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Response to San Joaquin County Complaint <br />First Cause of Action <br />Complaint: <br />a. Disposed or caused disposal of hazardous waste at an unauthorized point, in <br />violation of Health and Safety Code section 25201(c). <br />Environmental Health Department: <br />In the acid packaging area, acid (with a pH of 0-1) was found on the ground in <br />many areas. This is a violation of California Health and Safety Code Section <br />25189.5. All hazardous waste shall be disposed of at an authorized facility. <br />The same acid was being stored in a sump in the ground. This is a violation of <br />California Health and Safety Code Section 25189.5(d). All hazardous waste shall <br />be stored at authorized facilities and within authorized tanks or containers. <br />In the truck shop area, absorbent contaminated with oil was found a garbage can. <br />This is a violation of California Health and safety Code Section 25189.5. All <br />hazardous waste shall be disposed of at authorized facilities and in authorized <br />containers. <br />Sierra Chemical Response and Action: <br />The material referenced by EHD was in the hydrochloric acid repack containment <br />area. It was contained and not disposed to the environment. The material was <br />cleaned up and pumped to primary storage for use in dilution of product as <br />required. Kasey Foley EHD was notified by letter August 30, 2005 of the status <br />of the violations. <br />Steps taken by SCC: <br />The low pH material that was on the concrete loading area was removed the day <br />of the inspection. The supervisors and employees working in the area were <br />instructed that the concrete has to be kept dry and clean. <br />The material in the sump was removed the day of the inspection. The supervisors <br />and employees working in the area were instructed that the sump has to be <br />pumped out and cleaned following any activity in the area. <br />The absorbent contaminated with oil was containerized in a closed container and <br />labeled "Hazardous Waste -Hydrocarbon Contaminated Floor Dry", with an <br />accumulation date of 28 July 2005. A training class on Used Oil Management <br />(based on DTSC-Used Oil and Oil Filter Management Fact Sheet, April 2003) <br />was conducted by Jeffrey Kinder of CFR Services. The material was removed <br />from the facility on October 10, 2005 by Shop Hazards Solutions. A copy of the <br />invoice as well as the Uniform Hazardous Waste Manifest was provided to Ms <br />Foley by letter dated October 17, 2005. <br />