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As long as we make sure to do it in a clean manner and dispose of the used oil properly, will that keep us compliant? This technique was recommended by a Busch representative. 406: We have no receipts of used drums being hauled off, however, we have asked Lowry to add empty drums to our invoice for future recordkeeping. From: Gaitan, Jason <lgaitan@slgov.org> Sent: Wednesday, March 18, 2020 4:07 PM To: Michael Plascencia <mplascencia@sunnyvalleysmokedmeats.com> Subject: RE: Return to compliance Hi Michael, Thank you for your responses and patience. I have follow-up questions. Violations 102: Busch Vacuum Solutions cannot take your used oil filters, they are not a registered hazardous waste hauler nor are they a TSDF (Treatment, Storage or Disposal Facility). I advise either managing used oil filters as hazardous waste or performing analytical testing to determine if oil filters are hazardous waste or not. Violation 406: Just to clarify, Lowry did not leave a disposal receipt for the empty 55 gallon drums? Hope to hear from you soon, JASON GAITAN EHS San Joaquin County Environmental Health Department (209) 468 -9848 -Office (209) 468-3433- Fax 1868 E. Hazaelton Ave. Stockton, CA 95205 From: Michael Plascencia [mailto:mplascencia@sunnyvalleysmokedmeats.com] Sent: Thursday, March 12, 2020 4:16 PM To: Gaitan, Jason <jgaitan@sigov.org> Subject: RE: Return to compliance Violation 102: Busch Vacuum Solutions is the company that services all of our vac pumps. They supply the oil, filters and all parts needed for service. Since they supply filters, Monica asked Ralph our contact at Busch to please take filters with him and dispose per his company policies. I will try to get my hands on their policy. Violation 406: Monica has instructed Lowry to leave proof of removal of empty drums in our invoices. I can then obtain this info through our accounting team. I would be happy to provide proof at our next opportunity.