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May 2008 <br /> RESPONSE TO ALLEGED VIOLATIONS FROM ENVIROMENTAL HEALTH <br /> DEPARTMENT AND SAN JOAOUING COUNTYDISTRICT ATTORNEY <br /> HSC 25189.5(a) Disposed of or caused disposal of hazardous waste at an <br /> unauthorized point. <br /> This drain is actually a "clean out"for the water/oil <br /> separator. The individual questioned at the time of the April <br /> 6` inspection did not have first hand knowledge of this so he <br /> gave inaccurate information. <br /> Title 22, CCR, section 66262.11 (CCR)Failed to determine if a waste is a hazardous <br /> waste. <br /> While at the time of this inspection there was no first hand <br /> knowledge if this substance had the characteristic to be <br /> classified as a hazardous waste the Inspectors did ultimately <br /> take samples and send them for testing. When the results <br /> were returned they showed that the substance didn't have the <br /> characteristics necessary to be treated as a hazardous waste. <br /> We have however decided to treat the sanding waste from the <br /> body shop as hazardous. It is no longer mopped but swept up <br /> and contained as if hazardous and handled in the same <br /> manner as all other hazardous materials. <br /> Title 22, CCR 66265.31 Facility not maintained to minimize the release of hazardous waste <br /> This infraction is twofold Our service business for the year <br /> of 2006 had grown beyond prior years which contributed to <br /> one of our issues. The oiUwater separator filled to capacity <br /> before our scheduled clean out. To resolve this problem we <br /> modified our clean out schedule to quarterly regardless of <br /> business growth or not. As for the second issue with the <br /> spent absorbent and the transmission left unattended and <br /> leaking. This was resolved with employee training, couching <br /> and awareness. In addition we have placed "pigs" in the <br /> drains around our service, body shop and detail areas in case <br /> of any accidental spills. <br /> HSC 25201 (a) Stored hazardous waste on site longer than 90 days without a permit <br /> or authorization. <br /> We now inspect our containers daily for proper labeling. In <br />