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"Onward and Upward" <br /> SCHUFF STEEL <br /> PO Box 19028 <br /> Phoenix, AZ 85005-9028 <br /> 1841 W Buchanan <br /> Phoenix, AZ 85007 <br /> www.schuff.com <br /> June 24, 2019 <br /> Mr. John Alaniz <br /> San Joaquin Environmental Health Department <br /> 1868 E. Hazelton Ave <br /> Stockton, CA 95205 <br /> Re: Schuff Steel Response Large Quantity Hazardous Waste Generator Inspection Report May 30, <br /> 2019 <br /> Mr. Alaniz, <br /> Thank you for the opportunity to respond to the violations annotated on May 30, 2019 for Schuff <br /> Steel, Stockton, CA facility. <br /> Corrected: <br /> CCR 66262.11 Failed to determine if a waste is a hazardous waste. -The TCLP was completed on <br /> 12/11/2017. The Analytical Report is attached. <br /> CCR 66265.16(d) Failed to maintain complete personnel training records. -We have separated out in <br /> our SPCC a competent person and employees. A copy of pg. 15 of our SPCC is attached with that <br /> area highlighted. <br /> HSC 25160.2(b)(3) Failed to keep copies of consolidated manifesting receipts for three years. — Our <br /> used oil is not tracked via manifest since we do not dispose of it as waste. I have attached the <br /> receipts from Safety-Kleen Systems from when they have picked it up. <br /> CCR 66262.34(f) Failed to completely label stationary hazardous waste tanks. —Corrected on Site. <br /> CCR 66265.192(a) Failed to comply with new hazardous waste tank system assessment <br /> requirements. —Tank has been removed and disposed of. We have changed our method of storage <br /> to using 2 55 gal drums. <br /> CCR 66265.195 Failed to conduct daily inspections of hazardous waste tank system and maintain <br /> records onsite. —This violation is no longer valid since there is no longer a tank system onsite. <br /> CCR 66262.34(f) Failed to completely label containers or portable tanks of hazardous waste. — <br /> Corrected on site <br /> In process: <br /> CCR 66262.34(a) Stored hazardous waste on site longer than 90 days without a permit or <br /> authorization. —The disposal location, Buttonwillow, will not accept the 20yrd roll bin of dust off the <br /> previous analytics. Currently Safety-Kleen has new analytical results and is looking for a TSD facility <br /> that will accept it in the 20yrd bin. <br /> SCHUFF STEEL COMPANY - A SUBSIDIARY OF DBM GLOBAL. <br />