Laserfiche WebLink
ATTACHMENT 7: Corrective Action Response Regarding Vender Services that Generated Regulated Wastes <br /> WFS-Stockton leases equipment from third-party venders who own, and are responsible for the maintenance <br /> of, of equipment used by WFS personnel. Specifically, the facility uses the following venders: <br /> • Sunbelt Rentals supplies, and maintains, the diesel-powered generators distributed throughout the <br /> Stockton Station; and <br /> • Holt Equipment supplies, and maintains, the forklifts used at the Stockton Station <br /> Violations #113 and #608 of the 9/18/2019 inspection report incorrectly assigned generator compliance <br /> responsibility to WFS for the regulated wastes generated by Holt Equipment and/Sun Belt Rentals during <br /> maintenance of the leased equipment. In accordance with both EPA and DTSC guidance (see attached), since <br /> WFS neither owns the equipment being serviced nor are WFS personnel initiating the 'act' that generates the <br /> regulated wastes, the WFS Stockton Station is not the generator of the wastes produced as a consequence of <br /> maintaining the generators or the forklifts. <br /> Effective 3/15/2021, the Stockton Station's Lead Mechanic shall track and document the type and volume of <br /> regulated wastes generated, and removed from the facility, by Holt Equipment and Sunbelt Rentals when <br /> servicing vender-supplied equipment onsite. This information shall be maintained for a minimum of three (3) <br /> years and be made available up from Station management and/or regulatory agency representatives. <br />