COMPLIANCE INFO_PRE 2019 - Laserfiche WebLink

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(Continued from previous page) (11 /9/11), 009561607JJK (1/17/12), 009564048JJK (3/7112), 009740395JJK (3/16/12), 008816896JJK (3/20/12), 009574416JJK (5/1/12), 009574415JJK (5 /1/12), and 009565210JJK (7/3/12) were found without a signed off copy from the destination facility. All manifests have been located and properly matched with the designated facility's manifests. Copies of manifests not submitted to the DTSC have been mailed. Attached are copies of all matched manifests. Concerns #134: A tank assessment was not available on site for the used oil tanks and used antifreeze tanks. A hazardous waste generator shall obtain and keep on site a written assessment for each hazardous waste tank at the facility. Attached is copy of the most recent tank assessment, also available at the facility. Concerns #301: The shop is surrounded by eight drains which lead directly to the facility's unlined storm waste retention pond. Four of the drains were observed with covers; the other four were uncovered. Staining was observed around the drains. Liquid was observed around one of the drains. Facilities shall be maintained and operated to minimize the possibility of a fire, explosion, or release of hazardous waste to air, soil, or surface water which could threaten human health or the environment. The specific areas you mentioned in your report have been cleaned and the absorbent or gravel was managed through our oily debris waste stream. The drains going into the retention pond have been covered with oil absorbing mats, booms and rubber covers. The yard has been reminded of their obligation under Pick N Pull policy that oil drips are to be cleaned upon discovery. We would like to reiterate that we do not believe that incidental releases constitute a violation of this code as mentioned in our February lst, 2011 letter to San Joaquin County regarding this issue. As we've mentioned previously, PNP has numerous BMP's to "minimize the possibility of afire, explosion, or any unplanned release of hazardous waste to air, soil, or surface water that could threaten human health or the environment." (22 CCR 66265.31). It is our position that our BMPs meets the intent of the referenced code (i.e. minimize the possibility of. ... any unplanned release of hazardous waste to air, soil, or surface water that could threaten human health or the environment) and that it is not a violation of this statute to have incidental releases of automotive fluids as long as we have Best Management Practices to mitigate these releases. Attached are pictures of the drain area as well as pictures of the drains. 2