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i <br /> Pick-n-Pull Auto Dismantlers RECEIVED <br /> 10860 Gold Center Drive, Suite 250 <br /> Rancho Cordova, CA 95670 JAN 2 1 2020 <br /> January 16, 2020 ENVIRONMENTAL HEALTH <br /> UEl AUN-1ENT <br /> Lydia Baker <br /> Registered Environmental Health Specialist <br /> San Joaquin County Environmental Health Dept. <br /> 1868 E. Hazelton Avenue <br /> Stockton, CA 95205 <br /> RE: Hazardous Waste Generator Inspection Report Response <br /> Stockton Pick-n-Pull,3927 Clark Drive, Stockton, CA, CERS ID 10183141 <br /> Dear Ms.Baker: <br /> On October 10 and 11,2019 a comprehensive hazardous waste generator inspection was conducted <br /> at the Pick-n-Pull Auto Dismantlers(Pick-n-Pull)facility located at 3927 Clark Drive in Stockton, <br /> California (Site) by San Joaquin County Environmental Health Department (County). The <br /> inspection included a detailed walk-through of the Site and identification of each instance where <br /> staining was observed,where vehicles were alleged to be leaking, or where vehicle parts (e.g., oil <br /> filters, coolant reservoirs, etc.) appeared to contain fluids. This letter provides responses to the <br /> findings of that inspection as noted in the RCRA Large Quantity Hazardous Waste Generator <br /> Inspection Report (Inspection Report) provided electronically to Pick-n-Pull on November 13, <br /> 2019 and an amended report provided on January 8,2020. <br /> Hazardous Waste Determination -#102 <br /> During the inspection,metal fines from tool sharpening activities were observed to be on the floor <br /> near the grinder,inside the warehouse. The fines were promptly swept up and placed into a proper <br /> container on October 11, 2019. A picture of the container of the fines is provided in Attachment <br /> 1. The fines were characterized for disposal as nonRCRA hazardous waste based on their metal <br /> content and small particle size(< 100 microns). <br /> During the inspection,the County alleged that an incomplete hazardous waste determination was <br /> made for wastewater that was disposed of as a nonhazardous waste on December 27-28, 2018. <br /> The Inspection Report claims that McCampbell Analytical, which tested the wastewater prior to <br /> disposal,used an incorrect test method (EPA Method 200.8)to characterize the waste. <br /> 10860 Gold Center Drive,Suite 250,Rancho Cordova,CA 95670 <br /> www.picknpull.com/www.schnitzersteel.com <br /> PICK-N-PULL US: AR:Cabot—Little Rock*CA:Antelope—Chico—Fairfield—Fresno—Merced—Modesto—Moss Landing—Moss Landing Premier—Newark—Oakland—Rancho Cordova—Redding— <br /> Richmond—Rocklin—Sacramento—San lose North—San Jose South—Stockton—Stockton Premier—Windsor*FL:Panama City—Tallahassee•IL:Summit—Wadsworth •IN:Hammond KS:Kansas <br /> City 121h Street *MA:Freetown-Millis *MO:Kansas City Truman Road—Kansas City Winner Road—Springfield—St.Louis *NV:Carson City—Sparks -OH:Columbus •OR:Portland North— <br /> Portland South—Sherwood-TX:Dallas South—Dallas South Central—Dallas West—Fort Worth—San Antonio—Waco*UT:Salt Lake City•VA:Virginia Beach *WA: Arlington—Lynnwood—Tacoma <br /> —Vancouver <br /> ,SADA: *AB:Calgary 52"Street—Calgary Barlow Trail—Edmonton•BC: Kelowna—Mitchell Island—Surrey <br />