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trained in the operation and maintenance of equipment to prevent discharge procedure protocols, applicable pollution control laws, rules & regulations, general facility operations and the contents of the facility's SPCC plan. Annual briefings must be conducted to assure adequate understanding of the SPCC Plan and highlight and describe any known discharges or failures, malfunctioning components and any recently developed precautionary measures. Solution to Violation # 32: We have conducted the necessary training with all oil handling personnel using the old SPCC; please see attached training record sheet. Furthermore, we will train our associates again when ERM completes and certifies the SPCC plan. Violation # 50: Liquid level sensing devices have not been tested. Liquid level sensing devices must be installed in accordance with 40 CFR 112.8 and shall be regularly tested to ensure proper operation. Solution to Violation # 50: ERM is scheduled to conduct liquid level sensing device test during the integrity test on July 20, 2011. Violation # 60, 61, 62: Manifest number 004907846JJK (1/21/10) and 003336135JJK (3/3/10) were not found on site. Hazardous waste generators shall retain copies of all manifests for three years or until a copy signed off by the destination facility is received. The signed off copy shall be retained and made readily available for review for three years. If the generator did not receive a copy of the manifest with the handwritten signature of the owner or operator of the facility to which the generator's waste was submitted within 35 days of the date the waste was accepted by initial transporter, the generator shall contact the transporter and/ or the owner operator of the designated facility to determine the status of the waste. If the generator did not receive a copy of the manifest with the handwritten signature of the owner or operator of the facility to which the generator's waste was submitted within 60 days of the date the waste accepted by the initial transporter, the generator shall submit a legible copy of the missing manifest, with some indication that the generator has not received confirmation of delivery. Solution to Violation # 60, 61, 62: The manifest number 004908463JK was located after the audit, attached is the signed manifest. A copy of manifest number 0033361JJK and the letter to DTSC are attached. If you have any questions or concerns, please feel free to contact myself at 209-587-2315. We will also mail you a copy for your convenience. We are looking forward to resolving our violations and we will follow up with you upon ERM's completion of the SPCC plan and integrity tests, thank you.