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0 <br />ECS <br />November 26, 2014 <br />Stacy Rivera <br />San Joaquin County Environmental <br />Health Department <br />1868 East Hazelton Avenue <br />Stockton, CA 95205-6232 <br />Re: Inspection, November 3, 2014 <br />Return to Compliance <br />Dear Ms. Rivera, <br />RECEIVED <br />DEC 01 2014 <br />ENVIRONMENTAL <br />HEALTH <br />PERMIT/SERVICES <br />The purpose of this letter is to respond to the items noted as violations in the inspection conducted by your <br />office at our facility on November 3, 2014. <br />Item # Explanation and Return to Compliance Status <br />113 ECS Refining has used an individual manifest for shipments of waste glycol since <br />September 2013 due to its status as a Large Quantity Generator. This violation has been <br />corrected. <br />115 During the inspection, it was identified that the generator copy of manifest number <br />004475217JJK had not been sent to the DTSC within 30 days of the shipping date. <br />A copy of this manifest has been sent to DTSC; a copy of the letter and the manifest <br />are included with this submittal. <br />116 Manifest copies 009479243JIK (5/8/2012) and 009479250JJK (5/22/2012) were not <br />117 found on-site. An electronic copy of these manifests was on-site, but there were no hard <br />copies retained in the manifest file. Investigation of our files revealed that these two <br />manifests were for shipments that were improperly made. The shipments were made <br />to Clean Harbors, LLC and were routed through our Santa Clara facility; the shipment <br />was made before Clean Harbors approved the profile, so the shipment had to be <br />completed on another manifest. A copy of the explanation letter that was submitted to <br />DTSC at the time is included with this letter for explanation. <br />303 The material that was in the spill containment pallet was immediately removed to <br />correct this violation. Production staff that are responsible for packaging hazardous waste <br />were re-trained to ensure they are aware that any material spilled into the containment <br />pallet is immediately cleaned up. <br />407 The empty drums were marked with the word "Empty" and the date. <br />605 All hazardous waste labels were immediately put on the deficient containers, and <br />accumulation start dates added. The waste oil was generated on the date that was on the <br />inventory tracking label (11/3/14). This waste oil was shipped out to Asbury <br />Environmental Services on November 25, 2014. A copy of the shipping document is <br />2222 S. Sinclair Avenue Phone (209) 774-5000 <br />Stockton, CA 95215 Fax(209)774-5001 <br />