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McNeilus. <br /> 52 BOX 70 RECE � ((((=D <br /> 524 COUNTY ROAD 34 EAST [� '(,/vl^3 �\V��ItIV�._ <br /> DODGE CENTER, MN <br /> 507-374-6321 <br /> MAR 0 1 2010 Sent via email>;backusAsicehd.com;and U.S.Certified Mail <br /> February 22,2010 ENVIRONMENT HEALTH <br /> PERMIT/SERVICES <br /> Mr. Garrett Backus <br /> San Joaquin County Health Department <br /> 600 East Main Street <br /> Stockton,CA 95202 <br /> RE: Response Letter to February 18,2010 Hazardous Waste Inspection <br /> McNeilus Truck and Manufacturing,Inc.,Stockton,CA Service Center <br /> EPA ID#CAL000276412 <br /> Dear Mr.Backus: <br /> This letter serves as a follow-up to our telephone conversation of February 19,2010 and is our written response to the items <br /> identified on the Hazardous Waste Program Inspection Report from your February 18,2010 inspection of our Stockton,CA <br /> Service Center.The inspection report is included as Attachment 1 of this letter response. <br /> Item V. Failed to determine if a waste is a hazardous waste(CCR66262.11): <br /> Description of Findings: <br /> The facility has approximately ten 100m1 bottles of urethane two part resin which is out of date and cannot be used for <br /> its intended use. Make a hazardous waste determination as specified in Title 22 California Code of Regulations or <br /> dispose of this waste as hazardous waste. Send a copy of the disposal manifest to the Environmental Health <br /> Department by March 18,2010 or explain how this waste will be handled. Two photos were taken by the inspector <br /> and can be found in Attachment 2. <br /> Corrective Action: <br /> The manufacturer of the resin components contained in the ten 100m1(3.3 oz.)bottles has stated that the materials can <br /> be used beyond the 6 month expiration and therefore McNeilus does not consider this material to be a waste at this <br /> time. As part of our pollution prevention efforts,we are planning to use these materials for training purposes at the <br /> Stockton,CA and or other McNeilus facilities. <br /> Item#20. Failed to completely label containers or tanks of hazardous waste(CCR66262.34(f)): <br /> Description of Findings: <br /> A ten gallon container of empty and partially full aerosol cans was not labeled as hazardous waste(HW). HW <br /> containers must be labeled with"Hazardous Waste,"generator name and address,composition,physical state, <br /> hazardous properties and accumulation start date. Label the container as hazardous waste and correct immediately. <br /> Note that empty containers of aerosol cans can be labeled as"Universal Waste—Aerosol Cans." Dispose of <br /> hazardous waste within 180 days of initial accumulation. Dispose of universal waste within one year of initial <br /> accumulation. One photo was taken by the inspector and can be found in Attachment 3. <br /> Corrective Action: <br /> The aerosol cans were taken out of the container and placed into a steel collection drum immediately after the <br /> inspection. The drum was labeled as hazardous waste as shown in the photographs of Attachment 4. The waste <br /> aerosol cans are scheduled to be shipped to Rineco, Inc. (our waste disposal vendor located in Benton,Arkansas)for <br /> disposal on March 3,2010. A copy of the initial hazardous waste manifest will be promptly sent to you after the <br /> shipment as proof of disposal. <br />