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HERZOG, <br /> Transit Services Inc. <br /> 833 E. 8" St. Office 209-463-0713 <br /> Stockton, California Fax 209-464-9983 <br /> Ms. Michelle Le, <br /> The following has been compiled and is being submitted to you on behalf of the San Joaquin <br /> Regional Rail Commission in response to the exceptions noted during your inspection of the above <br /> addressed facility October 27th, 2003. <br /> Violation # Nat re of Violation Remediation <br /> CCR 66262.11 Failed to Herzog Transit Services, Inc. (HTSI) <br /> determine if waste was a immediately held two days of training that <br /> hazardous waste. addressed the proper handling, storage and <br /> disposal of the fuel and oil filters. Asbury <br /> 10 Environmental Services, was contacted to verify <br /> the handling instructions for each type of <br /> hazardous material and they provided labels that <br /> are now prominently displayed on each type of <br /> sealed container. <br /> Stored hazardous waste onsite All waste generated now falls under a date <br /> longer than 90 days. sensitive tracking system used to determine <br /> accumulation time (please see attached waste <br /> 19 oil tracking sheet as an example). Removal of <br /> the items identified was done immediately <br /> (please see copy of Asbury Environmental <br /> Services invoice). <br /> Failed to properly label Asbury Environmental Services provided labels <br /> 20 containers of hazardous waste. that are now prominently displayed on each type <br /> of sealed container. <br /> Failed to k ;ep containers of Each employee that is in anyway involved with <br /> hazardous waste closed except the handling and storage of hazardous materials <br /> 21 when addi g or removing has been instructed to open storage containers <br /> hazardous waste. only when necessary and to immediately close <br /> them upon completion of their task. <br /> Failed to p epare manifest for This is related to violation 10 above. Asbury <br /> 23 the transp rtation of a Environmental Services was contacted to verify <br /> hazardous waste. the handling instructions for each type of <br /> hazardous material. <br /> Contingency plan incomplete. As was discussed at the meeting with Michelle <br /> Le, Dina Abate and I, we are not a large waste <br /> 45 generator. We fell into this category during 2003 <br /> because of an intensive cleaning program we <br /> undertook, that had been deferred by the owner <br /> of the property for many years. This program <br />