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Contingency Plan: <br /> • 66265.52 (CCR) Contingency Plan incomplete. <br /> Response/Return to Compliance: <br /> • On page 3, the Emergency Coordinator and Hazardous Waste Response <br /> Team listing was updated with home phone numbers and now states that <br /> all members are accessible by cell phones and are on call 24 hours a day. <br /> • SJRTD would like to note that from an emergency response standpoint, <br /> mobile phones are more dependable than home phones. If an <br /> "Emergency Coordinator" (EC) is out of his or her home and not at work, <br /> the SJRTD emergency response program as it is currently configured <br /> would be able to reach the EC at all times. Solely placing the home phone <br /> number as title 22 CCR indicates would for us result in an inefficient <br /> emergency notification system. <br /> Personnel Training: <br /> • 66265.16 (CCR) Personnel training records incomplete <br /> Response/Return to Compliance: <br /> • Job descriptions for all appropriate classifications are being updated and <br /> placed in the training file. <br /> As indicated above, it is important to point out that SJRTD's sampling and <br /> independent laboratory analysis by our ELAP certified lab indicates the waste in <br /> question is not a hazardous waste; therefore, SJRTD respectfully requests that <br /> the SJCEHD retract the notice of violation andremove atleged- Cfas <br /> vio a ion rom e ice to Comp y instead. e <br /> �derstand that SJCEHD is conducting its own analysis (CAM 17 metals, full <br /> TCLP analysis and fish bioassay) through an independent laboratory and the <br /> Department of Toxic Substances Control Act's laboratory. We request that you <br /> are thoseresumewith us as soon as they are available. <br /> SJRTD appreciates SJCEHD pointing out the minor documentation lapses <br /> listed above. As indicated above, we have taken additional systematic, <br /> management and educational measures to prevent their reoccurrence. SJRTD <br /> also reaffirms its corporate commitment to its environmental health and safety <br /> policy; we are continuing our environmental health and safety program <br /> developments and management initiatives to continue to be a leading facility in <br /> San Joaquin County and the State of California. <br /> If you have any questions about this letter or the attached laboratory results, <br /> please contact us. We look forward to your response regarding our requests <br /> mentioned above. <br /> 1533 East Lindsay Street• Stockton CA 95205-4498 • (209)948-5566 • (209) 948-8516 fax <br /> www.sj-smait.com <br />