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0 <br /> February 1$t,2011 <br /> Mr.Ray von Flue <br /> San <br /> San Joaquin County EHD RECEIVED <br /> Unit III—CUPA <br /> 600 E.Main Street, FEB 0 7 2011 <br /> Stockton,CA 95202 <br /> RE: Pick N Pull Auto Dismantlers,3927 Clark Drive, 1-28-2011 Notice to Abate Order. ENVIRONMENTAL HEALTH <br /> PERMIT/SERVICES <br /> Mr. Von Flue, <br /> This letter is regarding your investigation of an anonymous complaint alleging our facility was"...chopping up cars at the back of the <br /> facility allowing transmission fluid and other vehicle fluids to into Deer Creek"We take all such complaints very seriously and have <br /> numerous best management practices in place through our storm water pollution prevention plan and operational procedures.Martha <br /> Miller and her staff have cleaned the observed oil staining from January 28`h. (See attached photo) <br /> 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 <br /> size(30 acres),some small incidental releases will be missed.As I mentioned previously,PNP has numerous BMP's to"minimize the <br /> possibility of afire, explosion,or any unplanned release of hazardous waste to air,soil, or surface water that could threaten <br /> human health or the environment."(22 CCR 66265.31). It is our position that our BMPs meet the intent of the referenced code(i.e. <br /> minimize the possibility of....any unplanned release of hazardous waste to air,soil,or surface water that could threaten human health <br /> 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 <br /> Management Practices to mitigate these releases.Below is list of the more pertinent BMP's that Pick N Pull employs to mitigate the <br /> incidental release of automotive fluid throughout our operations: <br /> 1) As soon as feasible and accessible,oil spots/stains are removed from the yard and disposed of as oil debris. In 2010,Stockton <br /> Pick N Pull shipped off over 148 cubic yards of oily debris at a cost of over$40,000. <br /> 2) Pick N Pull Stockton places vehicle carpet floor mats under engine compartment as available to catch drips and minimize <br /> release to soil.These floor mats are made of polypropylene, the same material as oil only absorbent pads.We believe this <br /> minimizes the amount of auto fluids that contact the soil. <br /> 3) Pick N Pull Stockton drains all vehicles of all automotive fluids to the maximum extent practical.However due to the <br /> circuitous channels,passageways,etc in engine and drive train parts,it is not possible to remove all fluids. In 2010 this <br /> facility shipped over 36,000 gallons of waste oil for recycling. Over 9500 gallons of waste antifreeze were also shipped off <br /> for reclamation. Last, 10 drums or 550 gallons of waste brake fluid was shipped in 2010 for proper disposal. <br /> If you have any questions please do not hesitate to contact me. <br /> Sincerely, <br /> CLL 0)A4^,,-_ <br /> Chris Orsolini <br /> Environmental Administrator <br /> Pick N Pull Auto Dismantlers-A Schnitzer Company <br /> 916-496-6768 cell <br /> 916-858-3116 desk <br /> 916-689-2003 fax <br /> corsolini@schn.com <br /> 10850 Gold Center Drive,Suite 325, Rancho Cordova, CA 95670 <br /> www.picknpull.com/wwrw.schnitzersteel.com <br /> PICK-N-PULL U5: -AZ: Chandler *AR: Cabot-Little Rock -CA; Antelope-CNco-Fairfleld-Fresno-Merced-Modesto-Moss Landing-Newark-Oakland-Rancho Cordova-Redding- <br /> Ric'hrnond-Rocklin-Sacramento-San lose North-San lose South-Stockton-Windsor -FL: Panama City-Tallahassee .IL: Summit-Wadsworth IN: Hammond *KO: St.Louis-Kansas City <br /> .NV: Carson City-Sparks *OH: Columbus *OR: <br /> North Portland-Portland-Sherwood-*TX: Dallas-Fort Worth-San Antonio -UT: Salt Lake City *VA: Virginia Beach .WA:. Vancouver <br /> CANADA: *AB: Calgary-Edmonton •BC: Kelowna <br />