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October 19 2017 <br />Page 4 of 4 <br />Immediately label these containers or place the wastes in properly labeled containers, and ensure that <br />all hazardous waste containers are marked with all the required information. <br />This is a minor violation. <br />RESPONSE: Drums have been labeled with start dates, fuel used up and buckets removed. <br />Ordered new drums, separated filters and labeled drums. <br />608 CCR 66266.130 Failed to properly manage used oil and fuel filters. <br />Bills of lading for the recycling of used oil filters for the last three years were not found on site. A copy of <br />each bill of lading must be kept on site for at least three years. Immediately locate a copy of all bills of <br />lading for used oil filters for the last three years, maintain them on site, and submit copies to the EHD. <br />RESPONSE: Bill of lading copies do not exist. Used oil filters were never picked up. <br />A 55 gallon black steel drum of used oil and fuel filters was observed in the hazardous waste storage <br />area with no accumulation start date and the used filter label affixed to the removable lid instead of the <br />drum. Used oil filters shall be drained of free-flowing oil, stored in a closed, rainproof container, labeled <br />as "drained used oil filters," and <br />marked with an accumulation start date. Immediately label this container properly and ensure that all <br />used filters are managed in this way. <br />RESPONSE: New drums are labeled with start dates in rain proof containers. <br />A 55 gallon black steel drum of used oil and fuel filters was observed in the hazardous waste storage <br />area with no accumulation start date. Facilities that generate up to one ton of used oil filters per year <br />may store the filters up to one year. Facilities that generate one ton or more of used oil filters may store <br />the filters for up to 180 days. Since it cannot be determined how long these filters have been on site, <br />immediately recycle these filters under a bill of lading and submit a copy of the bill of lading to the EHD. <br />ENVIRONMENTAL ALT <br />DEPARTMENT <br />Think Inside the TrianglCAk <br />