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Inspection Response - Estes June 2, 2011 Page 3 of 5 23d. Inspector: The DO employee training for Travis Horton was not performed per Travis Horton, although a training certificate was found dated May 19, 2011. The designated operator shall train facility employees for which he or she is responsible in the proper operation and maintenance of the UST every 12 months. Response: It is our understanding that the designated operatory did in fact spend time with the terminal manager going over the UST system and his responsibilities. In discussions with Mr. Horton after your inspection we believe he misunderstood your question as meaning he had received formal training (i.e. book course, video training etc.). The training Mr. Horton received was conducted by the DO in his office during the course of working hours at the terminal. The terminal manager is responsible for oversight of the UST's at all terminals that have UST's. Estes has asked the designated operator to complete a follow-up training with the Mr. Horton in June to assure he understands the UST system. Documentation of that training will be forwarded to your office upon completion. 7. Inspector: Failed to determine if a waste is a hazardous waste. At the time of the inspection oil was seen in the secondary containment spill pallet under 3 55 gallon drums of oil. It is unknown if this was a waste or not. Immediately make a hazardous waste determination per Title 22 regulations and handle accordingly or handle as a hazardous waste. Within 30 days provide written documentation to this office describing what action has been taken. Response: The three 55 gallon drums of oil viewed at the site is virgin motor oil utilized by the drivers at the terminal to add to their truck engines as needed. The oil in the spill pallets upon which the drums are resting on is also considered virgin. Oil that may be in that pallet is recovered and utilized in for the trucks. 8. Inspector: This facility's EPA ID number is inactive. A hazardous waste generator shall not treat, store, dispose of, transport or offer for transport, hazardous waste without an EPA ID number. Immediately contact DTSC and reactivate your EPA ID number and submit evidence to EHD by June 28, 2011. Response: No on-going activities are conducted on the site were hazardous waste is routinely generated and a permanent EPA ID number would be required. 52. Inspector: At the time of inspection it could not be demonstrated that employees who handle hazardous waste properly trained. Both Travis Horton and Bill Wardell stated hazardous waste training was not provided to them. The generator must insure that all employees who handle hazardous waste are thoroughly familiar with proper waste handling and emergence procedures. Immediately provide training to all employees who handle hazardous waste and submit a copy of training records to EHD by June 28, 2011. Inspection Response - Estes