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This is a Class II violation. V l_ d j zoos ENV I Iif.?NMi=N"IAL ATH UEP/1FiI"fVIENT Owens' Response/Corrective Action: HE Training on hazardous waste management and emergency response procedures has been completed. Training logs are attached as Exhibit 2 to this letter. Manifests Item 113: CCR 66262.20 Failed to prepare manifests for transportation of hazardous waste. 22.5 Metric Tons (M) of "NA3077 Hazardous Waste, Solid, NOS, (cadmium, chromium, lead), 9, PG III",waste tracking number 010315-28 and 20.3 M of "NA3077, Hazardous Waste, Solid, NOS, (cadmium, chromium, lead), 9, PG III" , waste tracking number 010315-29 was transported off site for disposal on August 3rd, 2015 without first preparing a uniform hazardous waste manifest. Uniform hazardous waste manifest 007708748JJK (20T) and 007708749JJK (18Y) were generated later. it appeared that 010315-28 corresponded to 007708749JJK and 010315-29 corresponded to 007708748JJK. A generator shall prepare a Uniform Hazardous Waste Manifest on EPA Form 8700-22 prior to the transport of a hazardous waste for off-site transfer, treatment, storage or disposal. Ensure that a manifest is prepared each time hazardous waste is transported for offsite transfer, treatment, storage or disposal. Submit written documentation describing the weight discrepancies noted above and what steps will be taken in the future to ensure hazardous waste istransported using uniform hazardous waste manifest. This is a Class Ilvio lotion. Owens' Response/Corrective Action: Cttivens' contractor shipped hazardous waste using non -hazardous waste manifests 010315-28 and 010315-29; hazardous waste manifests 007708749JJK and 007708748JJK, respectively, were later completed for these shipments. Copies of manifests 010315-28, 007708749JJK, 010315-291 and 007708748JJK are attached as Exhibit 3. Owens now maintains a number of blank uniform hazardous waste manifest forms onsite in an effort to prevent a recurrence of this issue. The small weight discrepancy noted on each manifest is due to the difference in weights measured by scales on the contractor's front-end loader and weights measured by scales at the landfill. Item 116: CCR 66262.40(a) Failed to keep signed copy of manifests from the designated facility for three years.