> Responses to Summary of Violations <br /> July 18,2018 <br /> By;john Alaniz <br /> Item#102 <br /> As you can see by the photos taken of the Universal Waste are proper and are labeled according to <br /> requirements. Photos 1660, 1661, 1655 refer to the handling and accumulation of Aerosol cans the may <br /> contain some product or aerosol component.We are a small quantity generator of Universal Waste and <br /> use the following processes. <br /> 1. Do not dispose in the trash or landfill. <br /> 2. Do not treat in any way! <br /> 3. Accumulation way under 5,000 Kg no notification or EPA number required Under 220 pounds <br /> per year. <br /> 4. Accumulation time 1 year <br /> 5. Proper labeling on container"Universal Waste—Aerosol Cans" <br /> 6. Covered container used and closed at the end of each day. Kept in a safe area,good ventilation, <br /> hard surface, material is segregated from incompatibles, away from types of flames <br /> 7. Employee training done <br /> 8. Emergency response plan in place <br /> 9. Shipping documents are kept for 3 years <br /> 10. Shipped with qualified transport companyto a qualified site <br /> Item#601&605 <br /> See attached Manifest. <br /> Don't know what he is referring to as all hazwaste containers on site are shipped off site within 90 days. <br /> The White 5 gallon bucket containing Metal shavings did not have an accumulation start date on it at <br /> the time.That bucket was shipped off site on 08/23/2018 see attached Manifest and is currently <br /> handled as a satellite accumulation area and shipped off site when full or 1 year from start of <br /> accumulation. <br />