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S TO CKTON 1c.OGIS TICS LLC <br />7 Corporate Drive <br />Keene, New Hampshire 03431 <br />Phone: (603) 354-7000 <br />Fax: (603)354-4694 <br />VIA HAND DELIVERY <br />October 15, 2015 <br />Ms. Michelle Henry, Inspector <br />San Joaquin County <br />Environmental Health Department <br />1868 East Hazelton Avenue <br />Stockton, CA 95205-6232 <br />Re: Small Quantity Hazardous Waste Generator Inspection <br />4199 East Gibraltar Ct, Stockton, CA 95206 <br />Supplemental Response to Alleged Violations <br />Dear Ms. Henry, <br />RECEIVED <br />OCT 16 2015 <br />ENVIRONMENTAL HEALTH <br />PERMIT/SERVICES <br />Stockton Logistics, LLC, (the "Company") submits this letter as a follow up to our meeting at <br />your office on October 6, 2015. We appreciate having had the opportunity to meet with you to <br />discuss directly this matter. <br />During our meeting, the majority of the discussion focused on the Company's return to compliance <br />efforts in connection with the alleged violations in the Small Quantity Hazardous Waste Generator <br />Inspection Report issued and amended on August 3, 2015. <br />This letter provides the Company's supplemental response with respect to return to compliance <br />matters. While the Company continues to contest certain alleged violations (including but not <br />limited to, alleged violation Item 102), and the Company maintains that it has successfully <br />demonstrated compliance with applicable regulations, the Company has implemented certain <br />training measures and taken other actions in a good faith effort to resolve this matter. <br />Further demonstrating the Company's commitment to compliance and resolving this matter, the <br />Company, along with representatives from the Company's waste broker (RM Jones) and <br />environmental consultant (Arcadis U.S., Inc.), conducted a three-day site visit focused on the <br />alleged findings. Attached as Exhibit 1, please find correspondence from Arcadis U.S., Inc. <br />supporting our response. <br />Temporary EPA ID Number and F Code (Item 10 1) <br />In response to your question regarding the temporary EPA Number, upon review of records, in <br />May 2011 the Company used a temporary EPA number in order to dispose of a drum. Regarding <br />your question relative to the removal of certain F code items under manifest 008025299, the <br />material was waste liquid (acetone and MEK found in paint products) from the aerosol <br />puncturing process. F waste codes were used because of the presence of spent non -chlorinated <br />solvents. <br />