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ASSOCIATE* <br />ATTORNEYS AT LAW <br />sAMES T. DUFOUR m <br />MICIIAEI. R. DRAYTON <br />� r <br />WILLIAM C. COLLIER <br />ENV!_,0 <br />E_ <br />October 21, 1994 <br />Mr. Eric Trevena, REHS <br />SAN JOAQUIN COUNTY ENVIRONMENTAL HEALTH DIVISION <br />445 North San Joaquin Street <br />P.O. Box 388 <br />Stockton, CA 95201-0388 <br />Dear Mr. Trevena: <br />819 F STREET <br />SACRAMENTO, CA <br />95814 <br />(916) 553-3247 <br />FAX (916) 553-3250 <br />Thank you for speaking with me regarding the above matter. This letter will summarize our <br />conversations this week. <br />On December 7, 1993, your office conducted an inspection at 835 South Stockton Street, Lodi, <br />California, the Can Manufacturing facility of Pacific Coast Producers. On the day the <br />investigation was performed, PCP representatives were informed of several issues raised by the <br />investigation. In an effort to be as responsive as possible regarding your concerns, PCP sent <br />a letter to you dated December 29, 1993. That letter discusses the concerns raised during the <br />inspection and includes a certification statement, in the form normally required by your office, <br />that all the statements in the letter are true and correct. <br />As we discussed, in view of PCP's letter to you dated December 29, 1993, the Report Of <br />Violations and Schedule Of Correction (ROV) dated October 5, 1994 comes as a surprise to <br />PCP. Additionally of concern is the fact that, the ROV includes matters that were based upon <br />misinformation and/or based on matters otherwise adequately addressed in PCP's letter dated <br />December 29, 1993. For example, the first "violation" states that, "Generator transported <br />hazardous waste to a facility that does not have a permit." It is our understanding that this <br />"violation" related to a statement made by Mr. Boyd Stevens of PCP during the investigation <br />regarding consolidation of waste oil from PCP's can manufacturing plant to PCP's cannery. A <br />PCP letter dated December 29, 1993, states "Please be informed that Mr. Stevens was in error <br />with respect to his statements. PCP has not, in fact, consolidated waste oils from these two <br />sources." Additionally, the third "violation" indicates that PCP stored hazardous waste on-site <br />for more than 90 days without a permit. However, PCP's letter explains that these drums were <br />stored pursuant to the "satellite storage" rule in 22 CCR §66262.34(e), which allows the <br />accumulation of up to 55 gallons per waste stream for up to one year, and that these particular <br />drums met the criteria for application of the satellite rule. <br />wp162\L\Tavaw.94 <br />