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0 I <br /> these "de-pollution" procedures (Best Management Practices), and all BMPs are required to be <br /> fully implemented.Pick-n-Pull acknowledges that during the inspection a number of vehicles were <br /> observed to not have been properly drained of their fluids and removed of their oil filters as <br /> required. Pick-n-Pull procedures and standards were reviewed with applicable staff immediately <br /> after the inspection and staff was directed to remove excess fluids and oil filters found in vehicles <br /> located in the Customer Yard. In order to ensure proper fluid draining and oil filter procedures are <br /> being followed, additional review and inspection of vehicles by Site leadership is now being <br /> implemented before vehicles are placed in the Customer Yard. <br /> It is important to note that although vehicles are to be drained of their fluids, they can only be <br /> drained of fluids to the extent practical; it is not feasible to remove every last drop of fluid from <br /> the vehicles. This can lead to minor releases of vehicle fluids throughout the Site,as was observed <br /> during the inspection. This is why best management practices(BMPs)to address minor spills and <br /> releases are implemented on a continuous basis by Site staff. When Customers remove parts from <br /> vehicles, residual fluids remaining in some of the vehicle parts can also be released, even if <br /> vehicles are properly drained in accordance with SOPs. BMPs are in place to address these minor <br /> spills as was explained by the Store Manager during the inspection. For example, gravel is placed <br /> throughout the facility to limit oil from having direct contact with the ground, and scrap <br /> carpet/mats/oil absorbent pads are used throughout the Site to capture minor spills. Oil stained <br /> gravel is removed and replaced when vehicle rows are cleared and areas can be accessed more <br /> easily and safely. Minor oil staining that was observed during the inspection has been properly <br /> cleaned up in accordance with Site BMPs. <br /> Vehicle fluids are disposed of as hazardous wastes. Gravel and used absorbent are tested for waste <br /> profiling and disposed of as a non-hazardous waste at a facility in Yuma,AZ. <br /> Photographs of cleaned up vehicle rows and of the cleaned portions of the Production Area are <br /> provided in Attachment 1. <br /> Maintaining Spill Control and Response Equipment-#303 <br /> During the inspection, secondary containment for vehicle crusher fluid was observed with fluid <br /> inside. The secondary containment was cleaned of material and the requirement reviewed with <br /> applicable staff to ensure the containment is more frequently checked and maintained. <br /> Closing of Hazardous Waste Containers -#403 <br /> During the inspection,a drain pan was observed to be open without a lid in the Customer Yard and <br /> a cardboard box of empty vehicle fluid containers was observed without a lid. It is likely that a <br /> Customer placed a drain pan beneath a vehicle they were working on as Pick-n-Pull does not drain <br /> fluids in the Customer Yard. Drain pans are not waste storage containers and do not typically have <br /> lids. The pan was removed from the Customer Yard and the oil was properly disposed of The <br /> box of empty fluid containers was provided with a proper lid immediately after the inspection. <br /> Page 4 of 6 <br /> Stockton Insp Resp_County_20200116 <br />