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The following is an itemized list of hazardous waste violations that have not been <br />addressed for ELON INC as of November 16, 2015. <br />Open violations from August 21, 2015 inspection <br />Violation #102 - Failed to determine if a waste is a hazardous waste or retain waste analysis on site for 3 <br />years. <br />Two stockpiles (one soil and one ground up concrete) were observed in the northern portion of the property. Any <br />person who generates a waste shall determine if the waste is a hazardous waste. EHD had received sampling result: <br />for two samples ("west pile" and "east pile") on 4-23-2015, however, since these samples were only analyzed for the <br />LUFT metals and TPH, the determination appears to be incomplete at this time. Immediately submit a sampling plar <br />and a sampling rationale indicating that an adequate hazardous waste determination for the above stockpiles was <br />made, make a hazardous waste determination for the observed stockpiles, and manage these stockpiles according t <br />the Title 22 hazardous waste regulations. Submit a statement and supporting documentation explaining how this <br />waste was managed. <br />Violation #109 - Failed to keep signed copy of manifests from the designated facility for three years. <br />Copies of uniform manifests for the disposal of hazardous waste were not found on site. Hazardous waste generato <br />shall retain copies of all manifests signed off by the disposal facility and all receipts used in a consolidated <br />manifesting procedure on site for three years and have them readily available for review. Immediately locate a copy <br />all manifests and receipts for the last three years, maintain them on site, and submit copies to the EHD. <br />Violation #112 - Failed to keep copies of consolidated manifesting receipts for three years. <br />Copies of hazardous waste disposal records were not found on site. Hazardous waste generators shall retain copies <br />of all manifests signed off by the disposal facility and all receipts used in a consolidated manifesting procedure on sit, <br />for three years and have them readily available for review. Immediately locate a copy of all manifests and receipts fc <br />the last three years, maintain them on site, and submit copies to the EHD. <br />Violation #116 - Failed to submit a written response within 30 days of receiving an inspection report. <br />An inspection was last done on November 20, 2015 and an inspection report was issued identifying information to be <br />submitted to bring this site into compliance. This information was required to be submitted by January 3, 2015. This <br />information has not been received resulting in a non-compliant status for this facility. An operator that receives an <br />inspection report shall have 30 days to submit a written response that includes a statement documenting corrective <br />actions taken or proposing corrective actions which will be taken. Ensure that a written response documenting <br />corrective actions taken or proposed is submitted within 30 days of receiving an inspection report. <br />Violation #403 - Failed to keep hazardous waste containers closed except when adding or removing <br />hazardous waste. <br />During the November 2014 inspection, a hazardous waste oil tank had an open lid and had an open funnel inserted i <br />the fill port opening . All hazardous waste containers shall be closed at all times except when adding or removing <br />waste. Submit the required return to compliance documentation indicating that this violation was corrected. <br />Violation #601 - Stored hazardous waste onsite greater than 180 days. <br />During the November 2014 inspection one 400 -gallon container of waste oil had a blank hazardous waste label. <br />Facilities who generate less than 1000 kg of hazardous waste per month and do not exceed 6000 kg of waste stored <br />on site at any time may store waste on site up to 180 days. Immediately contact a licensed hazardous waste hauler <br />to dispose of this waste under manifest and submit a copy of the manifest to the EHD. <br />Violation #605 - Failed to completely label containers or tanks of hazardous waste. <br />The 400 -gallon waste oil tank had a blank hazardous waste label. All hazardous waste tanks shall be marked with th <br />words "Hazardous Waste" and the accumulation start date. Immediately ensure that all hazardous waste tanks are <br />marked with the required information. <br />Open violations from November 20, 2014 inspection <br />Page 1 of 2 <br />