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rwi CEnTRRL SPRIr'1G, inn, <br /> 1616 Boeing Way Stockton,CA 95206 TEL:(209)983-1234 FAX:(209)983-1235 <br /> December 18,2009 <br /> Ray Von Flue, REHS <br /> Senior Registered Environmental Health Specialist <br /> San Joaquin County Environmental Health Department <br /> 600 E. Main Street <br /> Stockton,CA 95202-3029 <br /> Re: Corrective Action Statement <br /> Dear Mr. Von Flue, <br /> This Corrective Action Statement is submitted in response to your Hazardous Waste <br /> Generator Program Inspection Report dated November 30,2009. The notice of violations <br /> summary portion of your report contained three alleged violations related to operations, <br /> storage and labeling of wastes that relate to the California Health and Safety Code(HSC) <br /> and the California Code of Regulations(CCR). The following corrective actions respond <br /> to each violation by item number on your inspection report and code section of California <br /> law. <br /> Item #4 Section 15/89.5 HSC <br /> During a site inspection on May 29, 2009, you collected samples of"hot shot"and"cold <br /> shot'bead blast waste. You report that your analysis of the bead blast indicates that both <br /> the hot shot and cold shot are hazardous wastes based on total chromium concentrations. <br /> While CSI may not agree with the classification of the bead blast as a non-RCRA <br /> hazardous waste,this material will be handled,stored and disposed of as such as an <br /> interim corrective measure until this matter is resolved. <br /> Item #20 Section 66162.34 CCR <br /> You noted that during your inspection on November 30,2009, 55-gallon drums of hot <br /> shot and cold shot bead blast were labeled as non-hazardous. While CSI may not agree <br /> with the classification of the bead blast as hazardous, this material will he treated as a <br /> non-RCRA hazardous as an interim corrective measure until this matter is resolved. <br /> Please see attached photographs that clearly show hazardous waste labels on all drums <br /> containing bead blast. <br /> Item #1/ Section 66265.I73(a) CCR <br /> You noted that during your inspection on November 30,2009, 55-gallon drums of bead <br /> blast were not covered. You cited that these drums must be covered except when adding <br /> or removing waste. These drums have been covered and will remain covered except <br />