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0 6 <br /> According to my reading of 22 CCR §66265.174, there is no requirement to maintain a log of weekly <br /> inspections, merely to conduct them. In this case, the site appears to have conducted the required <br /> inspections, and to have regularly recorded them in multiple places in their Orange Binder <br /> compliance records, except for the aforementioned three (3)week period in June 2013, where they <br /> were only recorded in one location. However, as 22 CCR §66265.174 does not actually specify any <br /> recording requirement, the recordation of each date of inspection in the Orange Binder compliance <br /> records, whether in the"Section 5" checklist or in the "Section 9" log, is sufficient to satisfy the rule <br /> and show compliance with this section. <br /> That said, although the site appears to be in full compliance with required waste inspections under <br /> 22 CCR § 66265.174, when our DO returned to conduct his regular monthly DO inspection at this <br /> site on March 25, 2014, he reiterated the waste inspection process to the site personnel. He also <br /> took pictures of the February 2014 and March 2014 "Section 5"checklists and "Section 9" logs, <br /> showing proper completion of all required weekly waste inspections for this period as well as the <br /> previous 12 month period addressed above. Copies of all records referenced are attached for your <br /> review and records. <br /> Based on this evidence, we reiterate our position that the site employee's statement was in <br /> error, and respectfully renew our request for rescission of this violation. As our position has <br /> not changed from the submittal of our initial NOV Resolution Package on March 6. 2014,a <br /> new Return to Compliance Certification is not included. <br /> It is our policy to address deficiencies, issues of concern, and/or agency requests regarding our retail <br /> facilities immediately. With the submittal of this letter, it is our understanding that all items of alleged <br /> non-compliance have been resolved. If this is not correct, please contact me as soon as possible. <br /> If you have any questions or require additional information, please don't hesitate to contact me. <br /> Best r rds, <br /> Sara S muels <br /> Environmental Compliance Specialist <br /> Enclosure <br />