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Three fuel/oil filters were stored on top of a hazardous waste drum. Used oil/fuel filters must be stored <br />in a closed, rainproof container, labeled as "drained used oil and fuel filters," and marked with an <br />accumulation start date. Immediately place the filters in a container and label. Ensure that all used <br />oil/fuel filters are managed in this way. Recycle these filters under a bill of lading within one year of <br />generation or handle as hazardous waste. We confirmed with our dealer that the fuel/oil filters were placed <br />in the solid hazardous waste drum. The drum was removed by an authorized hauler on April 18, 2011. A copy <br />of the manifest is attached for your review and records. <br />Two empty 55 -gallon hazardous waste drums were observed onsite without "empty" labeling. <br />Containers larger than five gallons that previously held a hazardous material shall be marked with the <br />date they were emptied and managed within one year of being emptied. Immediately mark and <br />manage all empty containers per this section. On April 19, 2011, we confirmed with our dealer that the <br />word "empty" has been added to the labels of the one solid and one liquid hazardous waste drum that are on <br />site. <br />Three 55 -gallon partially full hazardous waste drums were observed on site. The accumulation dates on <br />the drums were 10-9-07, 9-23-09 and 1-20-08. The accumulation dates are greater than 180 days prior to <br />today. Facilities who generate less than 1000 kg of hazardous waste per month and do not exceed 6000 <br />kg of waste stored on site at any time may store waste on site up to 180 days. Immediately contact a <br />licensed hazardous waste hauler to dispose of this waste under manifest and submit a copy of the <br />manifest to the EHD by May 5, 2011. These hazardous waste drums were removed by an authorized hauler <br />on April 18, 2011. A copy of the manifest is attached for your review and records. <br />It is our policy to address deficiencies, issues of concern, and/or agency requests regarding our retail <br />facilities immediately. With the submittal of this letter, it is our understanding that the item(s) of alleged <br />non-compliance has been resolved. If this is not correct, please contact me as soon as possible. <br />If you have any questions or require additional information, please contact me. <br />Regards, <br />Richard C. Gossett <br />Environmental Compliance Specialist <br />Enclosure(s) <br />Page 2 of 2 <br />