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Cindy Vo [EH] <br />From: <br />Cindy Vo [EH] <br />Sent: <br />Wednesday, April 29, 2015 9:33 AM <br />To: <br />'edward.phillips@bnsf.com' <br />Subject: <br />Return to Compliance: Hazardous Waste Inspection for 801 Diamond Street Facility on <br />6/27/2013 <br />Attachments: <br />1_manifest_009944510JJK_50g of used oil.tiff, 2_manifest_009216148JJK_80g of used <br />oil.tiff, 3_manifest_010387057_400P DEBMS cont w oil and 330G oily water.tiff, 4 <br />_hazardous waste label_label with hazardous property.pdf, 5 -Return to Compliance <br />Certification Form.doc <br />Good Morning Edward Phillips, <br />Thank you for submitting your statement for the hazardous waste inspection conducted on 6/27/2013 by Jeffrey Wong. <br />Based on the amount, an average of approximately 167kg/month, this facility generated in 2012, it is not classified as a <br />Conditionally Exempt Small Quantity Generator (CESQG). Thus, the CESQG regulations does not apply to this facility. See <br />attachments 1,2, and 3 for manifests of hazardous waste generated in 2012 at this facility. <br />With that being said, I still need a statement documenting what corrective actions were taken or will be taken for the <br />following violations and the Return to Compliance Certification form: <br />• 404- failed to keep containers of HW closed except when adding or removing HW <br />• 703 -failed to comply with Code of Federal Regulations 262.34(d), (e), and (f) <br />• Signed and dated Return to Compliance Certification ( should have been attached to the inspection report, if not <br />please see attachment 5) <br />Although the following violations have been marked as corrected, I want inform you: <br />605 -failed to completely label containers or tanks of hazardous waste <br />You attached a photo (see attachment 4) of these containers properly labeled for removal, please ensure that you are <br />marking off the hazardous property of the content per section 66262.34 (f)(3)(B). <br />701 -Stored hazardous waste onsite greater than 180 days <br />With the destination facility exceeding the 200 miles, you may use the accumulation time of up to 270 days, but the <br />facility must label the accumulation start date to ensure that it does not exceed the 180 days or 270 days if the <br />Treatment Storage Disposal Facility (TSDF) is over 200 miles away. Without the accumulation start date, there is no <br />evidence of how long the hazardous waste has been stored onsite. So you are welcome to use either accumulation time <br />but ensure that it is properly labeled. <br />Please contact me at 209-468-8257 if you have any questions. <br />Thank you, <br />Cindy Vo <br />San Joaquin County <br />Environmental Health Department <br />1868 E. Hazelton Avenue <br />Stockton, CA 95205-6232 <br />