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RECEIVED <br /> Vorke <br /> 0� (' ; 2018 <br /> ENVIRONMENTAL HEALTH <br /> ENGINEERING, LLC °ERNMSERVICES <br /> www.Yorl<eEngr.com <br /> December 5, 2018 <br /> John Alaniz <br /> San Joaquin County Environmental Health Department <br /> 1868 East Hazelton Avenue <br /> Stockton, CA 95205-6232 <br /> Work: 209-468-3420 <br /> E-mail:jalanizl@sjcehd.com <br /> Subject: Return to Compliance—Newark Recycled Fibers, 800 W. Church Street, <br /> Stockton, CA,CERS ID 10180985 <br /> Ref: Inspection Report Dated November 6, 2018 <br /> Dear Mr. Alaniz: <br /> Yorke Engineering, LLC (Yorke) is responding on behalf of the Newark Recycled Fibers faciIit\ <br /> at 800 W. Church Street, Stockton, CA, CERS ID 10180985. This letter documents the Return to <br /> Compliance status(Attachment 1), responds specifically to alleged violations, and describes other <br /> measures taken by the Newark Recycled Fibers facility to promote future compliance. <br /> DISCUSSION <br /> The citations from the November 6, 2018 are repeated in whole or in substantial part below in <br /> italics and followed by a response. In a number of items related to maintenance of facility rolling <br /> stock there may have been a wrong assumption made during the site inspection or comments by <br /> facility personnel were not clearly stated. When extensive maintenance is performed on equipment <br /> like front-end loader or forklifts,the equipment is usually taken off-site where the full maintenance <br /> is performed in the vendor's shop. <br /> Item # 102 <br /> CCR 66262.11 Failed to determine if a waste is a hazardous waste. <br /> The general manager stated that several different companies come to service the forklifts and the <br /> front-end loader(such as Pape Machinery, Watts and Linde) and take waste generated back with <br /> them. No disposal records for used coolant waste were observed during the inspection. <br /> Immediately make a hazardous waste determination on any waste that is generated through the <br /> repair company. If the waste is deemed to be hazardous, manage according to hazardous waste <br /> laws and regulations. <br /> In most cases the used coolant would be generated when equipment maintenance is <br /> performed off site. If used coolant is generated on site it will be managed as a California <br /> Hazardous Waste. The proper management of used coolant was discussed in hazardous <br /> waste training provided to Newark Recycled Fibers personnel by Yorke on December 4, <br /> 2018. Going forward if used coolant is generated on site, it will be managed as a hazardous <br /> waste with proper records maintained. <br /> Item #104 <br /> CCR 66262.34(d)(2)No modified contingency plan. <br /> LOS ANGELES/ORANGE COUNTY/RIVERSIDE/VENTURA/SAN DIEGO/FRESNO/BERKELEY/BAKERSFIELD <br /> 31726 Rancho Viejo Road, Suite 218 ♦ San Juan Capistrano, CA 92675 ♦ Tel: (949) 248-8490 ♦ Fax: (949) 248-8499 <br />