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The following is an itemized list of hazardous waste violations that have not been addressed for ASSOCIATED TRACTOR SVC INC as of August13, 2018. Open violations from August 12, 2016 inspection Violation #106 - Failed to train employees on waste handling and emergency procedures. At the time of inspection, it could not be demonstrated (not necessarily documented) that employees who handle hazardous waste were properly trained. According to Mr. Maldonado, the employees last received training several years ago and have not been retrained despite hiring several new employees in that time. The generator must ensure that all employees who handle hazardous waste are thoroughly familiar with proper waste handling and emergency procedures. Provide proof of training to the EHD for employees whose responsibilities include hazardous waste. Violation #110 - Failed to keep signed copy of manifests from the designated facility for three years. Copies of uniform manifests for the disposal of hazardous waste for sandblast waste for the last three years were not found on site. During the 2011 and 2012 inspections sandblast waste was observed on site, but no disposal records were found. Hazardous waste generators shall retain copies of all manifests signed off by the disposal facility and all receipts used in a consolidated manifesting procedure on site for three years and have them readily available for review. Immediately locate a copy of all missing manifests and receipts for the last three years, maintain them on site, and submit copies to the EHD. Violation #113 - Failed to keep copies of consolidated manifesting receipts for three years. Copies of all hazardous waste disposal records for used oil were not found on site. The label on the used oil drum indicated at least five disposals occurred which did not have disposal records, including 6/23/16, 3/9/16, and three from 2015. Hazardous waste generators shall retain copies of all manifests signed off by the disposal facility and all receipts used in a consolidated manifesting procedure on site for three years and have them readily available for review. Immediately locate a copy of all manifests and receipts for the last three years, maintain them on site, and submit copies to the EHD. Violation #301 - Facility not maintained to minimize the release of a hazardous waste. Dark, oily staining and saturated absorbent were observed throughout the facility yard on the soil and the concrete. Facilities shall be maintained and operated to minimize the possibility of a fire, explosion, or release of hazardous waste to air, soil, or surface water which could threaten human health or the environment Immediately clean all stained areas, remove all contaminated soil, containerize all saturated absorbent, and manage according to Title 22 hazardous waste regulations. Submit a statement and supporting documentation explaining how this waste was managed. Violation #403 - Failed to keep hazardous waste containers closed except when adding or removing hazardous waste. -A drum of used oil and used oil filters was observed in near the used oil tank with no lid. -According to Larry, the shop employee, metal fines from metal grinding are vacuumed into an open metal bin on site and transferred to a plastic bucket for disposal approximately once a year or as needed. All hazardous waste containers shall be closed at all times except when adding or removing waste. Immediately close these containers and ensure all hazardous waste containers are closed when not adding or removing waste. Violation #601 - Stored hazardous waste onsite greater than 180 days. Facilities who generate less than 1000 kg of hazardous waste per month and do not exceed 6000 kg of waste stored on site at any time may store waste on site up to 180 days. -A 55 gallon blue and white steel drum and a white poly drum of used antifreeze were observed behind the shop with no accumulation start dates; a label on the secondary containment listed the accumulation start date 5/14/15. The most recent disposal records on site for used antifreeze are dated 5/14/15. -According to Larry, the shop employee, metal fines from metal grinding are vacuumed into an unlabeled metal bin on site and transferred to a plastic bucket for disposal approximately once a year or as needed. The disposal records on site indicate metal fines were hauled away on uniform manifests on 8/10/16 and 2/12/14. Since it cannot be determined how long the hazardous waste antifreeze has been on site, immediately contact a licensed hazardous waste hauler to dispose of this waste under manifest. Submit a copy of the manifest to the EHD within 30 days. Page 4 of 5