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DUFOUR & ASSOCIATES <br />ATTORNEYS AT 1AW <br />JAMES T. DUFOUR 819 F STREET <br />SACRAMENTO, CA <br />MICHAEL I, DRAYTON 95814 <br />(916) 553-3247 <br />KEN DAVIS, FAx (916) 553-3250 <br />GOVERNMENT REIATIONS CONSULTANT <br />Ms. Gail McNeil <br />DEPT. OF TOXIC SUBSTANCE CONTROL <br />400 P Street <br />Sacramento, CA 95914 <br />Re: Pacific Coast Producers Biennial Reports <br />Dear Ms. McNeil: <br />This will confirm our telephone conversation today in which we discussed the applicability <br />of regulations regarding biennial reports for small quantity generators of hazardous waste <br />(less than 1,000 kg in a single month). <br />From our conversation, it is my understanding that the requirement of filing a biennial <br />report is not applicable to a generator who generates less than 1,000 kg of hazardous waste, <br />or 1 kg of RCRA acutely hazardous waste, in any single month. As you know, it is our <br />position that Pacific Coast Producers (PCP) does not generate 1,000 or more kg of <br />hazardous waste in any single month, or 1 kg or more of RCRA acute hazardous waste in <br />any single month. <br />It is my further understanding from our telephone conversation that if we can demonstrate <br />from the hazardous waste manifests that they do not average to 1,000 or more kg of <br />hazardous waste, this will satisfy the Department of Toxic Substance Control that PCP is a <br />small quantity generator and not subject to the biennial report requirement. <br />We will gather the necessary information as soon as possible. In the meantime, you are <br />aware that the San Joaquin County Public Health Services has requested that we provide <br />them with a copy of each biennial report on the site. They will want these copies by <br />January 18, 1993. Consequently, you-: agreed to telephone Ms. Kasey Foley of the San <br />Joaquin County Public Health Services and inform her that we are working with DISC on <br />this issue. <br />