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it according to the Title 22 hazardous waste regulations". We reviewed applicable codes <br /> and regulations, and have reconfirmed that our "rinsate" solutions are not wastes. The <br /> fertilizer dilute solutions and the spray oil rinsates are not being discarded, relinquished, <br /> or recycled, and are not inherently waste-like. These materials are products that are <br /> being used for their intended purpose, and can be used directly without making any <br /> changes to the material. There is support for this in a guidance document from the <br /> California Department of Toxic Substances Control. In RG Document #23, it states: <br /> "Fertilizer rinsewaters are not normally considered wastes if they are reapplied <br /> on an agricultural area being treated or are diverted back into application or <br /> storage equipment for subsequent use." <br /> Under the General Waste Discharge Requirements for Fertilizer and Pesticide Handling <br /> Facilities, issued b)/ the Central Coact \Nater Quality Control Board the discharge <br /> specifications listed in paragraph C include the following in regards to fertilizer and <br /> pesticide rinsewaters: <br /> Collected and stored rinsewater containing pesticide or fertilizer residues shall be <br /> disposed of in accordance with the law and in a manner approved by the <br /> Executive Officer. If this rinsewater is applied to farmland or recycled on-site for <br /> landscaping irrigation. it shall be applied using the appropriate agronomic rates <br /> as specified on the product label. <br /> Based on this information, we request that violation #102 be vacated. If you have any <br /> questions, please call me at (208) 867-2627 or email me at john.pallen(a-)-simplot.com. <br /> Sincerely, <br /> J R. SIMPLOT COMPANY <br /> John J. Pallen, CHMM <br /> EHS Manager <br /> cc. S. Woods <br /> P. Simpson <br /> P. Derig <br /> B. Ackerman <br /> ti.l.iiiii`.I:.I:.tiiiiii./:iii <br />