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• A quick reference guide is posted on/near the machinery that was identified during the inspection to assist the maintenance team in the proper handling and disposal of metal shavings produced onsite (EXHIBIT B). • The DC West Coast Regulatory Compliance Specialist conducted an informal training/education session onsite with members of the Maintenance Department on 06/24/2020 so as to educate associates on the proper handling & disposal of metal shavings produced onsite. • The subject of"Metal Shavings" as a potential source of hazardous waste will be incorporated into the upcoming revision of the Hazardous Waste Management Program "PowerPoint" training. The newly revised training module is slated for completion by 08/01/2020. o The DC West Coast Regulatory Compliance Specialist will thereafter conduct formal additional onsite training at DC 4. • Item #103 — CCR 66262.40 ( c ) — Failed to retain hazardous waste determination including waste analysis on site for 3 years. o CORRECTIVE ACTION: ■ Hazardous Waste Determination—Products Without Labels • If the product label is missing, associates are instructed to scan an exact duplicate "viable/good"item in order to make a proper waste determination. o CORRECTIVE ACTION: ■ Hazardous Waste Determination—Products Do Not Scan • If associates are unable to scan a particular product with the (RF) device, they are instructed to determine the proper waste category by utilizing a printed copy of the "DC Hazardous Waste Category Guide". o A copy of the guide is available at the accumulation station(EXHIBIT Q. o CORRECTIVE ACTION: ■ Manifest Correction (012496412FLE)provided by Stericycle (EXHIBIT D). • Item#104-HSC 25244.19,25244.21 -Failed to adequately complete a Source Reduction plan and have it available for review. OBSERVATION: This facility, a large quantity generator, does not have a complete current source reduction plan on site for the year 2018. o CORRECTIVE ACTION: ■ Enclosed please find the Source Reduction Plan for 2018 (EXHIBIT E). • Item #106 - CCR 67100.7, 67100.8 - Failed to prepare and maintain a Performance Report every four years, when required. OBSERVATION: This facility, a large quantity generator, does not have a complete hazardous waste management performance report on site for the year 2018. o CORRECTIVE ACTION: 0 Enclosed please find the Management Performance Report(EXHIBIT F).