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Elianna Florido [EH] From: Middleton, Debbie <DMiddleton@Sallybeauty.com> Sent: Thursday, March 7, 2019 9:28 AM To: Elianna Florido [EH] Subject: Response to NOV Issued to Sally Store#1810 Attachments: Sally Beauty Supply#1810_2314 W Kettleman Ln Lodi_2019 HW Amended Inspection Report.pdf, Sally Store#1810 -Training Log.pdf, SBH Hazardous Waste Training Guide 2019.pdf, Hazardous Waste Categorization Supplement Training.pdf; Sally Store 1810 - Bins.pdf, Hazardous Waste - District Manager Compliance.pdf; Sally Store 1810 - Labels.pdf, RTC Certification - Sally 1810.pdf Importance: High Elianna, In response to your amended inspection report of January 17, 2019 for Sally store 1810 in Lodi, CA, please see the following: Item 106 CCR 66262.34(d)(2) Failed to train employees on waste handling and emergency procedures. • All associates have re-trained on waste handling and emergency procedures. See copy of training log*. The materials provided to aid associates in making a hazardous waste determinations are as follows: o Hazardous Material Management poster o Revised Hazardous Waste Training Guide, which includes a decision tree (see copy of Guide) o New Hazardous Waste Categorization supplement (see copy of Supplement) o SDS website o Toll-free number to the corporate office o Re-training of the employees at this location *Please note that because this location is a small-quantity generator there is no recordkeeping requirement. However, Sally has voluntarily re-trained employees at this location and maintained such records to ensure that employees understand the training they have received. Item 109 CCR 66262.23(a)(4) Failed to send generator manifest copies to DTSC within 30 days. • The generator copies of manifests 017403445JJK (9/12/18) and 017367086JJK (9/25/17) have been submitted to DTSC by our third-party vendor. Item 401 CCR 66262.34(d)(2) Failed to store hazardous waste in a container that is in good condition. • All bin lids have been replaced. See file titled "Sally Store 1810—Bins." • As a part of the re-training, associates were instructed to check the condition of the bins and lids during their weekly inspection. Item 404 CCR 66262.34(d)(2) Failed to inspect hazardous waste storage areas at least weekly. • The SBH Hazardous Waste Training Guide was revised to include a more robust weekly inspection checklist, see Guide, pages 2 and 3. • As a part of the re-training, associates were required to read the Guide and to immediately implement the more detailed weekly inspection. i