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Concern#49: Training records onsite were incomplete. The training records do not include written job <br /> descriptions or a description or a description of the training to be given to each employee. Please find attached a <br /> revised training log including employee job descriptions that match employee job titles. All of these training <br /> topics are completed at least once annually and within the fust 6 months of hire. (see attached training logs) <br /> Concern#59: The following manifest numbers were not on record with the DTSC: <br /> • 002595029FLE This manifest was created by mistake for a shipment of aerosols. The <br /> waste was finally shipped under a BOL. The final BOL copy is attached. <br /> • 000850548GBF, 005991397JJK, 006069742JJK, 007083765JJK and 008038569JJK were all <br /> mailed to the DTSC PO Box for generator manifests. <br /> Concern # 60, 61, 62: <br /> • Manifest numbers 000771168GBF, 000850548GBF, 005991397JJK, 006998230JJK, <br /> 007427265JJK, and 007425891JJK. All of these manifests we were able to locate terminated <br /> copies of. The site likely mailed the initial copy to the DTSC without retaining a generator <br /> copy for their records. (See attached manifest copies) <br /> • Manifest numbers 002595029FLE (discussed in concern#59), 007085492JJK, <br /> 007083765JJK, 0074544621JJK, 007431033JJK, 007431034JJK, 008025694JJK, and <br /> 008388093JJK. Terminated manifests were located for these and filed onsite for retention. <br /> (see attached manifest copies) <br /> Concern#67: The waste analysis for oily solids is incomplete. No QA/QC was with the lab results. Please find <br /> attached the most recent lab results for this facility with QA/QC. As we discussed in our phone conversation on <br /> 9-8-2011, we will separately analyze used absorbent, oily soil, and oily floor mats/pads. If necessary, we will <br /> manage any hazardous component as a Non RCRA hazardous waste and manage the others as Non Hazardous <br /> waste. These results should be available by Mid October 2011. Attached is the most recent analytical for yard <br /> gravel. <br /> Concern#78: An alkaline battery was observed on the ground near the stored crushers....immediately <br /> containerize all universal waste batteries in accordance with title 22 regulations. The alkaline battery was placed <br /> in a plastic pail with the site's alkaline battery waste. These waste streams are shipped for proper disposal. Since <br /> 2007, this facility has shipped nearly 300 lbs of waste alkaline batteries for proper disposal removed from <br /> vehicles that we process. An additional 270 lbs of waste dry cell batteries were shipped on 9-15-2011. (see <br /> attached BOL)The site is trained annually in proper handling and disposal of universal waste items. <br /> Sincerely, <br /> C41--, oma---- <br /> Chris Orsolini-Environmental Administrator <br /> 916.858.3116 <br /> corsolini@picknpull.com <br /> M nr <br /> LrV.Y12u+' <br /> 10850 Gold Center Drive,Suite 325, Rancho Cordova, CA 95670 <br /> w .picknpull.cum <br />