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CRM Corrective Responses (Continued) <br /> Violation#106-Failed to train employees on waste handling and emergency procedures. <br /> CRM conducted Hazardous Waste training 11-21-19 and reviewed emergency procedures, <br /> contact information,containment,clean up, location of spill kit materials and proper safety wear. <br /> Attached is the training summary form. <br /> Violation#110-Failed to keep signed copy of manifests from the designated facility for three years. <br /> Violation#111-Failed to comply with uniform hazardous waste manifest exception requirements. <br /> Violation#113-Failed to keep copies of consolidated manifesting receipts for three years. <br /> Violation#608-Failed to properly manage used oil and fuel filters. <br /> CRM has retained all forklift service records and separated them by serial number and will <br /> maintain three years of records. Watts Equipment Company has been servicing the forklifts. <br /> They provide onsite mobile service and remove and transport any waste oil/filter back to their <br /> maintenance shop in Manteca. Watts has recently changed their work orders to indicate if and <br /> how much oil/filters are replaced and removed from the site. Each work order is specific to <br /> individual forklift and provide serial number and lift maintenance information. Watts has <br /> provided their Craddle to Grave documentation which is attached. It provides their facility <br /> information and EPA ID as well as the facilities that the hazardous materials are transferred along <br /> with all receiving facility information/IDs. Additionally,CRM has implemented a Forklift <br /> Hazardous waste removal form to be completed each time oil/filters are replaced and removed <br /> from CRM. This will be completed for each forklift at every service interval involving oil/filter <br /> servicing. These records will be kept and maintained for three years or as required by law. <br /> Attached is a copy of the CRM Forklift Hazardous waste removal form. <br /> Violation#119-Failed to report program data in the California Environmental Reporting System(CERS). <br /> CRM has updated CERS to reflect the change in ownership from Hormel Foods Corp to CRM Co. <br /> LLC. Additionally,CRM has updated the site information including mailing address,emergency <br /> contact,environmental contact and billing information. Attached is the CERS print out summary. <br /> CRM also updated the hazardous waste generator status. <br /> Violation#3010-Unlisted Administration/Documentation violation. <br /> CRM has retained and provided a copy of the requested manifested disposal records. See <br /> Attached. <br /> Please review each corrective action response and contact me if you have any concerns or feel that we <br /> have not adequately addressed any violation. <br /> Ace , <br /> Steve Krauss <br /> Regional Manager <br /> CRM CO. LLC <br /> 1404 S.Fresno Ave, Stockton,CA 95206 Tel:209-662-6090 Cell:916-584-5158 <br />