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The following is an itemized list of hazardous waste violations that have not been <br />addressed for ASSOCIATED TRACTOR SVC INC as of August13, 2018. <br />Open violations from July 05, 2018 inspection <br />Violation #102 - Failed to determine if a waste is a hazardous waste. <br />-One blue 5 gallon plastic bucket was observed containing oily rags. The manager stated that the material was a <br />waste. Any person who generates a waste shall determine if the waste is a hazardous waste. Immediately, make a <br />hazardous waste determination for the oily rags, and manage it according the Title 22 hazardous waste regulations. <br />Submit a statement and supporting documentation explaining how this waste was managed. <br />Violation #104 - No modified contingency plan. <br />An emergency coordinator and modified contingency plan information is lacking. There must be at least one <br />emergency coordinator on site or on call to coordinate emergency response measures, and the following <br />information must be posted by a phone: the name and phone number of the emergency coordinator; location of fire <br />extinguishers, spill control equipment, and if present, fire alarm; and the phone number of the fire department, <br />unless the facility has a direct alarm. Immediately appoint an emergency coordinator and post the required <br />information by a phone. A form is provided that can be used for this purpose. <br />Violation #106 - Failed to train employees on waste handling and emergency procedures. <br />At the time of inspection, it could not be demonstrated (not necessarily documented) that employees who handle <br />hazardous waste were properly trained. The manager stated that complete hazardous waste training for the new <br />employees has not been given yet. The generator must ensure that all employees who handle hazardous waste are <br />thoroughly familiar with proper waste handling and emergency procedures. Provide proof of training to the EHD for <br />employees whose responsibilities include hazardous waste. <br />Violation #110 - Failed to keep signed copy of manifests from the designated facility for three years. <br />Disposal records for the 2017 year for metal shavings were not available for review during the inspection. The <br />manager stated that he was not sure if metal shavings were taken out that year. <br />During the 2011 and 2012 inspections, sandblast waste was observed on site, but no disposal records were found. <br />Hazardous waste generators shall retain copies of all manifests signed off by the disposal facility and all receipts <br />used in a consolidated manifesting procedure on site for three years and have them readily available for review. <br />Immediately locate a copy of all manifests and receipts for the last three years, maintain them on site. Submit <br />copies of the missing records to the EHD. <br />Violation #113 - Failed to keep copies of consolidated manifesting receipts for three years. <br />2017 disposal records for used antifreeze were not available for review during the inspection. <br />2016 and 2015 records for used oil were not available for review during the inspection. <br />Hazardous waste generators shall retain copies of all manifests signed off by the disposal facility and all receipts <br />used in a consolidated manifesting procedure on site for three years and have them readily available for review. <br />Immediately locate a copy of all manifests and receipts for the last three years and maintain them on site. Submit <br />copies of the missing records listed above to the EHD for review. <br />Violation #117 - Failed to submit a written response within 30 days of receiving an inspection report. <br />An inspection was last done on 8/12/2016 and an inspection report was issued identifying information to be <br />submitted to bring this site into compliance. This information was required to be submitted by 9/11/2016. This <br />information has not been received resulting in a non-compliant status for this facility. An operator that receives an <br />inspection report shall have 30 days to submit a written response that includes a statement documenting corrective <br />actions taken or proposing corrective actions which will be taken. Ensure that a written response documenting <br />corrective actions taken or proposed is submitted within 30 days of receiving an inspection report. <br />Page 1 of 5 <br />