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ATTACHMENTS: Corrective Action Response Regarding Management of Used Oil During the 9/18/2019 Hazardous Waste Generator inspection, the EJCEHD Inspector observed a partially full 55-gallon drum containing used motor oil. In response to this observation, the following hazardous waste management violations were issued: • Violation #601: Stored hazardous waste onsite greater than 180 days: and • Violation #605: Failed to completely label containers or portable tanks of hazardous waste The 55-gallon drum of used motor oil is generated from preventive maintenance of the Stockton Station's GSE and has been managed as a satellite accumulation location. Effective February 2020, the 55-gallon used oil satellite accumulation drum has been labeled in accordance with 22 CCR 66462.34 (f) by Ramos Environmental as part of the services provided. The 55-gallon drum is not offered for offsite transportation when full. Instead, the facility's designated hazardous waste hauler, Ramos Environmental, located in West Sacramento, pumps the contents of the 55- gallon drum as part of a consolidated milk-run transfer, and documents the milk-run pick-up using a consolidated Bill of Lading/Manifest document (see attached). Effective 02/15/2021, while the 55-gallon used oil drum will continue to be managed as a satellite accumulation location and pumped as part of a milk-run pick up, a Uniformed Hazardous Waste Manifest will be used to document the transfer instead of a consolidated manifest (see attached).