Laserfiche WebLink
January 11, 2000 <br />Mr. Michael P. Kith, R.E.H.S <br />Environmental Health Division <br />304 East Weber Avenue, Third Floor <br />P.O. Box 388 <br />Stockton, CA 95201-0388 <br />Re: Response to San Joaquin County -Environmental Health Division (SJC-EHD) Notice of <br />Violations, dated November 18, 1999 <br />Dear Mr. Michael P. Kith, R.E.H.S: <br />I have had the opportunity to review SJC-EHD's latest Notice of Violation (NOV) report <br />initially issued to QB Rebuilders (QBR) on October 7, 1999, then revised and re -issued <br />November 18, 1999. As requested, The Certificate of Return to Compliance relative to your <br />audit findings of QB Rebuilders, Inc., is enclosed. <br />All items in your findings have been corrected to compliance with the following comments <br />and/or exceptions: <br />NOV #4: Section 25189.5 (HSC)- Disposal of hazardous waste at an unauthorized <br />site: <br />It is unclear where this material originated. It may have been received in a <br />drum of core parts, or it may have been generated onsite. In any event, it was <br />an isolated incident, and at worst case was an unintentional release of an <br />unknown substance. It is evident that, based on the condition of the <br />discovered spilled material, the spill had occurred within 48 hours of discovery <br />since the spilled material had not been dispersed as a result of wind, weather <br />or traffic. <br />In the future, to insure that no drums stored in the Bone Yard contain any <br />residues, the following procedure will be implemented immediately: <br />I. Inspect all emptied drums. Remove all loose debris. <br />ll. Wash the drum at the Wash Area. <br />III. Re -inspect the washed drum to insure that all residues that can <br />be poured, chipped or wiped from the container have been <br />removed. <br />IV. Store the cleaned empty drum upside down on a pallet. <br />V. Stage the pallet in the Bone Yard. <br />QBR requests that this NOV be rescinded for the following reason: <br />HSC 25189.5 required that the "disposal" of a hazardous waste be done with <br />knowledge, or that the generator should have reasonably known that the <br />hazardous waste was being disposed. QBR neither had the knowledge that <br />the drum residues had been deposited on the ground, nor should have QBR <br />