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see attached Hazardous Materi--s Management Plan. #64- Failed to retain on-site required certification for HW tanks- CCR 66265.192 Response: I am working with the manufacturer that built the tanks to determine what needs to be done to certify all the AST tanks. I will have more detail information as to when this violation will be completely corrected by next week. #67- Failed to use controls and practices to prevent spillage and overflows from tank system- CCR 66265.194(b) Response: We are having difficulty getting the secondary containment unit of the used oil tank completely drained. The hauler is looking for a thinner hose to pump out the secondary Once I have a date I will inform you. #69- Failed to conduct daily inspections of the HW tanks- CCR 66265.195(a) Response: I have received a copy of the Hazardous Waste Tank System Daily Inspection Log in accordance to CCR 66265.195(a). We are updating our current daily used oil logs and incorporating the Hazardous Waste Tank System Daily Inspection Log. All of our California stores should have access to this form during the second week of January 2010. We will send a communication out to the stores prior to launching the new form to educate everyone about it. Training: All new employees are required to take the "New Employee Orientation" via the store Intranet which encompasses the following subjects: (1) Environmental compliance; (2) DOT general awareness; (3) Hazardous communication procedures; (4) Safety. Four separate videos also accompany the training section and the employee must complete a quiz at the end of the course. Once the employee "passes" each section, the program automatic logs the employee as having completed the orientation. In addition, all employees are required to take an annual California only environmental refresher. The refresher is also done via the store Intranet which encompasses (1) Identifying the waste generated at the store, equipment; (2) Recognize paperwork ( ie. manifest, accumulation labels, TSDFs) and paperwork retention; (3) Environmental Compliance (4) Sustain housekeeping requirements. Once the employee "passes" each section, the program automatic logs the employee as having completed the orientation. I have also attached the signed Compliance Certification. We will continue to update you on the progress until all violations have been resolved. Pep Boys appreciates your guidance and availability on these matters. Should you have any questions regarding this information, please contact me at (215) 430-9645. (See attached file: STORE #710- SAN JOAQUIN COUNTY- RETURN TO COMPLIANCE CERTIFICATION.pdf) Sincerely, Angela Banks Senior Project Manager Environmental Department Pep Boys- Manny, Moe & Jack 3111 West Allegheny Avenue Philadelphia, PA 19132 Phone: (215) 430-9645 Fax: (215) 430-4665 Disclaimer: The information contained in this communication is confidential and only for the use of the intended addressee(s). If you have received this communication in error, any disclosure or use of such information is strictly prohibited. Please notify the sender immediately and destroy all copies. Thank you. 7