Laserfiche WebLink
Qualex Inc. <br /> 120 Colonial Drive CQUalex KodakAuburn,CA 95603 aRocessw� <br /> June 30, 2000 <br /> San Joaquin County Public Health Services <br /> Environmental Health Division <br /> 304 East Weber Avenue, Third Floor <br /> Stockton, CA 95202 <br /> Attention: Michael Kitts <br /> Regarding: Unified Program Hazardous Waste Inspection Report, 612100 <br /> Dear Mr. Kith: <br /> I am a Regional Health, Safety and Environment Manager with Qualex, Inc. Our <br /> Manteca facility staff contacted me and requested assistance after your 6/2/00 <br /> inspection of their site at 555 Inqustrial Park Drive. t reviewed your inspection report <br /> with them, and drafted the 6/9/00 response letter from Jeff Rose to you. <br /> I am writing to you now to address finding number 49—"Personnel training records did <br /> not have job description and hazard/chemicaf involved. Update personnel training <br /> record as described in CCR 66265.16." You requested a response by July 7. <br /> As you may know, CCR 66265.16 is located under Title 22, Division 4.5, Chapter 15, <br /> Article 2. Chapter 15 addresses "Interim Status Standards for Owners and Operators <br /> of Hazardous Waste Transfer, Treatment, Storage, and Disposal Facilities". As a <br /> photoprocessor who generates silver-bearing spent processing solutions that are <br /> treated onsite for silver removal, without prior storage or accumulation, Qualex Manteca <br /> does not fall under any of the above categories. Therefore, these requirements are not <br /> applicable to this operation. <br /> However, the safety and operational training Qualex provides to employees who mix <br /> chemicals and operate the waste water treatment system does, in fact, satisfy the <br /> requirements of CCR 66265.16. Although we contend that the training requirements <br /> cited in CCR 66265.16 are not applicable, as we are not a transfer, treatment, storage <br /> or disposal facility, per your request, we have compiled records into one training <br /> document for each chemical mixing employee. Enclosed is a copy of the training <br /> record for the employee related to your citation. <br /> The confusion regarding this issue, and the issues cited in your notes related to finding <br /> #75 (Tiered Permitting Inspection and Manifests), reflect a lack of familiarity with the <br /> effects of Senate Bill 2111. As I have discussed with Mr. Doug Wilson of your <br /> department, SB 2111, which took effect in January 1999, stipulated that Califomia <br /> "silver only" hazardous wastes are to be regulated only to the extent they are regulated <br />