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Manzo, Elena K.[EHD] <br /> From: richard.bronson@shell.com <br /> Sent: Thursday,November 12,2020 3:41 PM <br /> To: Manzo, Elena K.[EHD] <br /> Cc: richard.bronson@shell.com;theresa.geijer@shell.com <br /> Subject: RE:Shell Stockton-#4 attached <br /> CAUTION:This email is originated from outside of the organization. Do not click links or open attachments unless you recognize the <br /> sender and know the content is safe. <br /> Elena, there are 4 pumps (under the load rack)within 80 feet of the location where the small container was found. We <br /> recently put fresh oil into two of them as they were new pumps, motors and gear reducers, so I consider the storage <br /> area near the generation point. Our understanding of the satellite storage requirements are; <br /> Under the Control:the accumulation container must be in the line of site of the operator or in a locked compartment to <br /> which the operator controls access. The purpose of this requirement is to ensure that the operator controls access to <br /> and management of the accumulated waste. This prevents mixing of incompatible wastes or other unsafe management <br /> practices.This is within sight of the operator and the operations control room and we control access to the facility 24/7. <br /> Satellite Accumulation Area(SAA): Area located at or near point of generation and under the control of the operator of <br /> the process generating the waste. <br /> Waste is placed in satellite accumulation area prior to end of work shift of individual operator of the process generating <br /> the waste. <br /> Our primary concern is complying with regulations, management of the waste and securing the waste from spillage and <br /> contamination. <br /> leld &1.06101( <br /> From: Manzo, Elena K. [EHD] <emanzo@sjgov.org> <br /> Sent:Thursday, November 12, 2020 12:57 PM <br /> To: Geijer,Theresa A SPLC-STO/65 <theresa.geijer@shell.com> <br /> Cc: Bronson, Richard D SPLC-STO/384<richard.bronson@shell.com> <br /> Subject: RE: Shell Stockton -#4 attached <br /> Think Secure.This email is from an external source. <br /> Thank you Theresa, let me take a look. <br /> Also, Richard, can you please clarify the use of the satellite container that we saw during the inspection. Does this <br /> container stay in the hazardous waste accumulation area and is taken to each pump when pumps are services, or does it <br /> typical sit by one of the pumps and was brought back to the main area for disposal (when we saw it).Thank you <br /> Elena <br /> From:theresa.geijer@shell.com <theresa.geijer@shell.com> <br /> Sent:Thursday, November 5, 2020 5:43 PM <br /> To: Manzo, Elena K. [EHD] <emanzo@sjgov.org> <br /> Cc: richard.bronson@shell.com <br /> Subject: RE: Shell Stockton -#4 attached <br /> CAUTION:This email is originated from outside of the organization. Do not click links or open attachments unless you recognize the <br /> sender and know the content is safe. <br /> 1 <br />