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0 <br /> 2) Pick N Pull Stockton places vehicle carpet floor mats under engine compartment as available to catch drips and minimize <br /> release to soil.These floor mats are made of polypropylene,the same material as oil only absorbent pads.We believe this <br /> minimizes the amount of auto fluids that contact the soil. <br /> 3) Pick N Pull Stockton drains all vehicles of all automotive fluids to the maximum extent practical.However due to the <br /> circuitous channels,passageways,etc in engine and drive train parts,it is not possible to remove all fluids.In 2010 this <br /> facility shipped over 36,000 gallons of waste oil for recycling.Over 9500 gallons of waste antifreeze were also shipped off <br /> for reclamation.Last, 10 drums or 550 gallons of waste brake fluid was shipped in 2010 for proper disposal. <br /> Concern#20: Improperly labeled containers: two 55 gallon drums for brake fluid, two 55 gallon drums of <br /> sodium silicate/water/oil, a 55gallon drum of"bad gas", and a 50 gallon container of used oil. Immediately label <br /> these containers. Dispose of the 50 gallons of waste oil and submit a manifest copy. The hazardous properties <br /> were corrected on all the labels mentioned. The used oil was pumped out with the normal used oil pick up so we <br /> cannot specifically produce a manifest for just this oil. (See Figures 5, 6, 7, 8 and attached oil manifest) <br /> Concern#22: "Two spent lead acid batteries were observed with corrosion on the temiinals.....A damaged <br /> battery shall be managed so as to minimize the release of acid and lead...Immediately manage and label the <br /> damaged lead acid battery in accordance with title 22 regulations." Our interpretation of a damaged battery was <br /> that it has to have cracks or caps missing to actually be "damaged". The employees who handle batteries will be <br /> trained as to the wider interpretations of a"damaged battery". These batteries will be wrapped in a plastic bag to <br /> better contain any leaks. Additionally, all "damaged"batteries will be shipped in the black liquid tight poly <br /> totes. Last, all battery pallets and bins will be labeled with a"Used Battery" label. This is consistent with Title <br /> 22 regulations and the DTSC December 2006 Fact Sheet: "Management of Spent Lead-Acid Batteries. (see <br /> attached damaged battery procedure, and used battery label photo Figure 9) <br /> Concern#30: "An empty white poly tank labeled"used oil' and twelve 55 gallon drums which previously held <br /> hazardous substances were observed in the shop without empty labeling....immediately mark and manage all <br /> empty containers per this section" The empty poly tank will be labeled with a"Empty Container" label with the <br /> required information. Pertaining to the 12 drums observed, these drums were re conditioned drums delivered by <br /> waste vendors that had not yet had hazardous substances place in them. Additionally, the empty, reconditioned <br /> drums were stored beneath a sign that says "empty drum storage area". Regardless, the site will label all empty <br /> drums with the same "Empty" label as the empty poly oil tank. (See attached photos, Figures 10, 11, 12) <br /> Concern#32: "A tank assessment was not available for the used oil tanks and used antifreeze <br /> tanks...immediately obtain written tank assessments for the hazardous waste tanks at this facility..."We have <br /> executed a contract with EarthCon Consultants to perform the tank assessment according to Title 22 <br /> requirements. We expect it to be complete by October 31s`, at the latest. As soon as it is complete a copy will be <br /> sent to you. <br /> Concern#35: "Daily inspections are only being conducted on the gasoline tanks.....Immediately begin <br /> conducting the necessary daily inspections for all hazardous waste tanks at this facility. Submit a copy of the <br /> inspection logs to EHD..." The site has restarted daily inspections of all tanks at the site. Please see attached <br /> inspection log sheets for used oil and used antifreeze tanks, figures 13, 14. <br /> Concern#45: The contingency plan for the facility was not complete or out of date. Please find attached a <br /> revised contingency plan that has also been submitted to the SJCOES web portal as well. <br /> lip <br /> 10850 Gold Center Drive, Suite 325, Rancho Cordova, CA 95670 <br /> w .picknpulLmm <br />