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ATTACHMENT 6: Corrective Action Response to Violation #110-Failed to keep signed copies of manifests from the designated facility Circa mid-2017, WFS assumed operation of the Stockton Faility. Due to the type and volume of regulated wastes generated (i.e., automotive maintenance related wastes) WFS Stockton did not offer its first shipment of non-RCRA waste, Used Motor Oil, until mid to late 2018. According to Frank Stanich, the Station's Lead Mechanic, to date the WFS Stockton Station has not generated waste antifreeze. Payment of regulated waste pick-up and disposal at the Stockton Station is done as a COD transaction using a credit card. Consequently, the Consolidated Manifest which included the billing information, has been, historically, retained by the credit-card holder for reimbursement of the credit card charges. Effective August 2019 the practice of the credit card holder retaining the original Consolidated Manifest was terminated (see attached). Effective 2/15/2021 a Uniformed Hazardous Waste Manifest will be used to document the offsite shipment of all regulated wastes, including Non-RCRA wastes (see attached). Additionally, the following non-RCRA waste management practices have been initiated: 1. All routinely generated regulated wastes have been identified and profiled (refer to Attachment 2 and the Regulated Waste Management Matrix). Management of all regulated wastes shall be in accordance with the requirements stipulated in the most current version of the facility's Waste Management Matrix, including using only the Uniformed Hazardous Waste Manifest to document and track transfer and recycling/disposal activity. 2. Used oil and fuel filters: a. Drained until there is no free-flowing fluids draining from the filter unit; b. Drained used filters with metal housing will be managed as non-hazardous drained oil filters for metal recycling; and c. Drained used filters w/non-metal housing will be managed as oily debris (CWC 222 or CWC 223)