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RECEIVED 10/01/2021 VIA EMAIL RCRA Large Quantity Hazardous Waste Generator Inspection Report Violations Response Heartland Steel 214 S Kelly St. Lodi CA Violation Response Item #102, CCR 66262.11: Failed to Contacted manufacture of the cartridge paint filters and determine if a waste is a hazardous waste. inquired about disposable process of the filters. The filters OBSERVATIONS: Hazardous waste themselves do not process any hazardous material and can determinations are needed for the following be thrown away with the general trash. The only other items: element is the powder coat paint which is also non- -powder coat stored south of Bay 1. The hazardous and does not list any hazardous chemicals on the following 250 pound containers of powder SDS sheets. Provide supporting documents for the coat were observed: 21 of Excel hazardous waste determination (ex. SDS sheets) Blue, 8 of Lozier Yellow, 6 of Sahara Tan, 6 of (Attached to the email are the manufacture specifications HB2 Blue, 4 of Forest Green, 1 of Muslin for the filter product showing what material is used to make Biege, 8 of Unicor Gray, 6 the filters) of Hannibal Orange, 8 of Lozier Gray, 10 of Provide SDS sheets for the powder coat paint also. Excel Ultra Orange, 6 of SR153 Blue, 6 of SDS sheet for orange paint is attached to the email. Deco Green, and 2 of Vista Green. The half full 55 -gallon drum as be repositioned to the -approximately 300-400 used powder coat hazardous waste shed and labeled accordingly. Provide a filters stored in Bay 8 photo of the drum and label. -3 containers of oily booms & rags stored (The drum was repositioned to the hazardous waste shed north of Bay 4 and was taken on the last pick up with Clean Harbors. Please -1 half full 55 -gallon drum of metal grindings see attached photo showing the drum is no longer in Bay 1.) stored south of Bay 1 Provide disposal record. Attached is the disposal record showing that the drum was picked up along with 7 other drums of metal shavings on 09/16/2021 Item #118, CCR 66265.16: Failed to maintain Safety and Hazardous waste training has been given to complete hazardous waste training records. Heartland's staff on 08/24/2021 OBSERVATION: The business operator could not The training records provided did not list the job titles and produce documentation during the inspection job descriptions for each employee. The inspection report that demonstrates employees have completed provided states, "The documentation must include a list of hazardous waste training annually. Only one training topics, date of training, job title, name of employee, employee, Muhammad Javaid, signed a training Written job description (qualifications and duties), and sheet dated 07/22/2021. employee signed (or certified) record that documents the training." (There were two groups that were trained on the 08/24/2021. Each group received both basic safety and hazardous waste training. One smaller group received a more in depth training on proper handling of hazardous waste on site. Attached is the training record in which the those who are involved with hazardous waste we properly trained topics listed. Each person that is involved are all forklift drivers. The training record description has been revised to show that.) The training record is still missing the written job description (qualifications and duties).