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Backus, Garrett <br /> From: Backus, Garrett <br /> Sent: Thursday, October 17, 2019 4:12 PM <br /> To: 'Smith, Lisa' <br /> Cc: 'Bret Smith'; Smith, Falynne; Cashman,Jason; Ruvalcaba, Cesar <br /> Subject: RE: Port of Stockton/ Inspection Response - SPCC Plan <br /> Lisa, <br /> I'll go ahead and file what you've sent me. The following violation from 10-13-17 has not been resolved: <br /> Violation 102—CCR 66262.11 Failed to determine if a waste is a hazardous waste <br /> Metal fines generated from metal grinding and cutting are being accumulated and were found during the 2016 <br /> inspection to be disposed of without first determining particle size or hazardous properties. According to Rita Koehnen, <br /> a sample of the metals was taken for analysis, but no analysis has been conducted. <br /> Any person who generates a waste shall determine if the waste is a hazardous waste. Immediately stop recycling metal <br /> fines, make a hazardous waste determination for the metal grindings and roofing tar waste, and manage them according <br /> to Title 22 hazardous waste regulations. Metal particles 100 microns or smaller must be handled as hazardous waste if <br /> the metal is determined to be a hazardous waste. Submit a statement and supporting documentation explaining how <br /> these wastes were managed. <br /> How are metal fines being handled? <br /> Thank you, <br /> Garrett Backus, Ld. Sr. REHS, CUPA programs <br /> San Joaquin County Environmental Health Department <br /> 1868 E Hazelton Ave, Stockton, CA 95205 <br /> (209)468-2986 gbackus(a-sigov.orq <br /> https://www.sigov.org/departmenVenvhealth/ <br /> Please note my email has changed. <br /> SAN J OAN I N <br /> COUNTY <br /> From:Smith, Lisa <Ismith@stocktonport.com> <br /> Sent:Thursday, October 17, 2019 3:49 PM <br /> To: Backus, Garrett<gbackus@sjgov.org> <br /> Cc: 'Bret Smith' <bsmith.compliancefirst@gmail.com>; Smith, Falynne<fsmith@stocktonport.com>; Cashman,Jason <br /> <jcashman @stocktonport.com>; Ruvalcaba, Cesar<cruvaIca ba@sjgov.org> <br /> Subject: RE: Port of Stockton/ Inspection Response -SPCC Plan <br /> Garrett, <br /> 1 <br />