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m Kasey Foley [EH] From: Kasey Foley [EH] Sent: Monday, October 11, 2010 2:47 PM To: ryan.egan@primecre.com' Cc: Michelle Henry [EH]; Willy Ng [EH] Subject: Brakemasters 1210 Tracy Blvd a] Hi Ryan, I have reviewed the hazardous waste inspection report and all documents provided and am sending you this synopsis of what is still needed. Violation #7- (CCR 66262.11) Failed to determine if a waste is a hazardous waste for: • 1-30 gallon drum with a preexisting ZEP writing on it • 1-55 gallon drum approximately 1/3 full of an orangish liquid Both of the drums above were identified as unknown by the facility manager so your response "All containers that stored hazardous waste have been properly labeled with the necessary label listing both its contents and the date last emptied." does not correct the violation. In order to properly label the containers the contents of the container must be known, then a hazardous waste determination must be made, only then can it be labeled. Then, as the inspection report spells out, it must be hauled by a registered hazardous waste hauler within 30 days of receiving the inspection report due to the fact that there is no way to know the initial date of accumulation because there was no label. Then a copy of the hazardous waste manifest must be submitted to this office for that specific waste. If the waste was determined to be non -hazardous then you must provide the method used to make that determination. Violation #11 -(CCR 66265.31) Facility not maintained to minimize a release of a hazardous waste for: • Metal fines from brake lathe on ground and in open containers • Catch pan full of oily liquid • Ground saturated with oily liquid in the hazardous waste storage area The area needs to be cleaned up then the waste must be properly disposed of by a registered hazardous waste hauler. Your response describes proper training and cleaning but no discussion of how the waste was handled and no copy of a manifest for that waste. Violation #20 [CCR 66262.34(f)] Failed to completely label containers of hazardous waste for: • 1-55 gallon drum of absorbent and 1-30 gallon drum of absorbent both were lacking initial date of accumulation and hazardous properties • 3 open container of brake fines without a hazardous waste label Your response referenced violation #11 that all containers were properly labeled. The response we are looking for should reference each container that was in violation and how the specific violation was corrected. This can be done by providing a photograph of each drum with the corrected label evident in the photo showing the words "Hazardous Waste", the generator's name and address, the contents of the container, the physical state of the hazardous waste, the hazardous properties, and the accumulation start date. Violation #27 [CCR 66265.173(a)] Failed to keep containers of hazardous waste closed unless actively adding or removing the waste for 3 containers of brake fines. Your response was that lids were placed on all containers storing hazardous waste. The response should reference the specific containers in violation and a photograph could help to illustrate what was done. Violation #50 [CCR 66262.34(d)] Stored waste onsite greater than 180 days for: 1-55 gallon drum of absorbent and 1-30 gallon drum of absorbent both were lacking initial date of accumulation You responded that all hazardous waste found during the inspection has been removed. The response required copies of manifests for all hazardous waste that was removed offsite by the hazardous waste hauler but so far the