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Washington, D.C. <br />Los Angeles <br />San Francisco <br />Mr. Doug Willson <br />McKenna & Cunw, LIP <br />Attorneys at Law <br />Suite 3300, Symphony Towers ■ 750 B Street ■ San Diego, CA 92101-8105 <br />619-595-5400 ■ Fax: 619-595-5450 <br />www.mckennacunco.com <br />June 6, 2000 <br />Supervising Manager <br />Public Health Services - San Joaquin County <br />Environmental Health Services Division <br />304 E. Weber Avenue, 3rd Floor <br />Stockton, CA 95202 <br />Denver <br />Dallas <br />Brussels <br />r <br />S. Wayne Rosenbaum -- <br />619-595-8032 -- _ <br />wayne_rosenbaum@mckennacitnec.crim <br />Re: Response to County of San Joaquin's Notice of <br />Violation of Unified Program Hazardous Waste <br />Management dated May 17, 2000 <br />Dear Mr. Watson: <br />The purpose of this letter is to respond to your Amended Notice of Violation <br />dated 5/17/00. While we do not necessarily concur with your analysis that <br />violations have occurred, we have, or will by the specified dates herein, <br />implemented specific structural and non-structural management practices to <br />address each of your concerns. <br />DISPOSAL OF HAZARDOUS WASTE AT AN UNAUTHORIZED POINT: <br />Health & Safety Code § 25189.5 <br />During your inspection of May 10th, you observed floor sweeps containing <br />sandblast beads being disposed of in a trash can in the caliper area. While we have <br />no evidence to assume that these floor sweeps are characteristically hazardous, out <br />of an abundance of caution QBR is currently, collecting, segregating and handling <br />these materials as though they were a hazardous waste. We intend to collect this <br />material for a period of not more than 60 days. At which time a representative <br />sample will be taken and sent to a California EPA approved laboratory for <br />evaluation. Should the materials be determined to be hazardous, we will continue <br />to handle them as such. Otherwise, we believe it is appropriate to dispose of this <br />