Laserfiche WebLink
J.R.Simplot Company <br /> Simplot Box 26955 <br /> Fresno,California 93 <br /> 93729-895955 <br /> (559)439-5728F@Business <br /> GROWER SOLUTIONS <br /> (559)439-5728 Fax <br /> 15 April 2016 RECEOVEE <br /> APR I �1 2016 <br /> San Joaquin County ENVIRONMENTAL HEALTH <br /> Environmental Health Department PERMIT/SERVICES <br /> 1868 East Hazelton Avenue <br /> Stockton, CA 95205-6232 <br /> Atten: Elena Manzo <br /> SUBJECT: aiTAPLOT S i OCK T ON NO i iCE TO ABATE E & AMENDED SQG <br /> HAZARDOUS WASTE INSPECTION REPORT OF 5 APRIL 2016 <br /> This letter is in response to your Notice to Abate, record ID# PR0539280, and your <br /> amended Small Quantity Hazardous Waste Generator Inspection report, pertaining to <br /> our Stockton facility located at 4863 Carpenter Road. Both the notice and amended <br /> report are dated April 5, 2016. <br /> The Notice to Abate resulted from an inspection your agency conducted at our facility on <br /> February 26, 2016. In the Notice, the sumps located in the fertilizer tank farm and <br /> chemical tank farm are referred to as underground storage tanks. The reference cited is <br /> California Health & Safety Code Section 25281(y)(1). The corrective action provided is <br /> to "immediately stop storing hazardous substances in the unpermitted USTs. Bring <br /> these USTs into compliance with the CCR Title 23 regulations, or discontinue the use of <br /> these tanks and obtain a tank closure permit from the EHD." We have reviewed the <br /> applicable California codes and regulations. and have determined that our sump <br /> structures are excluded from the definition of"underground storage tanks". Under <br /> California Health & Safety Code Section 25281(y)(1)(C), the term "underground storage <br /> tank" does not include: <br /> (C) Structures such as sumps, separators, storm drains, catch basins, oil field <br /> gathering lines, refinery pipelines, lagoons, evaporation ponds, well cellars, <br /> separation sumps, and lined and unlined pits, sumps, and lagoons. <br /> Under 23 CCR 2621(a)(7), the term "underground storage tank excludes: <br /> (7) A sump, pit, pond, or lagoon. <br /> Based on this information, we request that the Notice to Abate is rescinded. <br /> In the amended Small Quantity Generator Inspection Report, a new violation, item #102, <br /> was added to the existing report. The remarks listed under the violation make the <br /> presumption that the dilute fertilizer solution and spray oil rinsate are wastes, and that <br /> the facility "failed to determine if a waste is a hazardous waste or retain waste analysis <br /> on site for 3 years". The corrective action provided is to "immediately stop managing this <br /> rinsate and make a hazardous waste determination for the "diluted rinsate", and manage <br />