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Elianna Florido [EH] From: Middleton, Debbie <DMiddleton@Sallybeauty.com> Sent: Thursday, March 7, 2019 12:39 PM To: Elianna Florido [EH] Subject: Response to NOV Issued to Sally Store #3634 Attachments: Sally Beauty Supply #3634_1240 W 11th St Tracy_2019 HW Inspection Report.pdf; Sally Store 3634 - Training Log.pdf, SBH Hazardous Waste Training Guide 2019.pdf; Hazardous Waste Categorization Supplement Training.pdf; 3634- TRACY-0555-17369660.pdf, Sally Store 3634 - Bin Labels.pdf; Sally 3634 - RTC Certification.pdf Importance: High Elianna, In response to your amended inspection report of January 7, 2019 for Sally store 3634 in Tracy, CA, please see the following: Item 106 CCR 66262.34(d)(2) Failed to train employees on waste handling and emergency procedures. ? All associates have re-trained on waste handling and emergency procedures. See copy of training log*. The materials provided to aid associates in making a hazardous waste determinations are as follows: o Hazardous Material Management poster o Revised Hazardous Waste Training Guide, which includes a decision tree (see copy of Guide) o New Hazardous Waste Categorization supplement (see copy of Supplement) o SDS website o Toll-free number to the corporate office o Re-training of the employees at this location *Please note that because this location is a small -quantity generator there is no recordkeeping requirement. However, Sally has voluntarily re-trained employees at this location and maintained such records to ensure that employees understand the training they have received. Item 109 CCR 66262.23(a)(4) Failed to send generator manifest copies to DTSC within 30 days. ? The generator copies of manifests 019594728JJK (11/27/18), 017403262JJK (8/16/18) and 015886887JJK (11/22/16) have been submitted to DTSC by our third -party vendor. Item 110 CCR 66262.40(a) Failed to keep signed copy of manifests from the designated facility for three years. ? The facility copy of the manifest identified in the inspection report has been received by the store and put into their hazardous waste binder. ? As part of the re-training, associates were refreshed on recordkeeping and documentation requirements, which includes the status of both generator and designated facility copies. ? As requested, a copy of manifest 017369660JJK (5/25/18) is attached. Item 111 CCR 66262.42(a)(c)(d) Failed to comply with uniform hazardous waste manifest exception requirements. ? See above response. Item 605 CCR 66262.34(f) Failed to completely label containers or portable tanks of hazardous waste.