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McKenna & CUM, U... <br />Attorneys at Law <br />Mr. Doug Willson <br />Supervising Manager <br />June 6, 2000 <br />Page 5 <br />procedure is preferable to pulling the drums on a weekly basis, a procedure that has <br />a much higher probability of creating a spill through drum damage. However, if the <br />Agency disagrees with QBR's assessment in this matter, QBR will willingly meet <br />with the Agency to discuss effective alternatives. <br />T1,170C' O.NTA.,NER S OF �'HE SAME �XT_AS T E AT THE SAME S X T ELLI T c; <br />ACCUMULATION POINT IN THE RUST ARREST AREA: 22 CCR <br />66262.34(a) <br />QBR has fully reviewed and corrected this matter. <br />CONCLUSIONS <br />It remains unclear to QBR that many if not all of the instances cited in your <br />Notice of Violations dated May 17th are in fact violations of applicable regulations or <br />laws. However, QBR agrees with the Agency that in the vast majority of the <br />instances cited, operating and record keeping modifications identified in this letter <br />are to the benefit of all concerned. We hope that this letter adequately responds to <br />your concerns. Should you have further questions please do not hesitate to contact <br />me. As always, QBR's doors are open to the Department of Environmental Health <br />at any time. <br />Sincerely urs, <br />S. Wave o enbaum <br />SWR/dk <br />cc: Mr. Hubert Frings <br />David Iery, Esq. <br />