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HECEIVEL) Michelle Henry JAN 12 2015 January 9,2015 Page 4 NVI RdNMENTAL employee onsite, the cans are allotived to air dhy in the trash can. This facility does not have a hazardous ivaste lreatiment permit issued from either the EHD or the DTSC. Imiinediately cease ti-ealment of hazardous waste without a permit or obtain a b•eatinent perinil. Class I violation. Response to Item No.204: Please see the response to Item No. 202,above, Pourable volumes of paint are used in operations by Cooks Collision and are not waste paint. Paint containers that were photographed by the CUPA with pourable amounts of paint were still in use in operations. With respect to paint containers that are not fully emptied through operations, Cooks Collision employees are required to empty the containers manually into a 55-gallon drum designated for the specific type of waste paint. All employees have been trained to follow this procedure. Cooks Collision has also trained all employees to place empty paint containers into a closed collection bin,and the empty paint containers are then removed from the facility by Corrick Enviro Services Inc. (See Attachment E). Iter:No. 403: CCR 66262.34(d)(2). Failed to keep hazardous ivaste containers closed except when adding or removing hazardous ivaste. A 55g drum of water based ivaste paint was seen open. All hazardous ~paste containers shall be closed at all times except when adding or removing waste. Immediately close these containers and ensure all hazardous waste containers are closed~then not adding or removing waste. Class H violation. Response to Item No.403: Cooks Collision has trained all employees on hazardous materials and hazardous waste management. Compliance training is conducted annually. On January 5,2015, all employees received detailed training on the proper handling and disposal of hazardous materials, including the requirement to keep hazardous waste containers closed when not adding waste to the container. Training attendance logs are provided as Attachment E. Enclosed as Attachment F, please find a photograph of the closed 55-gallon drum of water based paint. Itein No. 601: CCR 66262.34(d). Stored Hazardous waste onsite greater than 180 days. 1-55g drum of water based paint waste had what appeared to be a start date of 91212013, 1-55g drum of solvent paint ivaste had an illegible label, and a 55g drmn of bondo dust did not have a start accumulation date. Facilities hvho generate less than 1000 kg of hazardous ivaste per month and do not exceed 6000 kg of ivaste stored on site at any lime may store waste on site up to 180 days. Immediately contact a licensed hazardous ivaste hauler to dispose of this ivaste under manifest and submit a copy of the manifest to the EHD. Class H violation. Response to Item No. 601: Cooks_Collision has improved the condition of the labels on all hazardous waste accumulation containers an- placed them in protective plastic sleeves to ensure legibility. Accumulation start dates are more legible and reflect accumulation times less than 180 00015773.3