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Sammons, Lynsey [EHD] From: Sammons, Lynsey [EHD] Sent: Friday, October 4, 2024 9:47 AM To: Anwar Hugais cc: abdul@excelpetro.com; Excel Petroleum Subject: RE: Return to Compliance Forms and Supporting Documentation for 6131 Pacific Ave. Attachments: CUPA Flyer Jul -Dec 2024 by Class Type -updated 94pdf; PR0518811 - 6131 Pacific Ave - 8-15-24 - SQG HW RTC Updated.pdf; PR0231223 - 6131 Pacific Ave - 8-13-24 - UST RTC Updated.pdf; PR0519508 - 6131 Pacific Ave - 8-15-25 - HMBP RTC Updated.pdf Hi Anwar, Per our conversation yesterday, below is a status update on alt out of compliance items identified in your recent inspections. I closed out the items marked as "Resolved" and provided notes for what I still need to close out those that remain open. I have provided updated RTC certification documents that only include those items that remain open. There shouldn't be any surprises here since we talked about all of these yesterday, but please feel free to reach out to me again with any questions. Hazardous Materials Business Plan (HMBP) inspection: • #11 — Resolved. I see that a new map was upload and attached. Please note that unless the propane has been relocated, it is still labeled inaccurately. If it has been moved, great. If not, please feel free to update and resubmit a new map that reflects its current location. The map's accuracy will be verified during the next HMBP inspection. • #14 — Please confirm that the Consolidated Emergency Response/Contingency Plan was covered in the HMBP training or provide additional training to employees covering this document and write a new RTC statement addressing this and the requirement for records to be maintained on site for 36 months. Small Quantity Generator (SQG) Hazardous Waste (HW) inspection: • #2 — Since you had concerns about this, I thoughtyou might be interested in seeing the regulations on training. Below specifically references requirements for the trainer and here is the link in case you want to read up on it yourself (https://www,law.cornell.edu/regulations/catifornia/22-CCR-66265.16). 1 did attach our list of free classes, but it is not a requirement for Abdul or anyone who trains your employees to attend one of these —they're just a free option. But there are many options out there, so as long as you can demonstrate that your employees have been provided with training on hazardous waste management that was directed by a person trained in hazardous waste management procedures (Abdul or anyone else), I'm happy to close this one out. Cal. Code Regs. Tit. 22, § 66265.16 - Personnel Training State Regulations Compare (a) Notwithstanding subsection (g), an owner or operator of a hazardous waste transfer, treatment, storage, or disposal facility shall ensure that facility personnel successfully complete a training program through classroom, computer-based, or electronic Instruction or on-the- jobtraining that teaches facility personnel to perform their duties in a way that ensures [he facility's compliance with the requirements of this chapter and section 5192, subsection (p), of Title 8, California Code of Regulations. Facility personnel engaged In shipping hazardous waste shall be triennially trained commensurate with their responsibilities to meet the requirements In section 172.704 of Title 49, Code of Federal Regulations. (1) The owner or operator shall ensure that the training program Includes all the elements specified in this section. (2) and must include instruction that teaches facility personnel hazardous waste management procedures (including, but not limited to, contingency plan Implementation and the Identification and segregation of incompatible hazardous waste or product) relevant to the positions in which they are employed. • #11 — Resolved E