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I I The Inspection Report also notes that stormwater training for an employee, Juan Ambriz (hired January 21,2019),was not provided within the first six months of hire(SWPPP training completed October 11,2019). At the time of the inspection, computer-based training records were not being properly automated for assignment. This issue was brought to the attention of Pick-n-Pull's training database administrators and has been corrected. Moving forward, automated training assignments will include stormwater training upon new hire. A copy of Mr.Ambriz's stormwater j training is provided in Attachment 4. Training records are maintained through the training software database. Hazardous Waste Disposal-#202 During the inspection,the County alleged that gravel debris,which has been profiled and classified as a non-hazardous waste by Pick-n-Pull, was improperly disposed of and should have been disposed of as a hazardous waste. Pick-n-Pull disputes this alleged violation. To properly profile and classify the waste, composite samples are collected by a qualified waste vendor and analyzed for metals, petroleum hydrocarbons, organics, and toxicity through fish bioassay analyses. The lab results were reviewed by the County during the inspection and confirm that the gravel debris does not exhibit hazardous waste characteristics. Pick-n-Pull does not believe that the sample of oily debris collected by the County during the inspection is representative of this high-volume waste stream that is periodically characterized by a qualified waste vendor to ensure its proper management. The sample collected by the County was selectively chosen from a visibly stained area on the ground rather than collecting/compositing several samples from the bin used to contain the gravel. A single "worst case" sample collected from the ground is not representative of the waste stream as a whole. Further, the sample in question contained only 10 mg/L lead,just nominally over the STLC value of 5 mg/1 and likely within background levels in the native soil. Similar questionable sampling techniques were also used by the inspectors when sampling other routinely generated wastes (e.g., used PPE and rags). Pick-n-Pull believes that its waste profiling procedures are consistent with regulatory requirements and that these waste streams are being properly characterized. i Minimizing Release of Hazardous Waste-#301 During the inspection, the County noted numerous instances of oily staining beneath vehicles located in the Customer Yard,vehicles with incomplete draining of fluid reservoirs,vehicles noted to be "actively leaking" and some vehicles with oil filters that had not been properly removed. Based on these observations, the County alleges that the Site is not maintained to minimize the release of hazardous waste or hazardous waste constituents. It is part of Pick-n-Pull's standard operating procedures (SOPS) to remove vehicle fluids such as brake fluid, power steering fluid, and windshield wiper fluid from vehicles during the Vehicle Clean Out(VCO)process,which occurs prior to placing vehicles in the Customer Yard. Oil filters are also removed from vehicles, drained and crushed as part of SOPs. Employees are trained on Page 3 of 6 Stockton Insp Resp_County_20200116