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Elena K. Manzo [EH] <br />Page 1 of 2 <br />From: <br />David Olney [DOIney@strongtie.com] <br />Sent: <br />Friday, December 11, 2015 4:20 PM <br />To: <br />Elena K. Manzo [EH] <br />Subject: <br />FW: Simpson Strong -Tie Large Quantity Hazardous Waste Generator Inspection Report - <br />Response <br />Follow Up Flag: <br />Follow up <br />Flag Status: <br />Red <br />Attachments: <br />return to compliance.pdf; metal fines testing 12 2015.pdf; Emergency Contact List - October <br />2015.pdf; BCP PLAYBOOK - October 2015.pdf; Emergency Spill Response Procedure <br />br20.doc; EAP - FPP Stockton 2015.docx; training roster 2015.pdf; job descriptions pdf.pdf <br />I tried to send but there is a size issue so I will have to send multiple emails <br />From: David Olney <br />Sent: Friday, December 11, 2015 4:16 PM <br />To: 'Elena K. Manzo [EH]' <br />Subject: Simpson Strong -Tie Large Quantity Hazardous Waste Generator Inspection Report -Response <br />Elena, <br />I hope this email finds you well. <br />I'm responding to your Inspection report generated 11/9/2015 and received sometime during the week of the <br />14th I believe but I was out of town as mentioned in previous email. <br />There are many documents and photos that will be attached to this email so more than likely I will send several <br />emails in order to get all of the information to you. <br />Please contact me directly if there are any questions/concerns that I may address. I've attached the "return to <br />compliance" document. <br />Item #105 <br />Failed to determine if a waste is a hazardous waste or retain waste analysis on site for 3 years. <br />We had Advanced Chemical Transport come in and take samples of the three areas identified by you. They were <br />then sent to California Agricultural & Environmental Laboratory in Ceres. Two of the sampled "metal fines" had <br />already been profiled as "waste" and was removed from the property and disposed of. This would be the "paper <br />filters" with metal fines from the grinders and the "metal fines" from the Dayton vacuum system. The "metal <br />fines" sampled from the New Tooling drill press did come back as hazardous waste. This was the material <br />previously recycled if you recall. We have implemented a new process for this waste. ACT is creating a profile <br />and will pick it up within a 90 period. The new process includes putting a 55 drums under the spout that the <br />waste comes out of and then once full or within 90 days will be removed. <br />I've attached the test results. I will also retain the analysis at minimum for three years. <br />Item #107 <br />Contingency plan is incomplete <br />Documents attached <br />12/15/2015 <br />