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0 • • Page 5 September 18, 2012 Reference Summary of violations narrative 06/26/12 inspection report 101 Wrong EPA No.used 103 No valid EPA No. When it was learned that an EPA number did not exist and was necessary for disposal of Waste Filters, Used Antifreeze and Used Oil an EPA number, CAL000368693 was issued to the Imperial Truck Wash &Repair business and facility at 2142 West Yosemite Ave. in Manteca, CA.Previousl EPA No was assumed to be valid for this address by waste hauler. Actual date when the"correct EPA number was first used is not readily determinable as all records up to the 26 June 12 search warrant were seized by San Joaquin County. Available disposal records since that date have been summarized and are on file at Imperial Truck Wash. They are summarized in Addendum#1 with a sample copy attached. A representative of the facility now reviews the disposal receipts prior to signing the document. 108 Determine if waste is hazardous waste Several containers of waste were discovered during the 26 June 12 inspection.These included: 1. In truck wash bay-Two approximately 20 gallon open metal drums, one blue and one brown leaky drum of oily sludge.Waste material was transferred to a labeled 55 gallon, 3 ring, metal lid has bolted locking retainer.Addendum#2,Laboratory analysis attached indicates that waste solids in the two troughs(the source)may be marginally hazardous. pH was 6.99,flashpoint was above 140°F, Waste is being accumulated for documented disposal within 90 days of accumulation starting date(26 Jun 12), disposal is required by 23 Sep 12. Asbury Environmental Services will pickup. 2. In truck wash bay-A 55 gallon poly blue open drum of oily debris, dark ashes, broken wooden pallet debris, along with waste food.Waste may be hazardous, it was transferred to a labeled 55 gallon, 3 ring, metal lid has bolted locking retainer disposal is required by 23 Sep 12. Asbury Environmental Services will pickup. 3. Outside, in front of the used oil change bay-A 55 gallon open metal drum, black has a dark liquid appears to be used oil along with trash.Trash was separated from used oil and will be disposed as hazardous waste. Used oil has been transferred to used oil tank for proper disposal. Disposal of oil contaminated trash as hazardous waste is required by 23 Sep 12.Asbury Environmental Services will pickup. 4. In southeastern interior corner at the rear of the used oil change bay-In a 20 gallon open blue metal drum and a 5 gallon bucket is a dark green liquid without an identifying label. This is solvent and used oil accumulated daily while washing oil change items. Rather than waste diesel solvent on a daily basis the containers are covered when not in use and allowed to accumulate waste oil and grit. Material is considered hazardous, containers are labeled and material is treated as waste oil at the discretion of service person by rinsing through drain oil catch pan and pumping to the waste oil tank for recycling. 5. Outside, in front of the used oil change bay, in a 55 gallon open drum there are two corn oil containers that have dark black oily residues. Material was rinsed out with diesel solvent, containers were allowed to dry and placed in trash bin. Disposal of used containers was reviewed in training meeting. 6. In the Garbage Only, Non-Hazardous Waste dumpster at the rear of the truck wash bay was a Lucas Heavy duty Oil stabilizer with a cup of oil-oil was recovered and is now drained from similar containers in the used oil change bay. Residual in similar containers is allowed to drain fully and disposed as waste oil or reclaimed for shop use. A low VOC brake cleaner aerosol can, not empty was discovered. It was completely emptied and placed in a labeled steel hazardous materials accumulation drum for future reclamation.