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0 & <br />Bridgestone Retail Operations, <br />333 E. Lake Street - Bloomingdale, IL - 60108 <br />VIA FACSIMILE AND FEDERAL EXPRESS <br />San Joaquin County <br />Environmental Health Department <br />Attention: Mr. Garrett Backus <br />600 East Main Street <br />Stockton, California 95202-3029 <br />Facsimile: (209) 468-3433 <br />April 26, 2011 <br />Re: Re: Bridgestone/Firestone #3583 <br />720 East Hammer Lane #1 Stockton California 95210 <br />Dear Mr. Backus: <br />This letter constitutes Bridgestone Retail Operations, LLC's (`BSRO's") response to the <br />Notice to Comply that BSRO received with respect to the Firestone Complete Auto Care facility <br />located at 720 East Hammer Lane in Stockton, California (the "Facility"). The Notice to <br />Comply references six separate items that were allegedly identified during an inspection of the <br />Facility that occurred on March 29, 2011. <br />BSRO has taken corrective and preventative steps to remedy the storage, management <br />and labeling items set forth in the Notice to Comply. BSRO believes that the Facility was in <br />compliance with the hazardous waste determination and tank assessment items at the time of the <br />inspection. With respect to these, BSRO has taken steps to ensure that the Facility maintains <br />proper documentation on-site and in a readily accessible location. BSRO's responses to each of <br />the six items alleged in the Notice to Comply are detailed below and supporting documentation <br />is attached to this response. <br />1. CCR 66262.11: Metal fines are generated from the brake rotor smoothing operation. Make <br />a hazardous waste determination for the metal fines waste, and manage it according to the <br />Title 22 hazardous waste regulations. Particles 100 microns or smaller must be handled as <br />hazardous waste if the metal is determined to be a hazardous waste. Submit a statement and <br />supporting documentation explaining how this waste will be managed by April 29, 2011. <br />BSRO has sampled brake shavings and made hazardous waste determinations, in California, <br />at numerous other facilities with similar operations, including in Rancho Cordova, Santee, <br />San Diego, Kearney Mesa, Newark, Fremont and Hayward. In all instances, the brake <br />shaving waste did not exceed any of the regulatory levels for hazardous waste. BSRO <br />believes that the sampling already conducted at these locations is representative of the brake <br />Credit Rrst National Association • ExpertTire <br />Rrestone Complete Auto Care'- Freston Complete Reet Care' <br />TiresPlus- • Wheel Works <br />