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The following is an itemized list of hazardous waste violations that have not been addressed for ASSOCIATED TRACTOR SERVICE INC as of October16, 2018. Open violations from August 27, 2018 inspection Violation #608 - Failed to properly manage used oil and fuel filters. Bills of lading for the recycling of used oil filters for the last three years were not found on site. A copy of each bill of lading must 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 three years, maintain them on site, and submit copies to the EHD. A metal used oil filter was observed laying on a shelf. Used oil filters shall be drained of free-flowing oil, stored in a closed, rainproof container, labeled as "drained used oil filters," and marked with an accumulation start date. Immediately properly handel the used oil filter and ensure that all used oil filters are managed in this way. Open violations from August 12, 2016 inspection Violation #101 - Managed a hazardous waste without an identification number. This facility does not have a valid ID number to manage hazardous waste. A hazardous waste generator shall not treat, store, dispose of, transport or offer for transportation, hazardous waste without an ID number. If you or your business generates more than 100 kg of RCRA hazardous waste and/or more than one kg of acutely hazardous waste, then you need to obtain an EPA ID number. All others must obtain a State ID number. Go to the DTSC web site http://www.dtsc.ca.gov/IDManifest/PERMHWID.cfm for the form to apply for an ID number. Immediately obtain an ID number to manage hazardous waste and submit evidence to the EHD. Violation #102 - Failed to determine if a waste is a hazardous waste. -Two 55 gallon drums of an unknown, gray, solid waste were observed next to the shop. -A 55 gallon yellow steel drum half full of liquid and solids was observed next to the shop. No hazardous waste determination has been made for this waste. Any person who generates a waste shall determine if the waste is a hazardous waste. Immediately make a hazardous waste determination for the these wastes, and manage them according the Title 22 hazardous waste regulations. Submit a statement and supporting documentation explaining how this waste was managed. Violation #104 - No modified contingency plan. An emergency coordinator and modified contingency plan information is lacking. There must be at least one emergency coordinator on site or on call to coordinate emergency response measures, and the following information must be posted by a phone: the name and phone number of the emergency coordinator; location of fire extinguishers, spill control equipment, and. if present, fire alarm; and the phone number of the fire department, unless the facility has a direct alarm. Immediately appoint an emergency coordinator and post the required information by a phone. A form is provided that can be used for this purpose. Violation #106 - Failed to train employees on waste handling and emergency procedures. At the time of inspection, it could not be demonstrated (not necessarily documented) that employees who handle hazardous waste were properly trained. According to Mr. Maldonado, the employees last received training several years ago and have not been retrained despite hiring several new employees in that time. The generator must ensure that all employees who handle hazardous waste are thoroughly familiar with proper waste handling and emergency procedures. Provide proof of training to the EHD for employees whose responsibilities include hazardous waste. Violation #113 - Failed to keep copies of consolidated manifesting receipts for three years. Copies of hazardous waste disposal records were not found on site. Hazardous waste generators shall retain copies of all manifests signed off by the disposal facility and all receipts used in a consolidated manifesting procedure on site for three years and have them readily available for review. Immediately locate a copy of all manifests and receipts for the last three years, maintain them on site, and submit copies to the EHD. Page 3 of 4