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Garrett Backus [EH] From: Garrett Backus [EH] Sent: Monday,January 08, 2018 10:38 AM To: 'john.pallen@simplot.com' Cc: Aaron Hang [EH]; Elena K. Manzo [EH]; Michelle D. Henry [EH]; Muniappa Naidu [EH] Subject: Simplot inspection report amended April 5 2016 - violation 102 Hi John, Regarding violation 102, inspection report amended April 5, 2016, Simplot,4863 Carpenter Road, Stockton CA— Hazardous waste determination of fertilizer and herbicide rinsate. Your letter dated 15 April 2016 states in the next to last paragraph that"The fertilizer dilute solutions and the spray oil rinsates are not being discarded, relinquished, or recycled, and are not inherently waste-like. These materials are products that are being used for their intended purpose, and can be used directly without making any changes to the material." The Environmental Health Department (EHD) inspection report states that"... all rinsate is being relinquished to the outside company as 'diluted fertilizer' with 'no analysis, no guarantee'..." The outside company is Van Exel Dairy. From the documentation provided by Simplot and the EHD inspection report, the rinsate water may contain fertilizer or herbicide and it is being sold to Van Exel Dairy for$1 with no herbicide or fertilizer analysis. The dairy cannot use the products for their intended purpose and cannot apply the rinsate to their crops at an agronomic rate since material information or product analysis is not provided to them. The EHD cannot rescind the violation and considers the rinsate to be waste which requires a hazardous waste determination per Title 22 California Code of Regulations section 66262.11. Sincerely, Garrett Backus, Ld. Sr. REHS,CUPA programs San Joaquin County Environmental Health Department 1868 E Hazelton Ave,Stockton,CA 95205 (209)468-2986 (phone) (209) 468-3433 (fax) gbackus@sjcehd.com http//www.sjcehd.com/ 1