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Process Specialties "EXCELLENCE IN PROCESS ENGINEERING AND SUPPOR7" 7-20-2011 Thuy Tran Environmental Health Specialist SJC Environmental Health Department 600 E. Main Street, Stockton, Ca. 95202 Thuy, On June 28th you and Ray Von Flue inspected our facility in Tracy and found four violations. Three of the four violations were corrected onsite. The fourth violation as we understood it was that we needed to add the job title to the current training logs for the two employees that handle hazardous waste at our facility. This was done and the new training log sheets are attached to this response. Violations: #20 CCR 66262.34(f) Failed to completely label containers or tanks of hazardous waste. This was a 30 gallon drum of waste lube oil located on the waste pad. The drum had the proper hazardous waste label, with the name, type, start date and state of the waste filled out. However, we failed to check the hazardous property box marked "toxic." We were allowed to check the box while the inspectors were on site. The permanent laminated label has now been changed and all required information is complete. #30 CCR 66261.7(f) An empty or HW or Haz Mat container (larger than 5 gallons) was not marked with the date it was emptied and or not managed within one year of it being emptied In the outgoing staging/shipping area of our warehouse there was an empty carboy (30 gallon) that held Caustic Soda (Sodium Hydroxide) used for wastewater neutralization. The carboy had just been emptied and changed, and was waiting to be picked up and replaced with a new full one in the next few days. The carboy did not have an empty label on it, or the date it was emptied. The inspectors let us place an empty label on it while they were onsite. We now have permanent laminated "empty labels" made for the occasional empty carboys waiting to be returned to the vendor. #45 CCR 66265.52 Contingency plan incomplete While our contingency plan in our files is complete, we have a page from the plan that lists all the emergency contact numbers posted a various locations around the plant. At one of those locations all the emergency contact phone numbers were correct except for the SJC OES number (that had changed in the last couple of years). All other emergency contact number postings around the plant had the correct and current SJC OES phone number. The inspectors allowed us to correct this on site and a new emergency contact list was printed and posted at this one location in the rear south wall of the plant. 1660 W. LINNE RD.. BLDG. A • TRACY. CALIFORNIA 95377 • 800.533.8820 • 209.832.1344 • FAX 209.832.1325