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March 8, 2012 <br /> Ms. Stacy Rivera, <br /> The following has bee compiled and is being submitted to you on behalf of the San Joaquin <br /> Regional Rail Commis ion in response to the exceptions noted during your inspection of the above <br /> addressed facility Feb 1 13, 2012. <br /> Violation # Violatio Violation Code Remediation <br /> Class <br /> We no longer use the Union Pacific's bins <br /> for disposal of our spent absorbent pads, <br /> fuel and oil filters. Herzog Transit Services, <br /> Inc. (HTSI) held training to the applicable <br /> personnel which addressed the proper <br /> handling, storage and disposal of spent <br /> CCR 66262.11 - Failed to absorbent pads, fuel and oil filters. Safety <br /> 108 M determine if waste was a Keen was contacted to verify the handling <br /> hazardous waste. instructions for each type of hazardous <br /> material and they provided labels that are <br /> now prominently displayed on each type of <br /> sealed container. They are the vendor who <br /> will dispose of these items as well. We will <br /> maintain all bills of lading on site. (see <br /> pictures) <br /> CCR 66262.130(c)(5) - <br /> 128 M Failed to retain copy of bill This is related to violation 108 above. <br /> of lading for used oil filters <br /> for 3 years. <br /> We cleaned the spill pallets in the shop and <br /> the outside storage area using absorbent <br /> pads (PIG Mats). Upon completion the <br /> spent absorbent pads were properly <br /> disposed of in the proper container. A <br /> CCR 66265.173(a) - Failed weekly inspection and tracking sheet has <br /> to keep containers of been implemented for the spill pallets for <br /> hazardous waste closed which we use. The employees performing <br /> 404 C2 except when adding or the inspections have been properly trained <br /> removing hazardous on the procedures for inspecting and <br /> properly filling out the inspection sheet. PIG <br /> waste. mats have been placed in the bottom of the <br /> spill pallets. When necessary, PIG mats will <br /> be properly disposed of and replaced with <br /> new ones. All inspection and tracking <br /> sheets will be kept on site for 3 years. (see <br /> pictures) <br />