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Alaniz, John From: Steve Heinen <s.heinen@pacificsteelgroup.com> Sent: Tuesday, April 28, 2020 12:42 PM To: Alaniz, John Cc: Eric DeLeon; Brian Lohr; Robert Thomas; David Scurlock Subject: Corrective action for Inspection Report Attachments: T; PSG Emergency Action Plan Stockton Facility final.doc; Stockton facility EAP training 1 st aid cpr aed training.pdf, shop formen and maintenance personnel job descriptions.docx; Stockton Contingency Plan for SJEHD.pdf; STK Compliance Cert20200428_12290857.pdf, STK Starlite Reclamation20200428_12363730.pdf Mr. Alaniz, I have the violations from your report listed below with a short explanation of our actions. Documentation is attached, including the signed Compliance Certification Form. Please contact me with any questions or concerns. 101; We have a hazardous waste ID number. CAL000444780 107; A contingency plan has been completed and attached 118; 1.) Bob Thomas—fabrication manager Juan Garcia—shop foreman Georgeo Herrera—maintenance Brian Lohr—maintenance 2.)job description attached 3.)training schedules are outlined in our Emergency Action Plan (EAP), which is attached 4.)training sign in sheets attached. We found the job description training was not done, so we did it a training session on the job descriptions and a refresher on our EAP and Contingency Plan 125; A submission has need made to the CERS reporting program and accepted. We are currently updating the hazardous material list and our EAP to reflect Hazardous Material locations and quantity. 301; The shear that was leaking hydraulic oil has been repaired and moved to our Napa facility. The rags and oil absorbent material was cleaned up and deposited of in a waste drum. That drum and other waste material was removed in May of 2019. Clean up documents are attached. 304; The storage container was cleared of waste drums in May, 2019 as noted above in 301. A current picture of the container is attached. Safety Kleen has been contacted to remove some of the barrels in the picture, as we are working to decrease our onsite quantities of new and waste material. 406; All waste containers onsite have labels. Safety Kleen will print labels for the empty containers we have on order. 601: As stated above, we did a full site cleanup of all hazardous materials. We have also changed some practices of the previous site operator. We no longer remove cutting oil from the machines. There is no practical reason to remove the oil. Oil is added as the level drops, as there is some oil left on the bar after threading. Chips from the machine(s) are periodically removed from the collection tray after they have drained overnight and before operation begins. The chips are then put in our scrap bins. The maintenance person who was with the previous operation continued to remove oil even after he was instructed not to. He was recently terminated. The oil you see in the container will be removed on the next visit from Safety Kleen. All cutting oil containers listed in 601 have been removed. 605; All waste containers have been labeled. We will only have used oil (hydraulic), oily rag/absorbent and empty aerosol can containers onsite. All non-manufacturing equipment services will be done by outside contractors, which will eliminate a large amount of the previously kept hazardous materials and subsequent waste material. 608; All oil filter drums were removed in 5/2020. We no longer service rolling stock internally. All rolling stock is serviced by an outside vendor(s). i