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The following is an itemized list of hazardous waste violations that have not been <br /> addressed for ALCO METALS as of April 22, 2017. <br /> Open violations from September 03, 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 /> A 55 gallon drum of copper turnings and smaller particles was observed in the storage building or metal recycling <br /> without first determining particle size or hazardous properties. Dark solids were observed accumulated on and <br /> around a copper wire processing machine inside the storage building. According to Mr. Rose and Mr. Lynch, the <br /> machine strips the insulation from the copper and the accumulation could be from the copper wiring or part of the <br /> sealant for the insulation. The floor around the machine was covered in oily staining. Any person who generates a <br /> waste shall determine if the waste is a hazardous waste. Immediately stop recycling metal fines, make a hazardous <br /> waste determination for the copper turnings waste and the waste around the processing machine, and manage <br /> them according to Title 22 hazardous waste regulations. Metal particles 100 microns or smaller must be handled as <br /> hazardous waste if the metal is determined to be a hazardous waste. Submit a statement and supporting <br /> documentation explaining how these wastes were managed. A sample of the copper turning waste was taken by <br /> the EHD at the time of inspection. <br /> Violation#104-No modified contingency plan. <br /> An emergency coordinator and modified contingency plan information is lacking. There must be at least one <br /> emergency coordinator on site or on call to coordinate emergency response measures, and the following <br /> information must be posted by a phone: the name and phone number of the emergency coordinator; location of fire <br /> extinguishers, spill control equipment, and if present, fire alarm; and the phone number of the fire department, <br /> unless the facility has a direct alarm. Immediately appoint an emergency coordinator and post the required <br /> information by a phone. A form is provided that can be used for this purpose. <br /> Violation#110-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 for prior to October 2014 were not found on site. <br /> Hazardous waste generators shall retain copies of all manifests signed off by the disposal facility and all receipts <br /> used in a consolidated manifesting procedure on site for three years and have them readily available for review. <br /> Immediately locate a copy of all manifests and receipts for the last three years, maintain them on site, and submit <br /> copies to the EHD. <br /> Violation#113 -Failed to keep copies of consolidated manifesting receipts for three years. <br /> Copies of hazardous waste disposal records for used oil prior to August 2014 were not found on site. Hazardous <br /> waste generators shall retain copies of all manifests signed off by the disposal facility and all receipts used in a <br /> consolidated manifesting procedure on site for three years and have them readily available for review. Immediately <br /> locate a copy of all manifests and receipts for the last three years, maintain them on site, and submit copies to the <br /> EHD. <br /> Violation#605-Failed to completely label containers or tanks of hazardous waste. <br /> A 55 gallon black steel drum of absorbent was observed with no accumulation start date and a hazardous property <br /> of"other." A 55 gallon blue poly drum of oily solids was observed with no hazardous property and no accumulation <br /> start date. A 55 gallon black steel drum of absorbent was observed with only the contents labeled. Two 55 gallon <br /> black steel drums of used oil were observed with no hazardous property or physical state listed. All hazardous <br /> waste containers shall be marked with the following information: <br /> -the words"Hazardous Waste" <br /> -name and address of generator <br /> -hazardous properties (ignitable, corrosive, reactive, toxic) <br /> -physical state(liquid, solid) <br /> -composition (contents) <br /> -accumulation start date <br /> Immediately label these containers and ensure that all hazardous waste containers are marked with all the required <br /> information. <br /> Page 1 of 2 <br />