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R E C!=_'�V E D <br /> AUG d 2016 <br /> This is a Class 11 violation. <br /> BN1 IROiNMEN TAL <br /> Owens' Response/Corrective Action: <br /> HEALTH OEPARTMEENT <br /> Training on hazardous waste management and emergency response <br /> procedures has been completed. Training logs are attached as Exhibit 2 to <br /> this letter. <br /> Manifests <br /> Item 113: CCR 66262.20 Failed to prepare manifests for transportation of hazardous waste <br /> 22.5 Metric Tons (M) of"NA3077 Hazardous Waste, Solid, NOS, (cadmium, chromium, lead), <br /> 9, PG III",waste tracking number 010315-28 and 20.3 M of "NA3077, Hazardous Waste, Solid, <br /> NOS, (cadmium,chromium, lead),9, PG 111" waste tracking number 010315-29 was transported <br /> off site for disposal on August 3rd, 2015 without first preparing a uniform hazardous waste <br /> manifest. Uniform hazardous waste manifest 007708748JJK (20T) and 007708749JJK (18Y) <br /> were generated later. It appeared that 010315-28 corresponded to 007708749JJK and <br /> 010315-29 corresponded to 007708748JJK. <br /> A generator shall prepare a Uniform Hazardous Waste Manifest on EPA Form 8700-22 prior <br /> to the transport of a hazardous waste for off-site transfer, treatment, storage or disposal. <br /> Ensure that a manifest is prepared each time hazardous waste is transported for offsite <br /> transfer, treatment, storage or disposal. Submit written documentation describing the <br /> weight discrepancies noted above and what steps will be taken in the future to ensure <br /> hazardous waste istransported usinga uniform hazardous waste manifest. <br /> ThisisaClassllviolation. <br /> Owens' Response/Corrective Action: <br /> Owens' contractor shipped hazardous waste using non-hazardous waste <br /> manifests 010315-28 and 010315-29; hazardous waste manifests <br /> 007708749JJK and 007708748JJK, respectively, were later completed for <br /> these shipments. Copies of manifests 010315-28, 007708749JJK, 010315-29, <br /> and 007708748JJK are attached as Exhibit 3. Owens now maintains a <br /> number of blank uniform hazardous waste manifest forms onsite in an effort <br /> to prevent a recurrence of this issue. The small weight discrepancy noted on <br /> each manifest is due to the difference in weights measured by scales on the <br /> contractor's front-end loader and weights measured by scales at the landfill. <br /> Item 116: CCR 66262.40(a) Failed to keep signed copy of manifests from the designated <br /> facility for three years. <br /> 4 <br />