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John Alaniz <br /> December 5, 2018 <br /> Page 5 of 7 <br /> Newark Recycled Fibers regrets that responsible facility personnel at the time did not <br /> follow up in responding to San Joaquin County EHD, nor did the former facility manager <br /> pas on this information to their successor or other company management. Newark <br /> Recycled Fibers has strengthened environmental compliance procedures recently by <br /> implementing an enterprise level environmental compliance task management system to <br /> generate task reminders and to document completion for review by corporate management <br /> and environmental staff. The topics discussed in hazardous waste training provided to <br /> Newark Recycled Fibers personnel by Yorke on December 4, 2018 will contribute to <br /> avoiding repeat violations and improving overall compliance. <br /> Item #406 <br /> CCR 66261.7 Contaminated container not marked with date emptied or managed within one year <br /> of being emptied. <br /> In the storage area, one blue and three black 55-gallon steel drums were observed without an <br /> empty date. Containers larger than five gallons that previously held a hazardous material shall be <br /> marked with the date they were emptied and managed within one year of being emptied. <br /> Immediately mark and manage all empty containers per this section. <br /> Management of empty drums that formerly contained hazardous materials or hazardous <br /> wastes was discussed in hazardous waste training provided to Newark Recycled Fibers <br /> personnel by Yorke on December 4, 2018. While on site, Yorke verified that two empty <br /> diesel drums were properly marked as empty with the date (see photos I and 2 in <br /> Attachment 3). In addition there was one empty black drum present in this area that is new <br /> and never contained a hazardous material and therefore does not require marking. <br /> Item #605 <br /> CCR 66262.340 Failed to completely label containers or portable tanks of hazardous waste. <br /> In the storage area: -Four black 55-gallon steel drums containing oily absorbent(3 full, 1 quarter <br /> full) were observed with a hazardous waste label missing the hazardous properties and the <br /> physical state. -One black 55-gallon steel drum containing oily absorbent(full)was observed with <br /> a hazardous waste label missing the hazardous properties. All hazardous waste containers shall <br /> be marked with the following information: <br /> - the words "Hazardous Waste" <br /> -name and address of generator <br /> -hazardous properties <br /> -physical state <br /> -composition (contents) <br /> -accumulation start date <br /> Immediately label these containers and ensure that all hazardous waste containers are marked <br /> with all the required information. <br /> Yorke alerted Newark Recycled Fibers that hazardous waste labels previously provided by <br /> the parent company were old federal hazardous waste labels and not California-specific labels <br /> and therefore did not include spaces for the required physical state and hazardous property. <br /> New California compliant labels were recently purchased and proper labeling was discussed <br /> Torke Engineering,LLC <br />