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� GFORGE OEUN MFIIAN Gorwmd <br /> -$141f OF GSIIFORNU—NEALIN AND WELFARE AGENCY• <br /> DEPARTMENT OF HEALTH SERVICES InyT-` a <br /> TOXIC SUBSTANCES CONTROL PROGRAM Q`v May 30, 1990 REGION 1 <br /> 10151 CROYDON WAY,SUITE 3 EPA ID# 8210020832 <br /> SACRAMENTO.CA 95827-21D6 <br /> (916) 855-7700 <br /> Colonel James W. LaBounty % mi a <br /> Commanding Officer <br /> Sharpe Army Depot <br /> Lathrop, CA 95331-5000 F <br /> � a� r 1990 <br /> SAN JOAQUIN COUNTY <br /> Dear Colonel LaBounty: PUBLIC HEALTH SERVICES <br /> ADMINMRATfOn1 <br /> REPORT OF VIOLATION <br /> On April 16-17 , 1990, the California Department of Health <br /> Services, Toxic Substances Control Program (Department) <br /> conducted an inspection of the hazardous waste facilities and <br /> records at Sharpe Army Depot (SHAD) . <br /> As a result of that inspection, violations of hazardous waste <br /> statutes and regulations were identified. <br /> Report of Violations: <br /> 1. Title 22, California Code of Regulations (CCR) , <br /> section 67102 (b) : <br /> SHAD did not follow its own Waste Analysis Plan with <br /> regard to a disposal of Industrial Wastewater <br /> Treatment Plant (IWTP) sludge waste at the City of <br /> Stockton Publicly OwTled Treatment Works (POTW) on or <br /> about September 20-21, 1989 . <br /> SHAD' s Waste Analysis Plan identifies the sludge <br /> waste produced at the IWTP as a hazardous waste and <br /> specifies U.S. Environmental Protection Agency (EPA) <br /> methods 8240 and 7000-series as the appropriate _ <br /> analytical methodology to be used to evaluate it <br /> (Table V-2 , page V-8) . The Waste Analysis Plan also <br /> requires analysis of a waste when its composition is <br /> unknown or when it is thought to be complex in nature <br /> (page V-5) . <br /> SHAD failed to analyze the IWTP sludge waste or to <br /> handle it as a hazardous waste prior to and during <br /> the transportation , and disposal of approximately <br /> 39 , 000 gallons of - he sludge at the Stockton POTW on <br /> or about September 20-21, 1989 - As a result, this <br /> waste was offered to :and transported byanunlicensed <br /> hauler (Parrish and Sons, Stockton) and disposed -of -` <br /> at an unpermitted Facility (Stockton POTW) . <br />