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structurally sound and intact. The earth supports the concrete lining and the stainless steel sumps to ensure rigidity and protection from spills to the environment. The following addresses use of rinsate in response to your request from Aaron Hang in his e-mail dated January 8, 2018. Specifically, the request states, "To help address the notice to abate, the Environmental and Health Department will need a written statement regarding how the rinsate liquid is being managed along with supporting documentation." The collection areas are pumped out daily or more often if they fill up before the end of the work day. This product is then sold to local farms to be applied as the original intended use of this material to farm land. Attached are invoices for local farms purchasing this material as well as analytical analyses of the rinsate. In accordance with a guidance document from the California Department of Toxic Substances Control in Document 23 (RG Document #23, Revision #1, 8/19/1993 which has not been rescinded), it states: "Fertilizer rinsewaters are not normally considered wastes if they are reapplied on an agricultural area being treated or are diverted back into application or storage equipment for subsequent use." Under the General Waste Discharge Requirements for Fertilizer and Pesticide Handling Facilities, issued by the Central Coast Water Quality control Board, the discharge specification listed in paragraph C include the following in regards to fertilizer and pesticide rinsewaters: #3. "Non-hazardous and non-toxic fertilizer tank sludge and fertilizer spill cleanup material may be applied to farmland using appropriate agronomic rates specified on the product label." #7 "Collected and stored rinsewater containing pesticide or fertilizer residues shall be disposed of in accordance with the law and in a manner approved by the Executive Officer. If this rinsewater is applied to farmland or recycled on-site for landscaping irrigation, it shall be applied using the appropriate agronomic rates as specific on the product label." And, 22 CCR 66261 .2(a) defines "Waste" to mean "any discarded material of any form (for example, liquid, semi-solid, solid or gaseous) that is not excluded by section 66261.4(a) or section 66261.4(e) or that is not excluded by Health and Safety Code section 25143.2(b) or Health and Safety Code section 25143.2(d)." (B) however, commercial chemical materials listed in section 66261.33, which are discarded commercial chemical products, off-specification species, container residues, or spill residues thereof, and which are applied to the land and application to the land is their ordinary manner of use are non-RCRA hazardous wastes. Commercial chemical products which are "retrograde materials" as defined in section 66260.10 are not wastes until they become "recyclable i 1 1 1 1 1 1 i i i i i i i i i i i 1 1 1 i i i i i i i i i i i i i i i 1 1 i i i 1 1 1 1 1 1 i 1 1 1 t i i i i 1 1 4 iiiiiiiii..iiiiiiiir.ririi. .iiiiiriiiiii.�:.�:ir.�:iiitiiiii"