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Sammons, Lynsey [EHD] <br /> From: Sammons, Lynsey [EHD] <br /> Sent: Tuesday, April 7, 2026 2:21 PM <br /> To: 'Jonah Sonner'; 'Frank Vallejo'; 'Philip Humphrey' <br /> Cc: Alaniz, John [EHD]; Presto, Carol [EHD] <br /> Subject: RE: [**EXTERNAL**] PR0538356, PR0538355, PR0543928 - HMBP, LQG HW, TP-PBR <br /> Compliance Info 2025 - 12.8.25 <br /> Hi Jonah, <br /> We were able to review all the RTC and CERS you submitted. I rejected the tiered permitting CERS <br /> submittal from 1/15/26 today and left comments. The property owner notification and prior enforcement <br /> history were not submitted. Even if they do not apply, those pages still need to be submitted. If they don't <br /> apply,you can mark"Exempt" and include a comment.Also, the estimate of closure cost needs some <br /> updating. Please see the feedback below: <br /> HMBP: <br /> • All violations closed <br /> LQG HW: <br /> • All violations closed <br /> Tiered Permitting: <br /> • Violation #7—Open. <br /> o What you submitted looks good. However, the inflation adjustment needs to indicate the <br /> year-by-year total with inflation. Since the original estimate for the filter press removal is <br /> from 2017,you'd need to show total with inflation for each year through 2026. The invoice <br /> for other waste disposal looks like it's from 2024, it would need to show inflation for 2025 <br /> and 2026. <br /> o The finalized closure cost estimate docs need to be submitted to CERS to close this <br /> violation. This is a CERS violation. <br /> • Violation #8—Open. It looks like 2025 was the last year inflation was adjusted for. Q3 data is <br /> available for 2025 now, so the closure cost estimate was required to be adjusted for 2026 by <br /> March 1st. The 2026 adjusted estimate needs to be uploaded to CERS,waiting for the next <br /> reporting period will delay closingthe violation. <br /> • Violation #20—Open. Since the sludge that enters the filter press is considered hazardous waste <br /> after leaving the tank, it would also need to be included in the waste analysis plan. Since the <br /> facility is not currently generating this waste stream, adding it to the waste analysis plan and <br /> indicating the plan will be updated when you resume generating the waste would be adequate to <br /> close out this violation. <br /> Let me know if you have any questions. <br /> Best, <br /> Lynsey Sammons <br /> i <br />