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The following is an itemized list of hazardous waste violations that have not been addressed for SJC FAIRGROUNDS as of May 17, 2019. Open violations from July 20, 2017 inspection Violation #712 - Failed to label universal waste to identify type of universal waste. UW lamps were found all over the property. Lamps were stored in trash cans, cardboard boxes, disintegrated cardboard boxes outside, shrink-wrapped on pallets stored on racks several feet in the air. They were stored in the maintenance shop, the overflow building, outside on pallets, outside in plastic trash containers and in the toilet storage room. Multiple broken bulbs were seen. Due to safety issues and blocked access inspector could not get an accurate count of the bulbs but it is estimated 800-1000 waste bulbs were identified on the property. Universal waste lamps shall be stored in a manner that prevents breakage and release to the environment. Universal waste shall be marked with the words"Universal Waste" and the type of waste (batteries, mercury containing equipment, lamps, electronic devices, CRTs, CRT glass). Immediately label these wastes and ensure that all universal wastes are labeled with the required information. Violation #713 -Stored UW onsite greater than one year or was unable to demonstrate the time UW has been stored. UW lamps were found all over the property. Lamps were stored in trash cans, cardboard boxes, disintegrated cardboard boxes outside, shrink-wrapped on pallets stored on racks several feet in the air. They were stored in the maintenance shop, the overflow building, outside on pallets, outside in plastic trash containers and in the toilet storage room. Multiple broken bulbs were seen. Due to safety issues and blocked access inspector could not get an accurate count of the bulbs but it is estimated 800-1000 waste bulbs were identified on the property. Universal waste may be accumulated for no longer than one year from the date the universal waste was generated. The universal waste handler shall be able to demonstrate the length of time that the universal waste has been accumulated. Since it could not be demonstrated how long this waste was stored on site, immediately dispose of this waste and submit a copy of the disposal receipt to the EHD. Violation #714 -Failed to train employees and maintain records on UW handling and emergency procedures. Per Skip, hazardous waste and universal waste training had not been provided. Employees who handle universal wastes (UW) must be trained initially and annually thereafter. At a minimum, personnel who manage UW shall trained and thoroughly familiar with proper universal waste management and emergency response procedures relative to those persons' responsibilities, including where applicable, 1. types and hazards associated with the UW managed at the facility 2. proper disposition of UW managed at the facility (e.g. locations of UW containers, or location of centralized UW area) 3. proper procedures for responding to releases of UW including the position titles and the means of contacting those personnel at the facility who are designated to respond to releases 4. labeling, collecting, handling, consolidating, and shipping UW at the facility, including, but not limited to the prohibition on the disposal of UW The UW handler shall maintain a written record by date indication the names of personnel who received the training and maintain those records for at least three years. Immediately provide employees with initial or refresher UW training. Submit a copy of the roster and the syllabus to the EHD. Violation #715 - Failed to keep complete records of each shipment of universal waste for three years. Copies of universal waste disposal records for 2015, 2016, 2017 were not found on site. Universal waste disposal records shall be retained for three years and have them readily available for review. Immediately locate a copy of all universal waste disposal receipts for the last three years, maintain them on site, and submit copies to the EHD. Page 3 of 3