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*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 copy of manifest 017403447JJK (9/12/18) has been submitted to DTSC by our third -party vendor. Item 605 CCR 66262.34(f) Failed to completely label containers or portable tanks of hazardous waste. As previously stated in our return -to -compliance responses for the other Sally and CosmoProf stores you have inspected in San Joaquin County, through examination of the regulation and advice from counsel, SBH respectfully disagrees with the inspector's interpretation that "composition" means "contents." Please note that the word "contents" is not in the regulation and, moreover, that the U.S. EPA's recent Generator Improvement Rules stressed that what is important on the labels is the hazard description, not the contents, and that reporting of contents is not required. Therefore, at this time, SBH does not intend to list by name all of the products placed inside a bin on the label, but rather, continue its practice of using the products listed on the pre-printed bin labels as examples only. Specifically, the applicable code section, 22 CCR §66262.34(f), provides as follows: (f) Generators who accumulate hazardous waste on site without a permit or grant of interim status shall comply with the following requirements: (1) the date upon which each period of accumulation begins shall be clearly marked and visible for inspection on each container and portable tank; (2) the date the applicable accumulation period specified in subsection (a) or (d) of this section begins, for purposes of subsections (a) and (b) of this section, shall be clearly marked and visible for inspection on each container and tank; and (3) each container and tank used for onsite accumulation of hazardous waste shall be labeled or marked clearly with the words, "Hazardous Waste."Additionally, all containers and portable tanks shall be labeled with the following information: (A) composition and physical state of the wastes, (e) statement or statements which call attention to the particular hazardous properties of the waste (e.g., flammable, reactive, etc.), (C) name and address of the person producing the waste. Finally, attached is the executed Return to Compliance Certification. I trust you will find this responsive to the violations and that CosmoProf store #8784 is returned to compliance. Regards, Debbie Middleton Senior Paralegal, Environmental Compliance and Litigation Sally Beauty Holdings, Inc.I Sally Beauty Supply LLC I Beauty Systems Group LLC I Arcadia Beauty Labs LLC 3001 Colorado Blvd., Denton, Texas 76210 Email: dmiddleton@sallvbeautv.com Ph: 940.297.4964, Fax: 940.297.4990