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As a result of the laboratory results indicating that the material is non-hazardous, it is Tuff Boys <br /> intent to sell the product to a metal recycler. <br /> 2. Category: Preparedness <br /> #11 CCR66265.3 facility not maintained to minimize the release of a hazardous waste. <br /> Response: <br /> Tuff Boy Sales, Inc. has a metal fabrication department consisting of three shears, two brake <br /> presses, one punch press, five drill presses, one mill, one iron worker, three lathes and two <br /> band saws. At the time of inspection two shears and the iron worker were observed to be <br /> leaking hydraulic oil. <br /> Action taken: <br /> All machines were inspected for leaks. Three machines were found to be leaking hydraulic oil. <br /> These same three machines were observed to be leaking hydraulic oil as evidenced by <br /> absorbent lying on the floor around the base of each machine. All three machines were taken <br /> out of service; and, leaks were repaired. All three machines are back in service with no leaks <br /> detected. Tuff Boy will continue periodic inspections to monitor for leaks. <br /> 3. Category: Storage <br /> #20 CCR66262.34 (f) failed to completely label containers or tanks of hazardous waste. <br /> Response: <br /> At the time of inspection, Tuff Boy had the following containers that did not comply with county <br /> labeling requirements. <br /> Containers and Action taken: <br /> a. One used oil container (poly) utilized at Tuff Boy for the purpose of storing used <br /> recyclable oil was emptied on July 07, 2010 by American Valley Waste Oil with the <br /> used oil hauled off as per manifest #003509670FLE (a copy of which is enclosed with <br /> this letter). <br /> b. Two waste solid absorbent containers (55 gals) were disposed of per manifest <br /> #001154585GBF on July 01, 2010 (a copy of which is enclosed with this letter). <br /> c. Three 55 gallons drums of Mobil teresstic 46 hydraulic oil were re-labeled by our <br /> supplier. <br /> d. One 55 gallon partially full drum of misc. oil was pumped dry with contents hauled off <br /> with manifest #003509670FLE on July 07, 2010 described in response item `3a°. <br /> e. One waste solid absorbent container (55 gals) was hauled off by Shop Hazards <br /> Solutions on manifest #001154590GBF, on July 07, 2010 (a copy which is enclosed <br /> with this letter). <br /> As a result of these actions taken, all current potentially hazardous waste drums have been <br /> labeled in accordance with the labeling requirements directed c.-, the inspectors report. <br /> 4. Category: Containers <br /> #27 CCR66265.173 (a) failed to keep containers of HVv closed except when adding or <br /> removing HW. <br /> Response: <br /> Tuff Boy acknowledges this and is implementing the following corrective action. <br /> Action Taken: <br /> After disposing of the contents of the two absorbent container, Tuff Boy conducted a Haz Mat <br /> handling meeting with shop personnel to educate those personnel on proper handling, labeling <br /> and storage procedures. <br /> 2 <br />