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Response to CUPA Inspection 1505 Navy Dr, Stockton, CA 95206 <br /> Many of these violations are similar in nature and will be addressed with training, <br /> policies, and standard operating procedures. The violations from 2016, 17, 18 and 19 <br /> were mostly repeats, therefore the corrective action made in 2019 will address all <br /> previous violations. <br /> Open violations from January 14, 2019 inspections: <br /> Violation # 102 <br /> • Locks placed on ball valves — confirmed <br /> • This is referring to waste in secondary containment and sumps. Waste oil was <br /> swept up using absorbent and placed in oil waste drum to be discarded as non- <br /> RCRA waste. Material was picked up by Ramos Environmental Services and <br /> managed per Title 22 requirements. — Closed <br /> • Need a map of piping to oil water separator— ongoing <br /> Violation# 110, 111 <br /> • Manifests found, 017145974JJK (9-11-2017), 016653849JJK (11/8/2016) <br /> closed. <br /> • Procedures have been created to manage manifests to ensure proper handling <br /> ofII anifests. <br /> Violation4p l 13 <br /> • Ramos Oil manages the oil/water separator. There are no records of oil/waster <br /> operator clean out. Upon inspection of the oil/water separator by Ramos <br /> Environmental Services it has been determined that the oil/water buildup on the <br /> grating is only superficial and the oil/water separator appears to be in good <br /> working order with minimal oil/water build up. <br /> Violation# 117 <br /> • Inspections were done on 1/27/2016 and 5/10/2017, this services as written <br /> response to same items reference in this response. Ramos Oil has filled the <br /> position of EHS Manager and will provide oversite to all CUPA inspections. <br /> Violation# 605 <br /> • Place label on drums — confirmed. <br /> Open violations from May 10, 2017 inspections: <br /> Violation# 102 <br /> • Material identified and profiled and sent off according to Title 22 hazardous waste <br /> regulations as a non-RCRA oil waste. <br />