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San Joaquin County <br />Environmental Health Department <br />600 East Main Street <br />Stockton, CA 95202 <br />Holt of California <br />7310 Pacific Ave. <br />Pleasant Grove, CA 95668 <br />Re: Inspection of Stockton Facility @ 1521 W. Charter Way on 4/12/2012 <br />#108: Metal fines: Prior to the April 2012 inspection Holt recycled our fines by simply <br />putting them in our scrap steel bin. We conducted two hazardous waste determinations on <br />different waste streams: 1) Spent media from our self contained sand blast cabinet; 2) <br />Collection of metal fines from metal working operations including but not limited to: <br />grinding, air arcing, & cutting. Please find enclosed those results. <br />Holt will be writing a Standard Operating Procedure on managing this waste and will <br />summit that to San Joaquin County Environmental Health Department (SJCEHD) when <br />completed. <br />#135: All documents were submitted to SJCEHD with regard to the Feb. 9, 2011 <br />inspection. #18 of that inspection stated that we "stored waste on site for longer than 90 <br />days." The drum of "paint waste" is at the point of generation which allows us to keep it <br />up to 270 days. As started in the inspection the accumulation start date was June 9, 2010. <br />This was the reason we did not have the waste hauled off "immediately", as was stated in <br />the summary of violations. <br />Where Holt did fail, is the shipping of this same waste for the calendar year of 2011. This <br />was an anomaly. The Subject Matter Specialist for this site was out on personal leave <br />during the time (May/June 2011) that this waste should have been shipped. During the <br />early part of March 2012 this mistake was discovered during an internal audit, and the <br />paint waste was shipped off immediately (Uniform Hazardous Waste Manifest <br />#009564448 JJK). <br />#605: The Subject Matter Specialist was re -familiarized with the term "hazardous <br />properties." Templates have been created of our common waste streams, reviewed, <br />posted and trained on. Also enclosed. <br />#804: The used fluorescent bulbs are now stored in a "structurally sound" container. We <br />are using the manufacture box with the proper labeling for Universal Waste. <br />Kevin Pargett <br />Environmental & Safety Inspector <br />916-240-1582 <br />k ax ett , holtca.corn <br />