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°P CSAN JOAQUIN <br />_M.: COUNTY <br />Greatness grows here. <br />October 11, 2019 <br />EHD/COPA Case Number: EN0005760 <br />Jordan Bottorff <br />EHS Manager <br />3028 Navy Drive <br />Stockton CA 95206 <br />Environmental Health Department <br />Linda Turkatte, REHS, Director <br />Kasey Foley, REHS, Assistant Director <br />PROGRAM COORDINATORS <br />Robert McClellon, REHS <br />Jeff Carruesco, REHS, RDI <br />Willy Ng, REHS <br />Muniappa Naidu, REHS <br />Michael Kith, REHS <br />Re: Notification of Potential Filing of Administrative Enforcement Order <br />Pacific Ethanol Stockton LLC <br />3028 Navy Drive <br />Stockton CA 95206 <br />Dear Ms. Bottorff <br />On December 6, 2019 representatives of the San Joaquin County Environmental Health <br />Department ("EHD"), which is the certified unified program agency ("CUPA") in this <br />jurisdiction, conducted a routine Aboveground Petroleum Storage Act inspection and a routine <br />Small Quantity Generator Hazardous Waste at 3028 Navy Drive, Stockton CA 95206, (the <br />"Facility"). <br />On February 11, 2019 a Small Quantity Hazardous Waste Generator Compliance Review <br />reVort was issued based on the review of documentation on site and submitted to the EHD on <br />a later date. <br />During the inspections and subsequent documentation review, EHD discovered violations of <br />law and, based on those findings, EHD is prepared to bring an administrative action against <br />Pacific Ethanol Stockton LLC pursuant to California Health and Safety Code (HSC) § <br />25404.1.1. The administrative action is to ensure compliance with applicable statutes and <br />assess penalties for violations. A copy of the inspection reports are enclosed. <br />EHD has found that the Facility is/was in violation of the following regulations: <br />1. California Code of Regulations (CCR) 66262.20 Failed to prepare manifests for <br />transportation of hazardous waste <br />2. CCR 66262.12 Managed a hazardous waste without an identification number <br />3. CCR 66262.11 Failed to determine if a waste is a hazardous waste <br />4. CCR 66262.40(c) Failed to retain hazardous waste determination including waste <br />analysis <br />1868 E. Hazelton Avenue Stockton, California 95205 T 209 468-3420 F 209 464-0138 1 www.sjgov.org/ehd <br />