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Page 1 of 4 <br /> Stacy Rivera [EH] <br /> From: Ava Kenney [Ava.Kenney@stocktongov.com] <br /> Sent: Friday, December 16, 2011 11:03 AM <br /> To: Stacy Rivera [EH] <br /> Cc: Jeff Willett; Kirk Cloyd; Larry Parlin <br /> Subject: City of Stockton MUD Hazardous Waste Generator and APSA Program Return to Compliance Update: Part 2 of 2 <br /> Good Morning Stacy, <br /> Per my e-mail, City of Stockton MUD Hazardous Waste Generator and APSA Program Return to Compliance <br /> Update: Part of 2, sent to you on 12/15/11 at 4:14 PM, I am completing the update we discussed during our telephone <br /> conversation in November. Below, you will find, the remaining Hazardous Waste Program Inspection Report outstanding issues <br /> we discussed, this e-mail is also keyed to your Hazardous Waste Program Inspection Report, dated 05/11/2011 and MUD's most <br /> recent Update, sent to you, on 8/3/2011: <br /> #49 - Available Hazardous Waste Personnel Training Program records were sent to you on August 3, 2011. Completion of a <br /> written Hazardous Waste Personnel Training Program that complies with Title 22 Regulations and is keyed to the Hazardous <br /> Waste Contingency Plan and other associated Emergency Response and HMM Plans is underway and expected to be completed <br /> in February 2012. <br /> #50 -Tertiary Plant 250 gallon used oil tank is empted by Evergreen Environmental in conjunction with waste oil tanks located <br /> at the Main Plant. This process is documented by a Consolidated Manifests, using Waste Code# CA 221. Because this tank is <br /> under used (only collects on average 30 gallons in 90 days), MUD Management is considering closing this tank <br /> and collecting used oil generated at the tertiary plant in a 55 gallon drum that will be consolidated at main plant waste oil tanks <br /> for disposal. Consolidate Manifests will be forwarded to you by January 15, 2012. <br /> #60-62 - All missing manifests were located. Exception reports for all future manifests that are not returned to MUD within 60 <br /> days of the date the waste was accepted by the initial transporter sent to DTSC. <br /> #64 - Lead Acid Battery disposal records have not been located. All future Lead Acid Battery disposal records will be filled <br /> retained on site for 3 years. <br /> #79 - Fluorescent Bulb have been stored correctly and consolidated at MUD Stores for pick up by Evergreen Environmental. All <br /> future bulbs will be stored correctly in compliance with Universal Waste handling regulations. <br /> #83 - Four 14 Foot Fluorescent Bulb storage at Old Cogen Facility have been stored correctly and consolidated at MUD Stores <br /> for pick up by Evergreen Environmental. All future bulbs will be stored correctly in compliance with Universal Waste handling <br /> regulations. <br /> #84 - Disposal Records for alkaline batteries were provided as attachments to our August 3, 2011 update. Evergreen <br /> Environmental Bill of Lading dated, July 27, 2011, <br /> APSA Inspection Report Issues: <br /> Status of Spill Prevention Control and Countermeasures (SPCC) Plan - <br /> MUD Management has determined that the most environmentally compliant and operationally effective storage plan <br /> for petroleum based chemicals used at the Main and Tertiary Plants is to store all but (23-fifty five gallon drums, our after <br /> hours/emergency supply) on the Main Plant. All full Clarifloc totes have been re-positioned at the Old Cogen Facility. No full or <br /> empty totes will be stored at MUD Stores in the future. This brings MUD Stores Petroleum storage capacity below the 1,320 <br /> gallon SPCC Plan requirement. <br /> The Main Plant SPCC plan update in conjunction with the aboveground storage tank maintenance and certifications work is <br /> underway, and being performed by Condor Earth Technologies. SPCC Plan update is scheduled to be complete in February <br /> 2012. <br /> Please contact me with any question or concerns. <br /> 12/22/2011 <br />