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7Joaquiyn <br /> STOCICTON SCAVENGERS ASSOCIATION <br /> 1240 Navy Drive <br /> JUN 2 2 'LOt (209)Stock9 6-5721 2o6 <br /> (209)946-5721ue Trir a ';JT :j[? U F( (209)948-4013 Fax <br /> ounty ENVIRO c _ <br /> Environmental Health Department <br /> PERMITISERVICES <br /> 600 East Main Street <br /> Stockton, CA 95202-3029 <br /> RE: Return to Compliance <br /> Dear Mr. Flue, <br /> This letter is intended to serve as both Waste Management's response to the <br /> Department's recent inspection as well as our request for the rescission of all the noted <br /> deficiencies documented during the May 18th routine inspection. <br /> On May 18`s, 2009 the San Joaquin County Environmental Health Department conducted <br /> a routine inspection of Stockton Scavenger's Facility located at 1240 Navy Drive, <br /> Stockton CA. Stockton Scavengers is a subsidiary of Waste Management. During the <br /> inspection SJCEHD documented five suspected minor violations. Waste Management <br /> has subsequently investigated each minor violation and has prepared the following <br /> response for each. <br /> Violation#10—66262.11 CCR—Failure to determine if a waste is a hazardous <br /> waste. <br /> Waste Management believes this finding to be in error. As discussed, we are utilizing <br /> generator knowledge authorized under CCR 66262.11 to properly characterize our wash <br /> water/residue generated during the truck washing operation. The truck wash is for the <br /> exterior washing of the vehicles only and no engine cleaning/degreasing takes place <br /> during the wash process. During the inspection Waste Management provided SJCEHD <br /> information regarding this waste that included test results that characterized this waste <br /> stream as non-hazardous. However,these results were not Waste Management's <br /> characterization" data but that of our disposal contractor (Evergreen Environmental <br /> Services, Inc.). This data is intended for their use as support of their acceptance decision. <br /> In making our non-hazardous characterization determination for this waste stream we <br /> reviewed analytical data from several other Waste Management facilities with like <br /> processes. Additionally Waste Management reviewed data and determinations from Non- <br /> WM truck washwater waste streams that have been submitted as a part of Waste <br /> Management waste acceptance requirements for our Altamont Landfill in Alameda <br /> County. It is our experience based on the aforementioned characterization data that <br /> wastewater and residue from exterior vehicle washing operations are not characteristic <br />