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WASTE MANAGEMENT <br /> Stockton Scavengers <br /> WIM 1240 <br /> wwSre aanm"etaeStoc <br /> nr Navy Drive <br /> Stockton,CA <br /> January 16,2013 <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(SJEHD)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. Stockton Scavengers has <br /> subsequently investigated this alleged violation and has prepared the following response. <br /> Violation code 108—Failed to determine if a waste is a hazardous waste <br /> It was noted on the inspection form that metal fines being generated from metal grinding was <br /> being disposed of without prior hazardous waste classification being made. Currently Stockton <br /> Scavengers,utilizing generator knowledge under CCR 66262.11,has determined this not to be a <br /> RCRA waste. However, Stockton Scavengers has contacted the metal recycling contractor and <br /> has confirmed they will recycle the sites metal shavings in question for recycling in accordance <br /> with scrap metal rules. Stockton Scavengers has set up a collection system onsite for this <br /> material. <br /> Violation code: 116& 117—Failed to Train Personnel Annually&Personnel Training <br /> Records Incomplete <br /> It was noted on the inspection form that training records on-site were incomplete and not all <br /> employees had been trained to reflect training listed on the Job Descriptions.It was also noted <br /> that Specific Titles of employees and Titles for the Trainings were not an exact match.While <br /> Stockton Scavengers feel the various training provided in whole to the employees meet all <br /> requirements, the facility has created a two specific training that meet this requirement. Stockton <br /> Scavengers has also updated the current Employee list and Job descriptions to reflect exact titles <br /> and training requirements for each Job Title.A Copy of the updated job descriptions with <br /> Stockton Scavengers current employee list is located in Attachment 1. <br />