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PUBLIC HLALTH SERVICES ,aPaC,o
<br />SAN JOAQUIN COUNTY
<br />ENVIRONMENTAL HEALTH DIVISION
<br />Karen Furst, M.D., M.P.H., Health Officer P
<br />q�
<br />304 East Weber Avenue, Third Floor • Stockton, CA 95202 4. iFo.R�.i
<br />209/468-3420
<br />TO: DAVID IREY, DEPUTY DISTRICT ATTORNEY
<br />SAN JOAQUIN COUNTY DISTRICT ATTORNEY'S OFFICE
<br />E VIRONMENTAL PROCSECUTIONS UNIT
<br />FROM: /, ONNA HERAN, RENS, DIRECTOR
<br />SAN JOAQUIN COUNTY
<br />ENVIRONMENTAL HEALTH DIVISION
<br />DATE: MARCH 21, 2000
<br />RE: REQUEST FOR LEGAL ACTION
<br />QB REBUILDERS, INC.
<br />2325 W. CHARTER WAY
<br />STOCKTON, CA 95206
<br />I. CASE SUMMARY
<br />QB Rebuilders, Inc. (QBR) is a vehicle brake and caliper remanufacturer. The old brakes (shoes and
<br />metals) are washed; the old brake shoes are then removed and discarded. The metal parts are then sand-
<br />blasted and recoated before the new shoes are placed on them. The old calipers are drained and washed
<br />before they are disassembled. The reusable parts are then washed and sand -blasted before they are
<br />reassembled with some new parts. In the process, the facility accumulates waste brake fluid, asbestos from
<br />brake shoes, sludge containing heavy metals and waste water from the brake and caliper washers and from
<br />cleaning up spills.
<br />On November, 6, 1997, during routine inspection of the facility, I received conflicting information on what
<br />would happen to the waste water; I then verbally advised Mr. Moreno, Safety Manager, and Mr. Dufall,
<br />Plant Manager, to characterize the waste water in the drums near the hazardous waste storage area. On
<br />11/5/97, Mr. Noe Gonzales, Production Manager, informed me that the wastewater was used in the steamer
<br />for part washing, on 11/6/97, he told me that he did not know what they did with the waste.
<br />On June 17, 1998, Joseph Moreno of QBR asked me if he could dry the sludge that contained heavy solid,
<br />metals, asbestos and brake fluid and take the dry cake to landfill. I informed Mr. Moreno that he could not
<br />do that (drying the sludge that contains heavy metals, asbestos and brake fluid and taking dry cake to
<br />landfill), it (drying the sludge) was considered treating hazardous waste, and a tiered permit would be
<br />required.
<br />On October 1, 1999, I conducted a routine inspection. The wastewater drums similar to those I saw during
<br />1997 routine inspection were on site. There were also several drums of sludge and waste brake fluid. None
<br />of those drums had a hazardous waste label. QBR representatives supplied analytical data, which they
<br />claimed indicated that it was non -hazardous, when it clearly indicated a hazardous waste. The analysis of
<br />the representative samples collected from those drums showed high concentration of Cadmium and Zinc.
<br />Some dry cake was observed on the ground near the employee picnic area. The analytical result of this
<br />area, sample 5A/513, collected from that cake showed high concentration of Cadmium and Copper. The
<br />concentration exceeded the regulatory level listed in section 66261.22 (a)(2)(A) of California Code of
<br />Regulation, Title 22. Other samples taken at the time of inspection revealed that hazardous waste was not
<br />being properly stored and removed from site in accordance Title 22.
<br />After the October 1, 1999 inspection, QBR removed the improperly stored waste under a uniform
<br />hazardous waste manifest.
<br />A Division of San Joaquin County Health Care Services
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