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0Sims <br />METAL <br />MANAGEMENT <br />September 22, 2011 <br />Ms. Stacy Rivera <br />Environmental Specialist <br />County of San Joaquin <br />Environmental Health Department <br />600 East Main Street <br />Stockton, CA 95202-3029 <br />Tgeefane 510412-5300 <br />600 swth 4' Street Facv.de510412-5423 <br />Morrond, CA 94804 info*simsmmcam <br />www sYmmm.com <br />Subject: Notice to Comply, Sims Metal Management <br />Stockton, CA Facility <br />Inspection of August17, 2011 <br />Dear Ms. Rivera: <br />This correspondence constitutes the response of Sims Metal Management (SMM) to <br />the County of San Joaquin: Environmental Health Department (EHD) as the result of an <br />inspection dated August 17, 2011. <br />SMM takes environmental compliance seriously and appreciates the opportunity to <br />respond to the concems of the County of San Joaquin; Environmental Health <br />Department. We make every effort to ensure the safety of our employees, community, <br />and environment. For your convenience, pertinent portions of the Notice to Comply <br />(NOC) are reproduced below, along with our responses. The concerns raised in the <br />NOC are bolded and italicized below. <br />1. Operations: (7) CCR 66262.11 Failed fo determine if a waste is a hazardous waste <br />Following this observation, a small amount of metal fines were generated as a result of the <br />grinder and were swept from the ground and accumulated into a jar. Given the volume of the <br />fines collected, there was not sufficient material for a waste determination. Since the <br />observation, a vacuum device has been installed to the grinder to remedy any airborne <br />debris from its operations. Once enough volume is accumulated, a sample will be submitted <br />to a certified laboratory. Grinding operations are minimal, and thus may take additional time <br />to collect a sufficient sample. <br />2. Preparedness: (11) CCR 66265.31 Facility not maintained to minimize the release of a <br />hazardous waste <br />Immediately following the inspection, the car crusher was cleaned of debris; Adsorbent <br />material was spread in the car crusher's secondary containment, and concrete surface. Any <br />oils absorbed in the area were swept clean. The facility will monitor the car crusher for any <br />further evidence of leaks. If a leak is observed, a work order will be issued to remedy this <br />problem immediately. Please see Exhibits 1, 2, 3 Car Crusher (photos). <br />3. Storage: (18) HSC 25201(a) Stored hazardous waste on site longer than 90 days <br />without permit or authorization <br />At the time of inspection, the two 5 gallon buckets containing solid debris and soil were <br />immediately placed into the proper Hazardous Waste drum. Appropriate labelling and <br />suns Metal Management <br />