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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 #601 - Stored hazardous waste onsite greater than 180 days. <br />Facilities who generate less than 1000 kg of hazardous waste per month and do not exceed 6000 kg of waste <br />stored on site at any time may store waste on site up to 180 days. One blue 55 gallon steel drum containing used oil <br />(1/4 full) was observed with no hazardous waste label. Since it cannot be determined how long the hazardous <br />waste has been on site, immediately contact a licensed hazardous waste hauler to dispose of this waste under <br />manifest. Submit a copy of the manifest to the EHD within 30 days. <br />One used oil tank was observed with an accumulation start date of 12-29-2017. <br />Facilities who generate less than 1000 kg of hazardous waste per month and do not exceed 6000 kg of waste <br />stored on site at any time may store waste on site up to 180 days. Immediately contact a licensed hazardous waste <br />hauler to dispose of this waste under manifest and submit a copy of the manifest to the EHD. <br />Violation #608 - Failed to properly manage used oil and fuel filters. <br />-One black 55 gallon drum containing used oil metal filters and used oil was observed open without a label. <br />-One black and one white 5 gallon plastic bucket was observed containing used oil filters (metal) were observed <br />with open without a label. <br />-One black 55 gallon steel drum containing punctured oil filters was observed without accumulation start date. <br />Used oil filters shall be drained of free-flowing oil, stored in a closed, rainproof container, labeled as "drained used <br />oil filters," and marked with an accumulation start date. Immediately properly drain, label and close the containers. <br />Ensure that all used oil filters are managed in this way. Submit a corrective action statement to the EHD once this <br />has been completed. <br />Bills of lading for the recycling of used oil filters for 2017 were not found on site. A copy of each bill of lading must <br />be kept on site for at least three years. Immediately locate a copy of all bills of lading for used oil filters for the last <br />three years and maintain them on site. Submit copies of the 2017 year to the EHD for review. <br />Open violations from August 12, 2016 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. According to Mr. Maldonado, the employees last received training several <br />years ago and have not been retrained despite hiring several new employees in that time. The generator must <br />ensure that all employees who handle hazardous waste are thoroughly familiar with proper waste handling and <br />emergency procedures. Provide proof of training to the EHD for employees whose responsibilities include <br />hazardous waste. <br />Violation #110 - Failed to keep signed copy of manifests from the designated facility for three years. <br />Copies of uniform manifests for the disposal of hazardous waste for sandblast waste for the last three years were <br />not found on site. During the 2011 and 2012 inspections sandblast waste was observed on site, but no disposal <br />records were found. Hazardous waste generators shall retain copies of all manifests signed off by the disposal <br />facility and all receipts used in a consolidated manifesting procedure on site for three years and have them readily <br />available for review. Immediately locate a copy of all missing manifests and receipts for the last three years, <br />maintain them on site, and submit copies to the EHD. <br />Violation #113 - Failed to keep copies of consolidated manifesting receipts for three years. <br />Copies of all hazardous waste disposal records for used oil were not found on site. The label on the used oil drum <br />indicated at least five disposals occurred which did not have disposal records, including 6/23/16, 3/9/16, and three <br />from 2015. Hazardous waste generators shall retain copies of all manifests signed off by the disposal facility and all <br />receipts used in a consolidated manifesting procedure on site for three years and have them readily available for <br />review. Immediately locate a copy of all manifests and receipts for the last three years, maintain them on site, and <br />submit copies to the EHD. <br />Page 2 of 3 <br />