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DEFENSE LOGISTICS AGENCY <br /> DLA INSTALLATION SUPPORT AT SAN JOAQUIN <br /> P.O. BOX 960001 STOCKTON, <br /> CALIFORNIA 95296-0001 <br /> August 1, 2019 <br /> Nicholas Loehrer,REHS <br /> San Joaquin County Environmental Health Department 1868 <br /> E. Hazelton Ave. <br /> Stockton, CA 95205 <br /> Nicholas Loehrer, <br /> DLA Installation Management at San Joaquin's Environmental Office has reviewed the San Joaquin County <br /> Environmental Health Department's (SJCEHD)Hazardous Material Program Compliance Review Report, <br /> PR0520316, dated July 8,2019. DLA did not negligently contribute to the violation described in PR0520316 <br /> and was not made aware of any spill released by Cemex resulting in the off-site removal of 300 pounds of <br /> "soil/diesel"prior to receipt of PR0520346. The following constitutes as our statement and supporting <br /> documentation in dispute of the Class I violation, "failure to report actual or threatened release to the EHD <br /> and/or CalOES"(Enclosure 1,Return to Compliance Certification): <br /> 1. DLA requires proper and immediate spill reporting by performing contractors on our site. We <br /> consistently brief and share documented environmental controls(Enclosure 2, DLA San Joaquin <br /> Environmental Checklist and Environmental Controls)with performing contractors during the <br /> solicitation phase and pre/post-award meetings. The checklist and controls at Enclosure 2 <br /> specifically address contractor obligations to report spills and procedures for generating and <br /> manifesting hazardous waste on our site. <br /> 2. Spill reporting procedures are in DLA Distribution San Joaquin's Spill Prevention Control and <br /> Countermeasures Plan. Person having or discovering the spill must notify Fire Department, Safety <br /> and Environmental. Environmental will assess the spill for any threats or potential threats to the <br /> environment,navigable waters and/or human health and report the spill in accordance with Cal <br /> OES and HSC regulatory requirements. DLA provided generator manifesting information to <br /> Gilbane on June 23, 2016(Enclosure 3, Supporting Documentation). <br /> 3. DLA researched DLA San Joaquin environmental and installation security and emergency <br /> services records going back six months from 03/20/17,the date on Manifest#016772566JJK. <br /> DLA was not notified by the controlling contractor, Cemex,that any spill had occurred during <br /> this period, and we do not have any record of this spill occurring. <br /> 4. In order to further respond to the violation described in PR0520316,DLA requires details from the <br /> SJCEHD stating what day the alleged spill occurred,where it occurred,the process generating the <br /> alleged spill,and any documentation showing that DLA had knowledge of, characterized,handled, <br /> or offered the 300 pounds of"soil/diesel"for disposal on Manifest#016672566JJK. <br /> Note:During a scheduled inquiry with the SJCEHD staff(Nicholas Loehrer and Muniappa Naidu) <br /> on July 30, 2019 at 3:30 pm, DLA Installation Management's Environmental Office asked if the <br /> SJCEHD could provide more specific details concerning date and time spill occurred, how much <br /> diesel fuel was spilled and which DLA representative and/or office was notified of the spill. We are <br /> currently awaiting these details from the SJCEHD. <br /> 5. Manifest#016772566JJK did not originate from any DLA organization. The manifest did not <br /> have our EPA ID#, and DLA did not certify the manifest. DLA does not have"generator <br /> knowledge"of the process that generated the waste offered for shipment on Manifest# <br />