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N Angelica Sandoval Marin [EH] From: Robert McClellon [EH] Sent: Wednesday, October 21, 2015 12:24 PM To: Angelica Sandoval Marin [EH] Subject: FW: Manifest Request from San Joaquin Inspector FYI, see below. Robert From: Strough, Barbara@CalRecycle [mailto:Barbara.Strough@CalRecycle.ca.gov] Sent: Wednesday, October 21, 2015 9:27 AM To: Robert McClellon [EH] Subject: RE: Manifest Request from San Joaquin Inspector Robert, Thanks for looking into this. When manifests are missing we don't ask the operator to recreate the past, and the Inspector has the option of issuing an Area of Concern or a Notice of Violation for the missing manifests. When just a few manifests are missing we recommend issuing an Area of Concern. When a lot of manifests are missing (which is a judgment call the Inspector makes), we recommend issuing a Notice of Violation with a compliance date 90 days from the inspection date. During the reinspection the Inspector would only look at the manifests from the previous inspection date to the reinspection date to ensure the operator has established a routine of properly maintaining the manifests. When a fire destroys records I agree with Ms. Marin's desire to be accommodating and understanding because the manifests aren't missing because of negligence. This operator has been inspected 13 times since May 2005 and there have been 2 NOVs, the last one issued in Jan 2010, and both of the NOVs were for failing to keep manifests. I recommend telling Terrill Transportation that they do not have to get copies of any manifests that were destroyed in the fire. As for what to write in the inspection report, we'll leave the judgment call to you and your Inspector about whether an Area of Concern or a Notice of Violation should be issued for manifests missing due to a fire. Thanks again, Barbara From: Robert McClellon [EH] [mailto:RMcClellon@sicehd.com] Sent:Wednesday, October 21, 2015 8:29 AM To:Strough, Barbara@CalRecycle<Barbara.Strough@CalRecycle.ca.gov> Cc:Angelica Sandoval Marin [EH] <amarin@sicehd.com> Subject: RE: Manifest Request from San Joaquin Inspector Barbara, here is what I found out. Ms. Marin was onsite conduct the inspection and the site recently suffered from a fire. It was obvious that the site did not have the manifests. Ms. Marin offered the operator the option of obtaining the manifests.She did not want to cite the operator for the non-compliance. What direction do you propose?We are willing to change our approach with your guidance. Robert 1