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INVESTIGATION CONCERNING ASBESTOES DISPOSAL 2355 W. ROBBERSON ROAD, STOCKTON OCTOBER 9, 1997 TED WITT (209)467-6660 By: Doug Wilson, Supervising RENS Steve Mindt, Senior REHS I made an inspection of premise with Steve Mindt, Sr. REHS. We noted as Mr. Mindt had originally seen, a pile of commercial truck brake pads. We were at the time attempting to locate the owner operator of the facility Mr. Ted Witt, Witt Feedlot, Stockton, CA. The pads were apparently removed from their metal holding drivers and still had the brass rivets protruding from the pads. We talked to several workers at the site who motioned us to go further back into the facility to find Mr. Witt. We located Mr. Witt to the west side of the barn and near the pond. Mr. Witt was told that there was concern over the brake pads being on the property and we had talked with a brake manufacturer concerning the asbestos content of commercial brake pads. We had found out that it was about a fifty percent chance that the brake pads did contain asbestos. I indicated to Mr. Witt that the only way we would know for sure was t to sample the pads and confirm if they were safe or not. Mr. Witt indicated that he did not want to sample today. I asked him why he didn't want it sampled. He indicated that he wanted to know if he would be fined. I indicated that I did not know what, if any, regulations would be charged against him if it were found to be asbestos. I indicated that it would be necessary to sample in order to determine if it was asbestos, which it may not be, but it needs to be confirmed for the safety of his workers as well as himself and his family. Mr. Witt indicated that he wanted the person who brought him the brake pads to take care of the problem. Mr. Witt stated that the person who brought him the brakes had informed him that they were supposed to be ground up and used for road base and someone had approved them to use them for that purpose. I informed Mr. Witt that I would really need to know who the responsible person was in order to find out if any testing or other information was available in order to determine if they were free of asbestos and safe. Mr. Witt indicated that the person who had brought him the brakes was well known to us (EHD) and that he wanted him to call us so that he could take care of the problem. Mr. Witt continued to be evasive about who the hauler was and we went into a guessing game of yes or no. Because Mr. Witt didn't want to be blamed for naming the other person. After several tries it was established that Bob Ronyack was the hauler. I informed Mr. Witt to have Mr. Ronyack call me and not to allow the removal of the material or he might cause additional violations for having the waste removed improperly to an unapproved disposal site. Mr. Witt agreed to allow sampling only after Mr. Ronyack had called EHD.