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0 0 <br /> Waste identification,proper storage,and disposal procedures were reviewed with Production Staff <br /> on June 28, 2018 to remind staff of the importance in properly managing the household chemicals <br /> and materials encountered in the vehicles. A copy of the training sign-in sheet is provided in <br /> Attachment 4. <br /> It was also observed that a waste shipment of soaps and surfactants was inadvertently shipped out <br /> as a non-hazardous waste when it should have been disposed of as a non-RCRA hazardous waste <br /> per the current waste profile approved for that waste type. This oversight was discussed with the <br /> waste contractor to clarify the confusion and ensure that these wastes will no longer be disposed <br /> of as a non-hazardous waste. All soaps and surfactant types of household wastes will be disposed <br /> of as a non-RCRA hazardous waste. <br /> Minimizing Release of Hazardous Waste-#301 <br /> During the inspection, oil staining was observed on the ground throughout the facility, three <br /> vehicles were noted as actively leaking, coolant was observed in a vehicle bumper, oil was spilled <br /> and dripped onto a tire by a customer at the Customer Return Area, empty containers were not <br /> properly placed in their designated storage containers, and oil and dirt were observed around the <br /> drains at the Drain Building. <br /> Vehicles are drained of fluids to the extent practical but cannot be drained completely dry. This <br /> can lead to minor releases of vehicle fluids throughout the Site, as was observed during the <br /> inspection. Best management practices (BMPs) to address minor spills and releases are <br /> implemented on a continuous basis by Site staff. When Customers remove parts from vehicles, <br /> residual fluids remaining in some of the vehicle parts can also be released. Several best <br /> management practices (BMPs) are in place to address these minor spills as was explained by the <br /> Store Manager during the inspection. For example,gravel is placed throughout the facility to limit <br /> oil from having direct contact with the ground, and scrap carpet/mats/oil absorbent pads are used <br /> throughout the Site to capture minor spills. Oil stained gravel is removed and replaced when <br /> vehicle rows are cleared and areas can be accessed more easily and safely. Minor oil staining that <br /> was observed during the inspection has been properly cleaned up in accordance with Site BMPs <br /> and applicable regulations. Vehicle fluids are disposed of as non-RCRA hazardous wastes. Gravel <br /> and used absorbent are tested for waste profiling and disposed of as a non-hazardous waste. In <br /> addition, the waste is not disposed of with regular municipal waste but separated and disposed of <br /> offsite at a designated waste facility. Manifests for recent shipments of these wastes are provided <br /> in Attachment 2. Photographs of the cleaned up areas related to the observations noted in the <br /> inspection report are provided in Attachment 3. <br /> Maintaining Spill Control and Response Equipment-#303 <br /> During the inspection, eyewash stations were observed to not be replenished after use and <br /> secondary containment for used oil and coolant at the Drain Building had some oil inside. The <br /> eyewash stations were maintained and replenished and secondary containments cleaned. <br /> Requirements to properly maintain eyewash stations and secondary containment were reviewed <br /> Page 4 of 6 <br /> StocktonInsp Response 20180726 <br />