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Alaniz, John [EHD] From: Jose Torres <wilsonandcoffeyappliances@gmail.com> Sent: Wednesday,July 29, 2020 12:40 PM To: Alaniz, John [EHD] Subject: Re: Return to compliance certification Attachments: Safety Plan.odt; Corrective Action Statement.odt CAUTION:This email is originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Hi, John Here is the updated corrections. We updated all the staff on the change of oil accumulation. We did go over the emergency procedures just did not included in the safety plan at that time. The Safety Plan has been updated also to include all the things you asked for. Updated on including the year 2017 for 110/113 Violation and The moving forward statement stating that we will start to keep Refrigerant Disposal records from this point forward. On Wed, Jul 29, 2020 at 11:25 AM Alaniz, John [EHD] <jalanizlksigov.org>wrote: Hi Jose, The regulation reads: CFR 40 section 262.16(b)(9)(iii) The small quantity generator must ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures, relevant to their responsibilities during normal facility operations and emergencies. That is what the training needs to ensure. If the employees are all familiar with this then the violation can be closed. The accumulation start time for used oil is 180 days for a small generator unless you claim it as satellite accumulation. A generator may accumulate up to 55 gallons of hazardous waste (or one quart of acutely or extremely hazardous waste) without a permit at the initial point of accumulation, known as a satellite accumulation area, for up to one year (Title 22 Cal. Code Regs., section 66262.34(e). Here is some information on MRSH https://dtsc.ca.gov/wp-content/uploads/sites/31/2015/07/CAR.pdf If you have any questions, please let me know. i