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0 0 <br /> CAL SHEETS«IC RECEIVED <br /> 1212 Performance Drive, Stockton, CA 95206 <br /> Phone (209)2343300 Fax (209)2343310 NOV 2 12015 <br /> November 20,2015 ENVIRONMENTAL <br /> San Joaquin County HFAITN nr134RTkAPNT <br /> Environmental Health Department <br /> 1868 East Hazelton Avenue <br /> Stockton,CA 92505-6232 <br /> Attn: Elena Manzo(emanzo(b)sicehd.com) <br /> Re: Hazardous Waste Generator Inspection Report,October 20,2015 <br /> Ms. Manzo, <br /> In response to the Notice to Comply arising from the inspection reference above, we have made the following <br /> corrections and also would like to submit supplemental documentation: <br /> Item#102—Corrected on site <br /> A copy of the sample test results was provided at the time of inspection. Please note that in the 2010 Summary of <br /> Violations(Attachment 1)the Notice to Comply states that: <br /> "Any person who generates a waste shall determine if the waste is a hazardous waste. Immediately, make a <br /> hazardous waste determination for the waste water and solid filtrate,and manage it according to the hazardous <br /> waste regulations. Submit a statement and supporting documentation explaining how this waste was managed <br /> within 30 days of receiving this report." <br /> Cal Sheets followed all those directions in good faith and reported all our actions in our response(Attachment 2), dated <br /> November 9, 2010, and signed by an officer of the company(Pete Brodie).We made"a hazardous waste determination <br /> for the waste water and solid filtrate," as required. At the time, no one at Cal Sheets realized that the Environmental <br /> Health Department expected to receive a copy of the lab report, especially since the report confirmed our original <br /> statements regarding the toxicity of the waste water used on site. <br /> Additionally, Pete Brodie added to the 2010 response: "With the corrections noted above we believe Cal Sheets is in <br /> compliance with all hazardous waste regulations. As a company it is important to us to be in compliance with all rules <br /> and regulations and we appreciate your help in deciphering the sometimes complex array of requirements." <br /> So Item 102 was corrected on site, but we respectfully disagree that it should have been a 2015 violation in the first <br /> place. We followed all the steps defined in the 2010 Notice to Comply and reported our activities and change in <br /> processes back to the EHD in a timely manner, adding that we believed Cal Sheets to be in compliance with all <br /> requirements arising from the 2010 Inspection Report. The lab results were available on November 24, 2010, and Cal <br /> Sheets would have provided them to the EHD immediately had they been requested(as we did during the inspection on <br /> 10/20/15). <br /> Item#103—Corrected on site <br /> A modified contingency plan was provided during the inspection and filled out right away. The required information is <br /> posted by the phones. However we already had submitted a Consolidated Emergency Response/Contingency Plan to <br /> the California Environmental Reporting System(Attachment 3), and keep copies of it near the control room phone in the <br /> plant and in the offices. Since we used the actual template provided by CERS, we are very surprised that the <br /> Emergency Response/Contingency Plan we submitted last year is unacceptable to EHD. <br /> 1 <br />