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Stacy Rivera [EH] From: Ava Kenney [Ava.Kenney@stocktongov.com] Sent: Thursday, December 15, 2011 4:14 PM To: Stacy Rivera [EH] Cc: Jeff Willett; Kirk Cloyd; Larry Parlin Subject: City of Stockton MUD Hazardous Waste Generator and APSA Program Return to Compliance Update: Part 1 of 2 Greetings Stacy, Per our telephone conversation in November, I am providing you with an update on the work we have done to complete our Hazardous Waste Generator and APSA Program return to compliance tasks. This update is keyed to your Hazardous Waste Program Inspection Report, dated 05/11/2011 and our most recent Update, dated 8/3/2011: Hazardous Waste Program Inspection Report outstanding issues: #7 - Metal fines generated and captured in various metal working machinery in the Maintenance Shop have been sampled and sent to California Laboratory Services for Hazardous Waste determination on 12/7/11. These results are expected by 12/26/2011 and will determine the management of this waste stream. In the interim, metal fines have not be sent to recyclers since 05/11/2011. The two aerosol cans of wasp killer and electronic fogger that were removed from trash cans at the time of the inspection were placed back in use until confirmed empty. The two empty cans of wasp killer were then disposed of as solid waste. Maintenance Division Management is investigating if there is a need to change the aerosol can disposal policy in light of the discovery of the Wasp Killer cans and electronic fogger found in the solid waste were not completely empty. #20 - The empty 55 gallon drum which previously held used anti-freeze was cleaned by using absorbent pads which were disposed in a designated oily waste disposal drum. The drum was then recycled as a solid waste collection can. The Hazardous Property section of the label for the 55 gallon black steel drum depicted in Photo #3 in the Cogen Building has marked as flammable. It is the policy of MUD to ensure that all future Hazardous Waste labels are completely filled out with all six required pieces of information. #23 - MUD staff has been unable to locate Bills of Lading for the recycling of used oil filters. MUD staff will file and keep for 3 years, all future used oil filters Bills of Lading. #32 - Condor Earth Technologies is under contract to provide MUD with an appropriate Hazardous Waste Aboveground Storage Tank assessment for all MUD Hazardous waste storage tanks. Initial inspection of our tanks by Condor's tank subcontractor occurred on Nov. 14th with a follow up inspection that occurred on Dec 1st. Tank maintenance, repair and certification is scheduled to be completed by Feb. 2012. #35 - Operations and Maintenance are currently conducting daily inspections of the Hazardous Waste Tanks and associated equipment. Copies of current logs will be provided to you upon your request. #45 - Condor Earth Technologies is assisting MUD with a Hazardous Material Contingency Plan update that will be consistent with our Emergency Response Plan and associated Hazardous Material Management Plan (HMMP) . Reviews and updates of this plan is underway and expected to be complete in Feb. 2012. #47 - The Emergency Coordinator of this facility is the Senior Plant Supervisor (24 Hour shift; rotating personnel) Cell#993-6212 when the Chief Plant Operator, Fermin Garcia, is not on the Facility. In Mr. Garcia's absence, the Deputy Director of Waste Water is the emergency Coordinator. Contact information is listed on the HMMP #2173 and #4412 (Tertiary Plant) . 1