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Response: We have instructed the lessee-dealer to conduct a daily visual inspection of <br /> the UST monitoring system and to maintain a log of his observations. We are informed <br /> that the lessee-dealer is now maintaining a log of daily visual inspections. <br /> 3. Alleged Violation: The Compliance Inspection Report stated the following: "Haz <br /> Waste manifests not showing proper disposal of fuel filters. Show proper disposal on <br /> manifests immediately." In the corresponding Violation checklist, a check was placed <br /> next to "Violation(s)not listed above." <br /> Response: Facility 2133 is a leased station. BP leases the property with the <br /> improvements to a lessee-dealer who operates the station. As the operator of the facility, <br /> it is the lessee-dealer who generates fuel filter waste and is responsible for its proper <br /> management and disposal. BP desires the proper management of all waste at its facilities. <br /> BP has instructed the facility on proper waste management practices, including the <br /> requirement that fuel filters be disposed of as hazardous waste. I note that there is no <br /> requirement under the State Hazardous Waste Control Law to maintain hazardous waste <br /> manifests on site. The absence of hazardous waste manifests showing the disposal of fuel <br /> filters at the station does not indicate that fuel filters are being disposed of improperly. <br /> I also enclose the signed Certification of Return to Compliance form for this inspection. <br /> With the transmittal of this letter, it is our understanding that the alleged violations <br /> associated with this routine inspection conducted on March 25, 2003 has been resolved. <br /> If this is not correct, please contact me as soon as possible. If you have any questions <br /> regarding the enclosed documents, or if further action is required by BP/ARCO, please <br /> contact me at (800) 525-5857 x6233. <br /> Truy yours, <br /> JO�Schetter <br /> Environmental Compliance Specialist <br /> BP West Coast Retail Business Unit <br /> Enclosures <br /> cc: File 2133 <br /> Deborah Felt <br /> Lisa Wing Stone <br /> Sandra Ikuta <br />