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0 9 <br /> Nowark Sierra Paperboard_Corp. TNEWARK <br /> HE <br /> 800 West Church Street A Newark Group, Inc.Company -` - GROUP <br /> Stockton,CA 95203 Products from Recycled Fibers t i;, <br /> 209,466-5251 <br /> Fax 209/942-1214 7`O NOV 18 PM I: 98 <br /> November 15, 1996 <br /> Public Health Services <br /> San Joaquin County <br /> Environmental Health Division <br /> 304 E. Weber Ave•3rd Floor <br /> Stockton, CA 95201-0388 <br /> (209) 468-3420 <br /> Dear Letitia: <br /> This letter is regarding the Hazardous Waste Inspection Report and Certification <br /> of Return to Compliance form that you mailed on October 25, 1996. After <br /> reviewing the report and the articles that you have provided, I have a discrepancy <br /> on which regulation is applicable. <br /> According to CCR Section 66263.42 (b) (1), the hazardous waste is pursuant to <br /> the requirements of Title 40 of the CFR section 262.20(e) and 263.20(h). Upon <br /> reviewing these sections, it states that the general requirements of the manifest <br /> do not apply to the generator and that the transporter retains the records for a <br /> period of at least three years after the termination or expiration of the agreement. <br /> Also according to CCR Section 66263.42, it states that (1) the transporter will be <br /> responsible for completing both the generator and the transporter section of the <br /> manifest, (2) the transporter's name and EPA identification Number shall be <br /> entered in both the generator information and transporter information spaces of <br /> the manifest and (5) the transporter will send the generators copy to the <br /> Department. <br /> Newark Sierra has an agreement with Safety Kleen for a Milkrun Operation <br /> where Safety Kleen assumes responsibility as the generator and hence, Newark <br /> Sierra is not out of compliance. Please review and respond to this matter. <br /> Thank you. <br /> Sincerely, <br /> David K. Wong <br /> Technical Supervisor <br />