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III. OWNER/OPERATOR: Circuit Works Incorporated (CWI), is located at 152 Frank West Circle in Stockton, California. This is the sole location for manufacturing and sales for CWI products. The general manager of CWI is John Heath. IV. GENERAL BACKGROUND: On April 28, 1987, PHS-EHD received complaint #87-747 alleging untreated hazardous wastewater from CWI was entering into the city sewer system, and drums of hazardous waste were remaining on site for more than 90 days. On April 29, 1987, a site inspection of CWI was conducted in response to complaint #87-747 regarding illegal discharge of hazardous wastewater into the city sewer and illegal storage of hazardous waste. This inspection was performed by the City of Stockton Municipal Utilities District, State Department of Health Services (DHS), and PHS-EHD. on June 26, 1987, DHS sent CWI a Report of Violation and Schedule of Correction for the inspection conducted on April 29, 1987. Six hazardous waste violations were documented. 1. Storing hazardous waste in excess of 90 days and without proper labeling. 2. Treating hazardous waste without a hazardous waste permit or variance. 3. Treating and disposing of hazardous waste to the sewer without an National Pollutant Discharge Elimination System (NPDES) permit. 4. Not completing a biennial report, and submitting this report to the Department of Health Services. 5. Lack of a training program for all employees who are involved with hazardous waste management. 6. Storing hazardous waste in uncovered drums. on February 2, 1989, the City of Stockton Municipal Utilities District sent a complaint to the San Joaquin County District Attorney's office regarding corrosives discharged into the sewer system by CWI on December 20, 1988. This complaint requested the County District Attorney's office to take legal action against CWI, and requested that CWI complete a Spill Prevention Plan, and submit a compliance schedule to the City 2