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11 <br />September 20, 2010 <br />Page 3 of 4 <br />85. No records were available for disposal of universal wastes. Per facility contact, the <br />universal wastes are hauled to the main City of Tracy facility for handling and disposal, <br />are taken to the household hazardous waste facility for disposal, or are taken to <br />universal waste drop off sites. A generator shall keep a record of each shipment of <br />universal waste on site for at least three years. This record may take the form of a log, <br />invoice, manifest, bill of lading, or other shipping document, and shall include the <br />following: <br />- Name and address of destination facility <br />- Quantity of each type of universal waste <br />- Date of departure <br />Disposal at the household hazardous waste facility in Stockton and at other drop off <br />sites must be done as a business. Begin this practice immediately. Ensure that all <br />universal waste disposals are done as a business, under the business name and EPA <br />ID number. <br />RESPONSE: <br />1, Maintenance personnel have verified the only universal waste generated by this <br />facility is re -usable shop towels that are picked up for laundering by an industrial laundry <br />service. <br />2. Used shop towels are stored in a suitably labeled container. <br />3. Shop towels are typically used only for general wiping of parts or hands. <br />is Only low-voc and non chlorinated cleaning products are used at this facility. <br />Note: (corrected on site) <br />- No modified contingency plan was available on site. <br />RESPONSE: <br />1, A plan was completed and posted at time of inspection. <br />Note: <br />- The tenant in the main office, Sky View, has been performing vehicle and equipment <br />maintenance'and using the used oil tank at this facility for disposal. Per facility contact, <br />Sky View is not associated with Tracy Municipal Airport and all future waste disposal w <br />be separated for the two facilities. As such, Sky View will be added as a separate <br />hazardous waste generator. Facility contact identified a storage building, a workshop, <br />and a mobile refueler as under the control of Sky View. None of these areas were <br />included in this inspection. <br />RESPONSE: <br />1. none <br />Think Inside the Triangle"'�—,,,�', <br />