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San Joaquin County Environmental Health Department 600 East Main Street Stockton, CA 95202 Holt of California 7310 Pacific Ave. Pleasant Grove, CA 95668 Re: Inspection of Stockton Facility @ 1521 W. Charter Way on 2/9/2011. The intent of the document is to illustrate that Holt of California's operations @ 1521 W. Charter Way are compliant with all Federal, State, and local laws. The few instances where we need to change our process; this will be noted as well. This document corresponds with the inspection report on the above stated date in numerical order. #7) Holt is committed to being environmentally responsible for all waste streams generated. Attached is the current (date of inspection) analytical profile of our waste. EHD Inspector Stacy Rivera states in the Summary of Violations that "No hazardous waste determination has been made". The attached proves otherwise. This Inspector further instructed Holt to "Immediately make a hazardous waste determination for these wastes and manage them according the Title 22". Please find attached the analytical results pulled by Asbury Environmental. We tested three waste streams: Wash rack soil, parts washer skimmer water, and absorbent material. All three were determined to be non -hazardous. Hence, Holt is in compliance with CCR 66262.11. # 18) The drum of "paint waste" with a start date of June 9, 2010 may be kept on site up to one year according to 22 CCR §66262.34(e)(1)(B) from our understanding. Furthermore, the location of the drum (which meets container requirements 22 CCR §66262.34(e)(1)(D)) and the location meets the definition of a point of generation (i.e. satellite accumulation) in Title 22 CCR §66262.34(e)(1)(E). #20) All red plastic bins have had the hazardous material labels removed. #27) Keeping the containers closed that collect the material from our automated parts washing cabinets' oil skimmer was a bit of a challenge. We are currently completing the fabrication of a "bridge." This bridge will get the waste from the drip lip to the container. Being that our waste does not meet the standard of hazardous, keeping the container closed does not apply to this waste stream. Regardless, Holt will comply as a best practice measure. #31) Due to the complexity of a tank assessment and this document is not completed. Our environmental consultants, HDR/EZM is working this assessment. This report will be submitted to EHD address at the of this document no later than April 15, 2011. #45) The contingency plan for the facility has been updated. Copy attached.