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ATTACHMENT 8: Corrective Action Response to Violation #301: Facility not maintained to minimize the release of a hazardous waste The WFS Stockton Station operates nearly 24-hrs a day, over four shifts seven days a week, loading and/or unloading Amazon's freight aircraft. Consequently, due to the intensity and frequency of the facility's operations, cleanup of incidental oil leaks from the Station's GSE is a daily occurrence. However, minor leaks and spills of motor oils and fluids are not classified as a 'release of a hazardous waste' subject to 40 CFR 262.16 unless the leaked or spilled motor oils/fluids go unabated for an extended period of time. That is not the case for the WFS Stockton Station's operations. Dock and ramp employees are trained to monitor for leaking GES equipment, and to clean, using only dry cleanup techniques, any observed oily spills/leaks upon discovery, or as soon as practical. It is the Station's practice to ensure that oily spills/leaks are cleaned by the end of the shift that the spill/leak occurred. Additionally, to minimize the opportunity for, and extent of, oily spills/leaks, prior to a WFS employee using a GSE unit, the employee is required to inspect the equipment to identify potential safety issues. In the event that a safety issue is identified, including leaking equipment, the employee is required to prepare a RED TAG out-of-service notice (see attached Powered Equipment Daily Safety Check and RED TAG SOP). However, it is necessary to clarify that WFS is not the only operator servicing Amazon's cargo plans. Other service providers fuel and repair the plans while the aircraft are staged on the ramps during loading/unloading operations. Consequently, it is inappropriate to attribute the oily debris observed by the SJCEHD Inspector during the 9/18/2019 solely to the WFS Stockton Stations operations unless the initial spill or leak was also observed by the Inspector. Effective March 15, 2021 the following housekeeping practices will be implemented: • Each Ramp Leader who is responsible for managing a cargo loading/unloading assignment, prior to completion of that assignment, shall inspect the ramp work area for evidence of any spills/leaks, either from the equipment used and/or the cargo handled. In the event that an oil leak, or spillage from the cargo, is discovered the Ramp Leader shall take immediate action to initiate cleanup of the leaked/spilled materials using dry cleanup methods. The Ramp Leader shall document the cleanup activity, including verification of proper management of all associated cleanup wastes; and • WSF Safety & Security personnel shall develop a formal station-specific Spill Cleanup Procedure and Cleanup Log for non-emergency events . The cleanup procedure will describe approved steps for cleaning up incidental leaks and spills of used oils, laundry shops and detergents and oily water.