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Michael Smith <br />Page 2 <br />halogenated hydrocarbon discharge. Nor is there any evidence that surrounding <br />properties may be the source of the contamination. <br />Mr. Brady filed a complaint with PHS-EHD citing improper storage of hazardous <br />materials and improper disposal of hazardous wastes at the facility known as <br />California Cedar Products (Cal Cedar) and a tenant known as L. O'Reilly and Sons <br />(O'Reilly). <br />PHS-EHD has statutory authority to 1) investigate the alleged reports of improper <br />disposal and/or storage of hazardous wastes and 2) conduct unannounced inspection <br />of facilities generating known and reported quantities of hazardous wastes in excess <br />of 5 tons a year through the California Code of Regulations, Health and Safety Code <br />Chapter 6.5, Section 25180. <br />PHS-EHD conducted a joint hazardous materials inspection with the Office of <br />Emergency Services on 18 October 1994 of Cal Cedar, 2470 Wilcox Road. The <br />inspection was performed based upon statutory authority in Health and Safety Code <br />to verify the storage and disposal practices in response to Michael Brady's letter of <br />complaint dated 1 July 1994. Unlike the facility inspections of Mr. Marlowe's tenant, <br />(Jeff Sweet and Company; 4638-B Waterloo Road: See attached report dated 13 <br />August 1993), no major violations of improper storage or improper disposals were <br />noted during the 2 hour inspection. <br />For the last 3 - 4 years, the research facility of Cal Cedar has employed pretreatment <br />of its waste water discharge. At the date of our inspection, no evidence of untreated <br />waste water was being discharged into the septic tanks. Water is supplied by a <br />public water supply since late winter 1990. <br />Prior to 1990, untreated waste water may have been discharged into the septic <br />systems (7 tanks, 3 grease traps, and 2 dry wells). Because PHS-EHD has no <br />regulatory authority to investigate historical uses nor has authority to direct Cal Cedar <br />to investigate their property for alleged discharges, discussions with the CVRWQCB <br />suggested that EPA may be able to pursue the investigation of the halogenated <br />hydrocarbons. <br />EPA contacted PHS-EHD 28 January 1994 and documentation was sent to EPA's <br />investigative staff person, Luisa Vallela, on 23 May 1994. Ms. Valiela telephoned <br />PHS-EHD on 2 December 1994 to state that the site had been accepted into the <br />Superfund program for investigation and prioritization.