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0 <br />Sprint <br />December 15, 2010 <br />San Joaquin County Environmental Health Department <br />Attn: Garrett Backus <br />600 East Main Street, Stockton, CA 95202 <br />0 <br />Sprint -Environmental, Health & Safety <br />Pete Wang, EHS Specialist <br />1850 Gateway Drive <br />San Mateo, CA 94404 <br />(650) 375.2019 - Office <br />(913) 523-2040 - Fax <br />RE: Hazardous Material Inspection- Sprint Facility, 3807 Coronado Ave., Stockton <br />Mr. Backus, <br />This letter is regard of the inspection violation #8 (Managed a hazardous waste without an EPAnumber) <br />identified in the inspection report of Sprint facility located at 3807 Coronado Ave., Stockton, issued on <br />November 18, 2010. We believe this facility does not require a permanent EPA number for the following <br />reasons: <br />1. The hazardous materials currently used and stored at this facility include lead -acid cell batteries, <br />diesel fuel stored in fuel storage tanks and emergency generators, and hazardous waste infrequently <br />generated at this facility includes used wet cell batteries, used fuel oil, contaminated spill supplies, <br />and universal waste. This Sprint facility does not generate any RCRA acute hazardous waste, nor <br />does Sprint handle, transport, dispose and recycle any hazardous waste on-site. <br />Cummins West, Inc. is Sprint's vendor responsible for maintaining generators and removing the used <br />oil from the generators, transports it to a facility in San Leandro, where it is placed in a container to be <br />recycled. Sprint believes it should not be required to apply for an EPA ID number because Cummins <br />West, Inc. already has an EPA ID number, therefore would be considered the waste generator. This <br />belief was confirmed by Mary Misemer, California Department of Toxic Substances Control <br />Regulatory Assistance Officer, during a recent phone conversation. Mary also referred to HSC <br />25250.12 which states "Used oil generated during maintenance operations may be transferred from <br />its point of generation to the maintenance person's place of business, other than a residence, for the <br />purpose of consolidation in a tank or container, without meeting the requirements of Sections 25160, <br />25163, and 25201, if the material is to be recycled at an authorized offsite hazardous waste facility." <br />Similarly, when lead -acid batteries are no longer of service and need to be replaced, Sprint <br />employees coordinate with battery vendors or hazardous waste disposal contractors to replace used <br />batteries and transport them to their designated recycling or waste disposal facility. Battery and <br />generator vendors are required to clean up spills and dispose of spill supplies if a spill occurs when <br />changing up batteries, maintaining generators, or refueling storage tanks. Contaminated spill supplies <br />generated by Sprint's employees are disposed through Sprint's approved disposal/recycling <br />contractors. <br />2. This Sprint facility does generate universal waste that includes dry cell batteries, lamps, and spent <br />electronic devices. The accumulative quantity of these universal waste is always less than 100 <br />kilograms (220 pounds) at any time, and all these universal wastes are disposed and recycled <br />through approved contractors. <br />If you have any additional questions regarding this matter, please feel free to contact me at (650) 375- <br />2019. <br />Thank you, <br />L/ <br />Pete Wang <br />Sprint EHS Specialist <br />