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The following is an itemized list of hazardous waste violations that have not been <br />addressed for UFP Thornton LLC as of February04, 2021. <br />Open violations from December 03, 2020 inspection <br />oil filters were handled. Copies of bills of lading shall be kept for a period of three years. <br />CORRECTIVE ACTION: Immediately obtain all missing bill of lading recycling records that can be found. Used <br />metal oil filters not stored, handled and disposed of according to this section are regulated as hazardous waste. <br />Provide a corrective action statement, bill of lading recycling records and supporting documentation to the San <br />Joaquin County Environmental Health Department (EHD) within 30 days. <br />❑ This violation was corrected <br />❑ Supporting documents included <br />❑ This violation will be corrected by (date): <br />Describe actions taken or will be taken to correct violation: <br />Violation #704 - UW handler failed to properly manage universal waste lamps. <br />OBSERVATIOI�t The facility is managing universal waste (UW) lamps in a way that does not prevent a release of <br />waste to the environment. <br />In the hazardous waste storage area: <br />-2 cardboard boxes (each containing approximately 9 lamps) were open <br />-Approximately 1 dozen lamps were stacked on a rack and were not in a container <br />REGULATION GUIDANCE: <br />(b) Lamps (including M003 wastes that contain lamps). A universal waste handler shall manage lamps in a way that <br />prevents releases of any universal waste or component of a universal waste to the environment, as follows: <br />(1) A universal waste handler shall contain any lamp in a container or package that is structurally sound, adequate <br />to prevent breakage, and compatible with the contents of the lamp. Such a container or package shall remain <br />closed and shall lack evidence of leakage, spillage or damage that could cause leakage under reasonably <br />foreseeable conditions. <br />(2) A universal waste handler shall immediately clean up and place in a container any lamp that is broken and shall <br />place in a container any lamp that shows evidence of leakage or damage that could cause the release of mercury or <br />other hazardous constituents to the environment. Containers shall be closed, structurally sound, compatible with the <br />contents of the lamps and shall lack evidence of leakage, spillage, or damage that could cause leakage or releases <br />of mercury or other hazardous constituents to the environment under reasonably foreseeable conditions. <br />(3) A universal waste handler may remove a lamp from a product or structure, provided the universal waste handler <br />removes the lamp in a manner designed to prevent breakage. <br />CORRECTIVE ACTION: Immediately place all UW lamps into closed, structurally sound containers with labeling: <br />"universal waste -lamps". Provide a corrective action statement and supporting documentation to the San Joaquin <br />County Environmental Health Department (EHD) within 30 days. <br />❑ This violation was corrected <br />❑ Supporting documents included <br />❑ This violation will be corrected by (date): <br />Describe actions taken or will be taken to correct violation: <br />Page 4 of 6 <br />