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`17 WASTEQUIP RE <br /> MAR 2 1 2016 <br /> March 14, 2016 ENVIRON <br /> San Joaquin County Environmental Health Department pEMSEROCSLTH <br /> ATTN: Aris Veloso, REHS, MBA <br /> 1868 East Hazelton Avenue <br /> Stockton, CA 95205-6232 <br /> RE: LQG Inspection Report Response <br /> Dear Mr. Veloso: <br /> Please accept this letter as response to the Large Quantity Hazardous Waste Generator <br /> Inspection Report finding dated February 16, 2016 for our Wastequip Manufacturing <br /> Company, LLC (Wastequip) facility located at 11900 East Locke Road, Lockeford, CA <br /> 95237. The report identified two violations. The violations along with the course of <br /> actions are listed below: <br /> Item 105 (CCR 66262.11 and 66262.40(c)) <br /> Failed to determine if a waste is a hazardous waste or retain waste analysis on site for 3 <br /> years. <br /> Response: <br /> The facility attempted to collect a cured HE107 — Asphalt Emulsion and Dampproofer <br /> "Henry's" sample for analysis in order to accurately determine its potential toxicity. All <br /> material observed on site was collected and containerized for analysis on February 17, <br /> 2016. However, during transport the sample collected along with other materials <br /> collected for laboratory analysis were damaged. Due to damage the initial sample could <br /> not be used for analysis. Analysis of this material is underway. A delay gathering <br /> additional material was encountered due to its limited generation. The facility did not <br /> have sufficient quantities of the waste to complete all the necessary laboratory analysis. <br /> As of the date of this letter the facility has collected sufficient quantities of the material <br /> and submitted the material for laboratory analysis (chain-of-custody attached). <br /> Wastequip will provide the analytical results to San Joaquin County Environmental <br /> Health Department upon receipt. Further, upon receipt of the results, Wastequip will <br /> immediately classify and manage the waste appropriately. <br /> Item 301 (CCR 66265.31) <br /> Facility not maintained to minimize the release of a hazardous waste. <br /> Response: <br /> The Scotchman F.I. was inspected and no functional leaks were identified. The staining <br /> was cleaned; however, the cause of the staining is unknown. Due to the unknown cause, <br /> after cleaning, a drip pan with sorbents was installed at the observed stain location. If <br /> future releases occur, the source will be identified and the impacted sorbents managed <br /> according to applicable regulatory waste oil / sorbent management practices. <br /> Corporate Headquarters 6525 Morrison Boulevard,Suite 300 1 Charlotte,NC 28211 1 877.4689278 1 sales@wastequipcom 1 www.wastequip.com <br /> • <br /> _ — r <br />