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JAMES T. DUFOUR MICHAEL R. DRAYFON KEN DAVIS, GOVERNMENT RELATIONS CONSULTANT ' DuFou & Associms* ATTORNEYS AT LAW December 22, 1992 Kasey Foley, REHS Director of Environmental Health PUBLIC HEALTH SVCS. - SAN JOAQUIN COUNTY P.O. Box 2009 Stockton, California 95201 819 F STREET SACRAMENTO, CA 95814 (916) 553-3247 si FAX (916) 553-3250 Re: Pacific Coast Producers: Report Of Violation And Schedule of Correction Dear Ms. Foley: Our client, Pacific Coast Producers (PCP), forwarded your Report Of Violation And Schedule Of Correction (Report), dated December 7, 1992. Pursuant to our telephone conversation on December 18, 1992, this will inform you of our anticipated schedule for completing the items listed in the Report. Nevertheless, you agreed to follow PCP to provide the requested certification on or before January 18, 1993. In addition, this letter will address the issue of the biennial report submissions requested in the Report. As set forth at length in Mr. Ron Myers' letter to Ms. Paula Violett and you, dated November 24, 1992, a copy of which is enclosed, PCP was responsive to the recommendations of the inspectors regarding the deficiencies that were ultimately made part of the Report. Mr. Myers' letter explains PCP's ongoing concern for proper hazardous waste practices, as well as other environmental concerns. As set forth in the letter, PCP retained our firm to develop a Corporate Hazardous Materials And Hazardous Waste Management Program that was to be implemented uniformly at all PCP plants in early 1993. It is expected that this program will significantly improve PCP's waste management practices with the same effectiveness as PCP's project this year to improve worker safety. Although the concerns raised in the report will all be addressed in the 1993 program, the following is our proposed schedule for correcting the matters noted in the Report (other the biennial report, which is discussed later). Violation #1, #2, and #3 (labeling of waste containers): All containers for the on-site storage of hazardous waste are labeled with the information set forth in the report. Additionally, a written informative policy for the labeling of hazardous waste containers will be implemented within 30 days. Violation #5 and #6 (contingency plan): Pursuant to our discussion, we anticipate that a contingency plan will be completed within the next 10 days.