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SJC ENVIRONMENTAL HEALTH DEPARTMENT ;Rf ATTN: GARRETT BACKUS <br /> 1868 E HAZELTON AVENUE S P X <br /> STOCKTON, CA 95205 <br /> February 25,2022 <br /> RE: SPX COOLING TECHNOLOGIES INC.,200 N WAGNER AVE., STOCKTON; CERS <br /> ID 10182275 <br /> Dear Mr. Backus, <br /> I am pleased to make your acquaintance and hope you found our new environmental <br /> consultant for this site, Guy Graening of GHD,helpful on the day of inspection. We received <br /> your Large Quantity Hazardous Waste Generator Inspection Report dated February 18,2022, <br /> and Hazardous Materials Program Inspection Report dated February 18,2022. <br /> We wanted to proactively respond within the week, and not wait until the Return to <br /> Compliance Certification deadline of March 20,2022 (30 days from receipt), as we were able <br /> to correct and/or provide requested documentation for all alleged violations,but the two <br /> (#102, 502)marked"pending",which will be corrected within the original 30 day window. <br /> SPX Cooling Technologies, Inc. (SPX)provides this proactive response in a spirit of <br /> cooperation and reserves all rights and defenses to object to the allegations, and makes no <br /> admissions. <br /> Regarding the large quantity generator(LQG) characterization of the facility, as recognized <br /> on the header of the inspection report,there was no hazardous waste generated in Calendar <br /> Year 2021. As you observed,the sludge was recently removed from the groundwater <br /> extraction treatment system(GETS) and is being dried,which is part of routine maintenance <br /> every 1-2 years. As the liquid is removed during the drying process and sent back through <br /> the GETS,we have not characterized it as a waste in the past. In contrast to the liquid,the <br /> resulting solid waste is characterized as hazardous and manifested for disposal,with copies <br /> kept by SPX, sent to DTSC, and available to the CUPA upon request. This site has been <br /> operating for decades under this assumption,with agreements/permits,oversight and <br /> inspections by DTSC and RWQCB,without any indication this was inaccurate. We request <br /> your reconsideration of the large quantity generator status, and the tank items (#501, 502, <br /> 507). <br /> For line 114,regarding an alleged failure to keep signed copies of manifests, SPX has and <br /> maintains the manifests. Our new consultant, GHD,is still getting up to speed on this <br /> SPX Corporation 6325 Ardrey Kell Rd.Suite 400,Charlotte,NC 28277 www.spx.com <br />