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3 <br /> Emergency Response/Contingency Plan - is complete. Make sure that the training record (form I left with <br />you, which will be kept at the dairy) covers the training indicated on this plan. <br /> Training Plan – this was not accepted because when you selected “provided elsewhere in CERS” there is an <br />option to select where else in CERS the training plan is located. That would be in the Emergency Response <br />Plan. Edit the submittal to select this option. (See the attachment for a screenshot of this page). <br /> <br />In order to close all the violations for the HMBP inspection report, please make the changes to the CERS submittals <br />noted above and send me a record of training along with the Return to Compliance certification at the end of the report. <br /> <br />As always, please contact me with any questions at (209) 468-3562. <br /> <br />Have a great weekend. <br /> <br />Christine Lawrence <br /> <br />From: Christine Lawrence <br />Sent: Monday, June 3, 2019 10:57 AM <br />To: 'jmsilva11@aol.com' <jmsilva11@aol.com>; 'vfurtado@fragservices.com' <vfurtado@fragservices.com> <br />Subject: FW: Your recent routine inspection <br /> <br />Good Morning Mr. Silva, <br /> <br /> <br />Attached are the inspection reports from your recent hazardous materials business plan and hazardous waste <br />inspections from May 31st, 2019. Currently you have a farm operations permit for hazardous materials from San Joaquin <br />County Environmental Health Department and is the reason for my recent inspection. As a condition of the permit, an <br />inspector will come out every 3 years to verify you are in compliance with the requirements for farms with reportable <br />quantities of hazardous materials. Because you also have used oil at the facility leftover from the previous owner, this <br />qualifies you as a hazardous waste generator as well. As such you need to have a hazardous waste generator permit for <br />used oil from San Joaquin County Environmental Health Department as long as there is used oil being generated or <br />stored on site. I initiated the permit for you. The cost for this permit is $63 and accounting will send you a bill. <br /> <br />If you decide to get rid of the waste, please provide me with documentation of where the waste was taken. You may <br />transport used oil under 55 gallons to the county Household Hazardous Waste disposal facility (by appointment), to an <br />ag waste disposal facility that accepts used oil (see attached brochure); or you may consolidate the oil at your other <br />facility provided you have a hazardous waste permit and EPA ID number at that facility. Another option, you may apply <br />for a temporary EPA ID number and have the waste picked up by a licensed hazardous waste transporter from the 24065 <br />E Arthur Rd facility. If you self-haul the waste to a disposal facility, I will need a receipt with the date and quantity of <br />waste disposed as well as the name and address of the receiving facility. If you take the waste to your other facility, <br />please provide me a statement as well as a copy of the consolidated manifest showing the waste was picked up by a <br />transporter at that facility. If you have the waste picked up at R & S, I will need a copy of the consolidated manifest from <br />that pick-up. <br /> <br />If you decide to keep the permit, you may continue to store and generate used oil only. You must comply with <br />regulations for hazardous waste generators including obtaining an EPA ID number, training employees, creating a <br />modified contingency plan, managing waste according to Title 22 (labeling, storage accumulation time limits, etc), and <br />disposal record management. <br /> <br />In addition, you have two 250 gallon steel tanks near where I observed the drum of used oil. These should also be <br />managed appropriately. If the tanks ever held fuel or other hazardous waste they should be managed as empty <br />hazardous waste containers and be labeled with the words “empty” and the date they became empty (use your best <br />knowledge to determine). They need to be managed within one year of being marked empty, so either be reused or