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September 23t', 2011 Stacy Rivera �'�� i I V- �_ San Joaquin County Environmental Health Department SEPI S 2011 600 East Main Street Stockton, CA 95202 SAN JOAQUiN COUNTY ENVIRONMENTAL HE4LTH DEPARTMENT RE: August 18th,2011 inspection at Stockton Pick N Pull,3927 Clark Drive, Stockton, CA. Ms. Rivera, This letter serves as our response to your inspection findings from August 18th, 2011 at our facility located at 3927 Clark Drive, Stockton, CA. Concern#7: "Containers of household wastes, such as washer fluid, oil, antifreeze, pesticides, and window cleaner were observed in a container outside the shop, at the northeast corner, without labeling." Make a determination of waste status and manage them appropriately. The cubic yard box with waste paint was relabeled and shipped offsite. All oil containers, transmission fluid,power steering fluid, and other lube or hydraulic oil were transferred to the site's used oil tanks for recycling. All of the antifreeze containers were transferred to the site's used antifreeze tank for recycling. All of the containers of brake fluid were transferred to the site's used brake fluid drum for recycling. In the interest of waste minimization, some containers of cleaning products were retained by the site for use in our site operations. Any container of product that cannot be disposed of in our normal waste streams or reused will be properly disposed of as required by law. See attached manifests and Figure 1 for properly labeled paint. Concern#11: Oil stains observed in various locations throughout the yard. "Facilities shall be maintained in manner to minimize the possibility of a fire, explosion, or release of hazardous waste to air, soil, or surface water that 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 leaking equipment has been scheduled for repairs by September 30th, 2011. See Figures 2, 3, &4. 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 151, 2011 letter to San Joaquin County regarding this issue: We strive to clean up any and all drips,leaks,spills as soon as practical;however,due to the nature of our business and the sites large size(30 acres),some small incidental releases will be missed.As I mentioned previously,PNP has numerous BMP's to"minimize the possibility of a fire, 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.Below is list of the more pertinent BMP's that Pick N Pull employs to mitigate the incidental release of automotive fluid throughout our operations: 1) As soon as feasible and accessible,oil spots/stains are removed from the yard and disposed of as oil debris.In 2010,Stockton Pick N Pull shipped off over 148 cubic yards of oily debris at a cost of over$40,000. 10850 Gold Center Drive, Suite 325, Rancho Cordova, CA 95670 w .picknpull.com