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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 October16, 2018. <br />Open violations from July 05, 2018 inspection <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 #301 - Facility not maintained to minimize the release of a hazardous waste. <br />Oily staining and oil saturated absorbent were observed throughout the facility yard and the maintenance shops. <br />Metal fines were observed in front of three drill presses. The manager stated that the waste was going to be <br />disposed of as hazardous waste. Facilities shall be maintained and operated to minimize the possibility of a fire, <br />explosion, or release of hazardous waste to air, soil, or surface water which could threaten human health or the <br />environment. Immediately clean the staining, and manage according to Title 22 hazardous waste regulations. <br />Submit a statement and supporting documentation explaining how this waste was managed. <br />Violation #403 - Failed to keep hazardous waste containers closed except when adding or removing <br />hazardous waste. <br />Facility Yard: <br />-One 5 gallon metal pan containing used oil (90 percent full) was observed with no lid. <br />-One blue. 55 gallon steel drum containing used oil (1/4 full) was observed with no lid. <br />Facility Shop: <br />-One steel drip pan next to a drill press containing used oil (1/4 full) was observed with no lid. <br />-One blue 5 gallon plastic bucket containing used oil (1/3 full) was observed with no lid. <br />All hazardous waste containers shall be closed at all times except when adding or removing waste. Immediately <br />close these containers and ensure all hazardous waste containers are closed when not adding or removing waste. <br />Page 1 of 3 <br />