COMPLIANCE INFO_PRE 2019 - Laserfiche WebLink

Home Browse Search

0 Sprint December 17, 2010 San Joaquin County Environmental Health Department Attn: Garrett Backus 600 East Main Street, Stockton, CA 95202 Sprint- Environmental, Health & Safety Pete Wang, EHS Specialist 1850 Gateway Drive San Mateo, CA 94404 (650) 375-2019 — Office (913) 523-2040 — Fax RE: Hazardous Material Inspection- Sprint Facility, 3807 Coronado Ave., Stockton Mr. Backus, This letter is regard of the inspection violation #8 (Managed a hazardous waste without an EPS number) identified in the inspection report of Sprint facility located at 3807 Coronado Ave., Stockton, issued on November 18, 2010. We believe this facility does not require a permanent EPA number for the following reasons: The hazardous materials currently used and stored at this facility include lead -acid cell batteries, diesel fuel stored in fuel storage tanks and emergency generators, and hazardous waste infrequently generated at this facility includes used wet cell batteries, used fuel oil, contaminated spill supplies, and universal waste. This Sprint facility does not generate any RCRA acute hazardous waste, nor does Sprint handle, transport, dispose and recycle any hazardous waste on-site. Sprint ensures all hazardous waste will be handled in the appropriate manner by approved vendors and meeting all requirements in accordance with Title 23. Cummins West, Inc. is Sprint's vendor responsible for maintaining generators and removing the used oil from the generators, transports it to a facility in San Leandro, where it is placed in a container to be recycled. Sprint believes it should not be required to apply for an EPA ID number because Cummins West, Inc. already has an EPA ID number, therefore would be considered the waste generator. This belief was confirmed by Mary Misemer, California Department of Toxic Substances Control Regulatory Assistance Officer, during a recent phone conversation. Mary also referred to HSC 25250.12 which states "Used oil generated during maintenance operations may be transferred from its point of generation to the maintenance person's place of business, other than a residence, for the purpose of consolidation in a tank or container, without meeting the requirements of Sections 25160, 25163, and 25201, if the material is to be recycled at an authorized offsite hazardous waste facility." Similarly, when lead -acid batteries are no longer of service and need to be replaced, Sprint employees coordinate with battery vendors to replace used batteries. HazMat Response- HazMat One, Inc. is Sprint's hazardous waste vendor responsible for managing and handling the mitigation and remediation of a significant release, spill, leak, etc. When a spill occurs, contaminated spill supplies will be placed in 55- gallon containers. HazMat One uses licensed local hazardous waste vendors to clean up releases and haul waste to disposal facilities in the area. A temporary EPA number will be generated by HazMat One when filling the hazardous waste manifest. All hazardous waste manifests are maintained at Sprint's corporate office. 2. This Sprint facility does generate universal waste that includes dry cell batteries, lamps, and spent electronic devices. The accumulative quantity of these universal waste is always less than 100 kilograms (220 pounds) at any time, and all these universal wastes are disposed and recycled through approved contractors. If you have any additional questions regarding this matter, please feel free to contact me at (650) 375- 2019.