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Kasey Foley, REHS <br />December 22, 1992 <br />Page 2 <br />Violation #7 (employee training records): Within the next 30 days, PCP will complete and <br />maintain employee training records. A training session is scheduled to be taught by Michael <br />Hurley of Dufour Environmental and Resource Management, a C.S.T.I. certified instructor. <br />Violation #8 (communication or alarm system): PCP will arrange for the installation of a <br />communication or alarm system within the next few days. <br />Upon completion of all the above, PCP will send their written certification as requested. <br />As you know, PCP disputes Violation *4 which is bases on the fact that a biennial report <br />could not be located. Although Title 22 would lead one to believe that all generators must <br />submit a biennial report, the reference to title 40 of the Code of Federal Regulations <br />indicates that the requirement applies only to large quantity generators. A large quantity <br />generator is on that generates 1,000 or more kilograms of hazardous waste in a month. <br />Enclosed is a letter from the DTSC that confirms that the requirement applies only to such <br />large quantity generators. This was also confirmed by Gail McNeil of DTSC who is <br />responsible for biennial reports for the DISC. <br />A review of the hazardous waste manifests indicates that, indeed, PCP does not qualify as <br />a large quantity generator. Therefore, PCP is not required to provide the biennial report <br />cited in the Report. <br />We are working with DTSC on this issue. Ms. McNeil informs me that she will contact you <br />to explain this. Enclosed is my letter to Ms. McNeil confirming our understanding. <br />If you have any questions or need any further information, please call us. <br />Very truly yours, <br />DUFOUR & ASSOCIATES <br />MICHAEL R. DIKAYTON <br />MRD:ket <br />Enclosure as stated. <br />cc: Pacific Coast Producers <br />12/18/92/26003.08 <br />