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Page 2 of 4 By the way, I believe all the issues you raised in your inspection report have been suitably addressed. The following text is copied from the word document, which to a large extent was prepared three weeks ago. I anticipate that this document will be incorporated into the return to compliance document. Regards, Bruce Ludeman ROUTINE HAZARDOUS WASTE GENERATOR INSPECTION Response prepared by Bruce Ludeman, Airport Coordinator 23. No disposal records available on site for drained used fuel filters. Per facility contact, the filters have been hauled to the main City of Tracy facility for handling and disposal. Persons generating .transporting, or receiving used filters shall use a bill of lading to record the transfer. Bills of lading must indicate generator, transporter, and receiving company names, addresses, telephone numbers, the quantity and size of containers transferred, and the date of transfer. A copy of each bill of lading must be kept on the premises for a period of three years. Begin this practice immediately. RESPONSE: 1. Maintenance staff has been trained on proper disposal of used fuel filters. 2. An appropriately labeled folder has been created for the suitable storage of each bill of lading. Instructions on the folder will direct a document retention schedule of three years 2. Fuel filters will be drained into existing fuel -recovery boxes that allow the reuse of the fuel. 3. Maintenance staff will arrange for the immediate and proper disposal (within 2 days) of used fuel filters. 50. The used oil tank has an accumulation start date of February 10, 2010. A generator of less than 1000 kg of hazardous waste in any calendar month shall not accumulate or store hazardous waste for greater than 180 days. Immediately dispose of this waste by having it hauled by a licensed hazardous waste hauler. Submit a copy of the disposal manifest to the EHD within 30 days (9/17/10). RESPONSE: 1. The used oil tank was appropriately disposed of on August 25th, 2010by Asbury Environmental Services. 2. Copies of the disposal manifests will be stored in the existing file prepared for these manifests. 3. A copy of the disposal manifest will be sent to EHD. 63. A consolidated manifest from February 10, 2010 was available for used oil, but no other manifests were available for disposal of used oil or other hazardous wastes hauled. The generator shall retain a legible copy of the hazardous waste disposal manifests on site for at least three years from the date of transport. Begin this practice immediately. 9/21/2010