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October 22, 1992 Ms. Susan J. Laney Dept. of Toxic Substances Control Region 1 10151 Croydon Way, Suite 3 Sacramento, CA 95827-2106 Dear Ms. Laney: RECE11 D 0 C T 2 6 1992 • P0. Sm f)3J6 Stockton. California 95206 (2091406-3192 FAX Q091.i65-0631 We received your Report of Violations letter dated October 5, 1992. We have attached a copy of your letter and provide the following response. Each numbered paragraph below replies to, a corresponding paragraph of the Report. 1. The owner/operator or the facility's agent shall retain at the facility a copy of each manifest for at least three years from the date of delivery. Forward has retained manifest copies for years prior to the current year at the main office, located at 1145 West Charter Way, Stockton. We are currently making additional copies of each manifest prior to 1992, for at least three years before the present. Forward will store the additional copies at the facility, located at 9999 South Austin Rd. A full set of copies will be transferred to the Forward facility by October 30, 1992. Forward will continue to retain a copy of each manifest at the facility for at least three years from the date of delivery in compliance with Title 22, CCR, Section 66265:71 (a)(6). 2. Generators who accumulate hazardous wastes on site without a permit shall comply with labelling and marking.requirements. In accordance with Title 22, CCR, section 66262.34 (f), Forward's 500 gallon waste oil tank has been labeled with an accumulation sticker that is replaced each time the tank is emptied. A copy of the sticker is attached. The sticker includes the words "Hazardous Waste", the date of accumulation of the waste oil, and Forward's name and address. All four sides of the tank have also been labeled with the words "Waste Oil", "Toxic" (the hazardous property of the waste), and "Liquid" (physical state of the waste). 1