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bp <br /> 0 <br /> BP West Coast Products LLC <br /> 4 Centerpointe Drive <br /> La Palma,CA 90623-1066 <br /> January 4, 2003 <br /> JAN 0 7 2003 <br /> Mr. Raymond Vo Flue Ei'VVi AIUENT HEALTH <br /> San Joaquin Coun y Environmental Health Department PERM T%SERVICES <br /> 304 East Weber Avenue, Third Floor <br /> Stockton, Califor 'a 95202-2708 <br /> RE: Inspection eport,October 10, 2002 <br /> ARCO Facil ty No. 2130 <br /> 7906 N. El U orado Street <br /> Stockton, C lifornia <br /> Dear Mr. Von Flu <br /> This letter responds on behalf of BP West Coast Products(BP)to an Inspection Report <br /> issued by the San aquin County Environmental Health Department(EHD) during an <br /> inspection of ARC 3 Facility No. 2130 by you on October 10, 2002 (Attachment A). <br /> I understand that I Is. Ruth Ha of KHM Environmental Management, Inc. (KHM) discussed <br /> this inspection wita you during a telephone conversation on November 4, 2002. <br /> Please note that A 1CO Facility No. 2130 is a leased facility. BP owns the real estate and <br /> the underground storage systems, but leases the property and improvements to a third- <br /> party dealer who operates the station. BP's franchisee agreement with the lessee-dealer <br /> requires the lessee dealer to comply with all requirements of the law. BP provides the <br /> lessee-dealers wi training and guidance on how to accomplish this goal. However, the <br /> lessee-dealer is an independent business person and not a BP employee. <br /> HAZARDOUS W STE INSPECTION <br /> The following is B 's response to the four items noted during the hazardous waste <br /> inspection on October 10, 2002. <br /> • Item 10: 6262.11(CCR) Failed to determine if a waste is a hazardous waste. <br /> The Inspection Re ort states that the facility should begin handling used absorbents and fuel <br /> filters as hazardou waste. Absorbent and fuel filter waste is generated by the lessee-dealer <br /> and it is the lessee dealer who is responsible for its proper management and disposal. <br /> According to the Inspection Report, the operator of the site informed the inspector during <br />