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MAZTU GB ENY <br /> 'mnasw slur Stmktoa Scavengers <br /> 1240 Navy Dtive <br /> Stockton,CA <br /> August 9,2013 <br /> Stacey Rivera <br /> San Joaquin County <br /> Environmental Health Department <br /> 1868 East Hazelton Avenue <br /> Stockton,CA 9525 <br /> RE:Response to Hazardous Waste Program Inspection conducted on December 19,2012 <br /> Dear Ms.Rivera, <br /> On December 19,2012 the San Joaquin Environmental Health Department(SJE,I, D)conducted a <br /> routine Hazardous Waste Program Inspection of Stockton Scavengers located at 1240 Navy <br /> Drive,Stockton, CA. Stockton Scavengers is a subsidiary of USA Waste of California,Inc. <br /> During the inspection SCEMD documented eight alleged violations an a response was sent on <br /> January 16,2013. In April 2013 Sharon Simpson,Environmental ProtectionSpecialist,spoke to <br /> you regarding the Training Records and metal fines submitted on January 16,2012.St t s k <br /> Scavengers would like to submit the response below and has attached the remaining training <br /> records that was requested <br /> Violation code 108—Failed to determine R a waste is a hazardous waste <br /> Ms.Rivera had concerns that our previous response would not be in line with Scrap Metal rules <br /> due to the size of the particles and that the material would still need to be handled as hazardous <br /> waste.Due to this concern Stockton Scavengers chose to submit a representative sample to Test <br /> America for a testing.These tests confirmed that 80% of the metal fines are well above 100 <br /> microns and would be able to be handled under the scrap metal regulations.Stockton Scavengers <br /> has attached these test reviews for San Joaquin's review in Attachment 1. As state earlier, <br /> Stockton Scavengers has contacted the metal recycling contractor and has confirmed they will <br /> recycle the sites metal shavings in question for recycling in accordance with scrap metal Hiles. <br /> Stockton Scavengers has set up a collection system onsite for this material. <br /> Violation code: 116& 117—Failed to Train Personnel Annually &Personnel Training <br /> Records Incomplete <br /> Todd Nienhouse, who is the District Manager of Stockton Scavengers, conducted training for <br /> DOT Awareness Training&Hazardous Materials/Waste Training, Including Hazardous <br /> Materials Business Plan(HMBP)& Hazardous Waste Contingency Plan. During this training a <br />