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DongellLawren`re <br /> RrMeyLLr SOUTHERN CALIFORNIA NORTHERN CALIFORNIA NEVADA <br /> FORTY FIFTH FLOOR SUITE 950 SUITE 800 <br /> L A W Y E R 5 707 WILSHIRE BOULEVARD 770 L STREET 2300 W. SAHARA AVENUE <br /> WWW.DLFLAWYERS.COM LOS ANGELES, CA 90017 SACRAMENTO, CA 95814 LAS VEGAS, NV 89102 <br /> TELEPHONE 213.943.6100 TELEPHONE 916.449.3999 TELEPHONE 702.856.4558 <br /> FACSIMILE 213.943.6101 FACSIMILE 916.4(4-99..3998 ��FA/7CSIMILE 702.856.4301 <br /> u ECEUEV <br /> January 26, 2010 :,,i L 8 2010 <br /> Ray Von Flue, RENS ENVIRUNMENT HEALTH <br /> Senior Registered Environmental Health Specialist PERMIT/SERVICER <br /> San Joaquin County Environmental Health Department <br /> 600 E. Main Street <br /> Stockton, CA 95202-3029 <br /> RE: RESPONSE TO NOTICE OF VIOLATION DATED NOVEMBER 30,2009 <br /> CENTRAL SPRING,INC., 1616 BOEING WAY, STOCKTON, CA 95206 <br /> Dear Mr. Von Flue: <br /> On May 29, 2009, the San Joaquin County Environmental Health Department ("the <br /> County") conducted a site inspection of the Central Spring manufacturing facility located at 1616 <br /> Boeing Way in Stockton, CA. During the inspection the County collected three samples of <br /> waste material; one sample of"hot shot' bead blast waste material, one sample of"cold shot' <br /> bead blast waste material, and one sample of waste water. The samples were submitted to <br /> GeoAnalytical Laboratories Inc. for analysis of CAM 17 metals for comparison with TTLC <br /> waste thresholds. Additionally, the County noted that the bead blast waste would be subject to <br /> WET test and TCLP test extraction if TTLC concentrations warranted further analysis. The <br /> Laboratory results from the May 29, 2009 sampling event are compared to hazardous waste <br /> criteria in Table 1. A copy of the laboratory analytical report is attached as Exhibit A. <br /> 1. BEAD BLAST WASTE CLASSIFICATION <br /> In its November 30, 2009 Notice of Violation to Central Spring, the County reported <br /> three alleged violations related to the storage and disposal of bead blast waste. Specifically, they <br /> reported one alleged Class I violation related to the disposal of bead blast waste as a non- <br /> hazardous waste, one alleged Class 11 violation related to improper labeling of this same waste as <br /> a non-hazardous waste and one alleged Class TI violation related to the failure to keep containers <br /> of the waste closed except when adding or removing this same alleged hazardous waste. The <br /> County contends that the bead blast waste is classified as a hazardous waste under California <br /> Title 22 CCR66261.24(a)(2) based on "high levels" of chromium in "hot shot' and "cold shot' <br /> bead blast waste. <br /> Based on our thorough review of California Title 22 CCR66261.24(a)(2), the <br /> classification of the bead blast as a non-RCRA hazardous waste by the County is incorrect. <br />