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John Alaniz <br /> December 5, 2018 <br /> Page 6 of 7 <br /> in hazardous waste training provided to Newark Recycled Fibers personnel by Yorke on <br /> December 4, 2018. While on site, Yorke verified that all hazardous waste labels in use were <br /> properly filled out. See Example labels in Attachment 3, photos 3 and 4. <br /> Item #608 <br /> CCR 66266.130 Failed to properly manage used oil and fuel filters. <br /> The General Manager stated that several different companies come to service the forklifts and the <br /> front-end loader(such as Pape Machinery, Watts and Linde), and take waste generated back with <br /> them. Invoice 116616 (4/5/2017) showed that used oil and used oil filter waste was generated. <br /> Disposal records for the used oil frlters for the last three years were not found on site. Per Title <br /> 22 California Code of Regulations (CCR) 66266.130, oil filters that are not completely drained <br /> need to be managed as hazardous waste. If the oil filters are completely drained, they can be <br /> disposed of via recycling. A bill of lading needs to be left with the facility for drained oil filters. <br /> Per 22 CCR 66266.130 (c)(5), bills of lading must indicate generator, transporter, and receiving <br /> company names, addresses, telephone numbers, the quantity and size of used oil filter containers <br /> transferred, and the date of transfer. If the oilfilters are being taken as recycling, immediately <br /> start to keep and store the bills of lading when the filter waste is generated. <br /> In most cases the used oil filters and used oil from vehicles would be generated when <br /> maintenance of rolling equipment is performed off site. If used oil and/or used oil filters <br /> are generated on site they will be managed as a California Hazardous Waste and proper <br /> consolidated and uniform hazardous waste manifesting procedures will be used. The <br /> proper management for used oil and used oil filters and fuel filters was discussed in <br /> hazardous waste training provided to Newark Recycled Fibers personnel by Yorke on <br /> December 4, 2018. <br /> CONCLUSION <br /> Newark Recycled Fibers has taken your inspection report seriously. The above discussion along <br /> with the attachments provide a response to your November 6 inspection report for Newark <br /> Recycled Fibers facility at 800 W.Church Street,Stockton,CA,CERS ID 10180985. The training <br /> provided to staff and use of manifest tracking log and the environmental task management system <br /> should help prevent recurrence of the above items. If I can answer any further questions, please <br /> contact me at(415) 897-6203 xl. <br /> Sincerely, <br /> Michael Dudasko CPEA, QISP <br /> Principal Engineer <br /> Yorke Engineering, LLC <br /> mdudasko@Yorkeengr.com <br /> cc: Aurelia Anderson,Newark Recycled Fibers <br /> Michael Fourcand <br /> Bill Doerr <br /> Torke Engineering,LLC <br />