Respondent failed to:
1. Conduct an adequate hazardous waste determination on non-empty aerosol cans & a solvent and failed to determine if the waste solvent exhibits any of the characteristics identified in 40 CFR 261Subpart C,
2. Label used oil ASTs and one used oil storage container with the words used oil ,
3. Clean up and properly manage released used oil and other materials, and
4. Ensure that used oil is transported only by a transport that has obtained an EPA ID number.
Respondent shipped off-spec used oil to a burner who did not have an EPA ID number and failed to ensure the used oil is burned in an industrial furnace or boiler.