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The following is an itemized list of hazardous waste violations that have not been addressed for UFP Thornton LLC as of February04, 2021. Open violations from December 03, 2020 inspection Violation #608 -Failed to properly manage used oil filters or fuel filters. OBSERVATION 1: Containers of used metal oil filters out of compliance with the storage rules were observed on-site. In the hazardous waste storage area: One black 55 gallon steel drum containing drained metal filters was missing the accumulation start date and the words "drained used oil filters." One black 55 gallon steel drum containing drained metal filters was missing the accumulation start date. REGULATION GUIDANCE: (b) "used oil filters" are defined as filters which contain a residue of used oil and which are exempt from regulation as a hazardous waste under the scrap metal provision found in federal law. (c) Used oil filters that meet the conditions of subsection (b) of this section and are managed and recycled in compliance with the following requirements shall not be regulated as hazardous waste. (1) The filters are drained of free-flowing used oil. For the purposes of this subsection, free-flowing is defined as a continuous stream of oil exiting the filter when the filter is inverted. Oil exiting drop by drop is not considered to be free-flowing. However, if the filter is equipped with a device (such as a rubber flap located just inside the filter opening) which impedes the drainage of used oil from the filter, that device shall be manipulated to allow the oil to exit the filter freely, or the filter punctured, crushed, opened, drained, or otherwise handled in a manner that will allow the used oil to exit the filter. (2) The drained used oil filters are transported for purposes of metal reclamation to any of the following: (A) A smelter or other scrap metal processor where they are recycled or; (B) A storage facility or consolidation facility that subsequently transfers the filters to a facility described in paragraph (A) or (C) of this subsection or; (C) A municipal solid waste incinerator for energy recovery, if the residual casings are subsequently transferred to a facility described in paragraph (A) of this subsection, or to a storage or consolidation facility that subsequently transfers the residual casings to a facility described in paragraph (A) of this subsection. (3) The drained used oil filters are accumulated, stored, and transferred in a closed, rainproof container that is capable of containing any used oil that may separate from the filters placed inside. Drums of used oil filters shall be sealed during transfer so that used oil will not spill out when they are laid upon their sides. Drums shall be secured as a load to prevent movement or tipping during transfer. Containers shall be labelled as "drained used oil filters" (not as hazardous waste) and show initial date of accumulation or receipt on each container of filters. (4) Storage of less than one ton of used oil filters shall be limited to one year. Storage of one ton or more of used oil filters is limited to 180 days. (5) Persons generating, transporting, or receiving used oil filters shall use a bill of lading to record the transfer of used oil filters. Bills of lading must indicate generator, transporter, and receiving company names, addresses, telephone numbers, the quantity and size of used oil filter containers transferred, and the date of transfer. A copy of each bill of lading must be kept on the premises of the generator, transporter, and receiving facility where the used oil filters were handled. Copies of bills of lading shall be kept for a period of three years. CORRECTIVE ACTION: The labeling was corrected during the inspection. Since it is unknown how long the filters have been on site, have the filters disposed of, or submit records showing how long the filters have been on site. Used oil filters not stored, handled and disposed of according to this section are regulated as hazardous waste. Provide a corrective action statement, disposal records and supporting documentation to the San Joaquin County Environmental Health Department (EHD) within 30 days. OBSERVATION 2: This facility generates drained used metal oil filters. Acomplete three year bill of lading record for used oil filter recycling was not observed during the inspection. Bills of lading were not observed for the following date range: 12/3/2017-12/3/2020. REGULATION GUIDANCE: Persons generating, transporting, or receiving used metal oil filters shall use a bill of lading to record the transfer of used oil filters. Bills of lading must indicate generator, transporter, and receiving company names, addresses, telephone numbers, the quantity and size of used oil filter containers transferred, and the date of transfer. A copy of each bill of lading must be kept on the premises of the generator, transporter, and receiving facility where the used Page 3 of 6