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1 <br />Christine Lawrence <br />From:R and J Dondero Inc <rjdonderoinc@msn.com> <br />Sent:Thursday, September 12, 2019 5:05 PM <br />To:Christine Lawrence <br />Subject:Re: Inspection return to compliance <br />Attachments:20190912170349220.pdf <br />Hi Christine, <br />I am waiting for confirmation on the training date for the shop guys. It should be within the next two weeks as <br />far as I know and I will send you the training document as soon as it is done. Gary will be conducting it. <br />I am attaching a photo of the food grade oil container's. I am not sure what they use it for, but will ask <br />again. It is all handled as hazardous, and they put it into the hazardous waste container. <br />Sorry it is taking me so long to get you all of these answers, but I get it in bits and pieces as the guys are in <br />harvest mode. <br />I will be gone until Monday, but hopefully I will have the rest of your answers by then. <br />Thank you for your patience, <br />Cindy <br /> <br />From: Christine Lawrence <clawrence@sjgov.org> <br />Sent: Wednesday, September 11, 2019 11:31 AM <br />To: R and J Dondero Inc <rjdonderoinc@msn.com> <br />Subject: Inspection return to compliance <br /> <br />Hello Cindy, <br /> <br />The following two violations from your hazardous waste inspection remain open <br />1. Fail to train employees on waste handling and emergency procedures. <br />Corrective Action: Generator must ensure all employees that handle hazardous waste are thoroughly familiar <br />with proper waste handling and emergency procedures. Provide training for employees whose responsibilities <br />include hazardous waste and submit a record of training to the EHD. I am concerned with the employees <br />working in the shop and handling the waste generated there. We offer free classes at our offices on hazardous <br />waste management. See the attached list of classes. <br />2. Failed to determine if waste is a hazardous waste for the oil covered in sandy absorbent. <br />You stated this oily waste was determined to be non-hazardous based on the fact it was food grade oil. What is <br />the oil used for? How does the SDS classify the hazards? And finally, how was the waste disposed? Regular trash <br />bin? <br /> <br />I emailed Gary Reeves for corrections needed to close the last violation on your hazardous materials business plan <br />(HMBP) inspection report. <br /> <br />Thanks so much. Let me know if you have any questions. <br /> <br />Best, <br />Christine Lawrence, EHS <br /> <br />From: R and J Dondero Inc <rjdonderoinc@msn.com> <br />Sent: Tuesday, September 10, 2019 8:49 AM