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hopper. The hopper was emptied into the Haz-Mat bin the following day, after <br /> you took samples for your office and subsequent to that,the contents in the Haz- <br /> Mat bin was hauled to an approved landfill for proper disposal. <br /> In 1997 Sumiden shipped used oil off site on two(2)occasions, and in 1998, on <br /> four(4) occasions. In each of the two years, used oil did not stay on site for more <br /> than 90 days. I realize that used oils must be shipped each 90 days,but the 90 <br /> days start from the accumulation date, not just each 90 days. <br /> 6. (#20) 66262.34 (CCR)Failed to properly label containers of hazardous waste. All <br /> Filter cake in filter press hopper is not labeled. Provide proper labels <br /> immediately. <br /> # 1 —Your inspection was conducted on November 16, 1999. On November 15, <br /> 1999, Sumiden shipped off site 1,450 gallons of oily water on Uniform Hazardous <br /> Waste Manifest# 99318124, included with this report as Enclosure# 3. When <br /> the barrels contained the used oil,they were also properly labeled. The used <br /> labels were removed when the used oil was removed. New labels will be <br /> reinstalled at the point in time when new accumulation date starts. <br /> Proper label is now installed on Filter Press Hopper. <br /> 7. (#21)66265.173 (a)(CCR) Failed to keep containers of hazardous waste closed <br /> except when adding or removing hazardous waste. <br /> # 1 —Waste Oil. Several of the waste oil drums had open bungs. <br /> # 2—Filter Cake from filter press hopper is being stored in a container without a <br /> cover. <br /> # 3—Floor Sweep/Drawing Soap waste dumpsters are being stored uncovered. <br /> Keep all containers of hazardous waste closed except when adding or removing <br /> the waste. <br /> Several oil drums did have the bungs open,but they had just been emptied the day <br /> before(see Enclosure# 3), and at the time of inspection, were empty containers. I <br /> believe this section addresses containers that are holding hazardous waste, and not <br /> containers that once held hazardous waste. <br /> It is true that the filter press hopper had materials in it, and it was not covered. <br /> Under normal circumstances, filter press hoppers are not covered. The mistake <br /> that we made was not emptying the hopper in a timely fashion, after cleaning out <br /> the clairifier system. The hopper has been emptied of all contents, and a <br /> Hazardous Waste Sticker has been installed. <br /> It is also true that the dumpsters containing the floor sweepings and used drawing <br /> soap was not covered. These(3)dumpsters are satellite containers that are <br /> 3 <br />