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RE: Lodi Metal Tech <br /> April 1, 1994 <br /> Page 2 <br /> Invoices for our charges were submitted to the SWRCB in April of 1990 for <br /> October-December 1989, in June 1990 for January-March 1990, in September <br /> 1990 for April-June 1990, in January 1991 for July-September 1990, and in <br /> February 1991 for October-December 1990. <br /> Our office did not receive copies of the bills sent to you by the SWRCB. <br /> However, we were notified in June of 1990 that bills for March 1989-March <br /> 1990 were being prepared; in May of 1991 that the bills for April 1990-June <br /> 1990 were being sent, and in November 1991 that July 1990-December 1990 <br /> were going out. <br /> The cover letter sent by the SWRCB with the initial invoices indicated that "You <br /> will be billed at a future date for State Board program management" costs. 1 <br /> have enclosed a sample copy of that letter. <br /> In summary, I agree that the bills sent by the SWRCB were very late and that <br /> the separate billing for their costs must have been confusing. In defense of the <br /> SWRCB, cost recovery billing was a new endeavor for their agency and was <br /> more complex than anticipated. The legislature and the SWRCB responded to <br /> the many complaints about the billing process and made substantial changes <br /> in the process. I understand that responsible parties are now billed on a more <br /> frequent basis. I would also add that the reason for the delay in billing for the <br /> State costs was to spread the cost over a greater number of sites thereby <br /> reducing the overall cost per hour. <br /> 2) You indicated that your facility was recently inspected by a State Department <br /> of Toxic Substances Control(DTSC) representative who was accompanied by <br /> a member of our staff. You had questions about the role and activities of our <br /> inspector. <br /> With regards the fact that the DTSC inspector put on a protective suit and <br /> boots while our inspector did not: The DTSC inspector chose to wear cotton <br /> coveralls and boots solely in order to protect his street clothes. Our inspector <br /> did not choose to do the same. <br /> Tiered-permitting is a new program for hazardous waste facilities. Our staff <br /> person was invited to accompany the DTSC inspector to familiarize our staff <br /> with the procedures. At the current time, the DTSC is regulating these <br /> activities although our agency may perform these inspections in the future. <br /> During the inspection, it was pointed out that waste oil generated on one <br />