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0 <br /> .... RECEIVED <br /> Stacy Rivera, REHS JUN 0 6 2014 <br /> San Joaquin County ENVIRONMENTAL <br /> Environmental Health Department PERMIT/SERVICES HEALTH <br /> 1868 E. Hazelton Ave. <br /> Stockton, CA 95205 <br /> RE: May 6th, 2014 Compliance Inspection at Yara Stockton Facility <br /> Ms. Rivera, <br /> This letter is in response to the inspection completed by the San Joaquin County <br /> Environmental Health Department on May 6th, 2014 at the Yara North America (YNA) Stockton <br /> facility. According to the referenced inspection report, the alleged violation cited was '4108 — <br /> C2(Class 2 violation) - CCR 66262.11- Failed to determine if waste is hazardous waste." YNA <br /> feels that a waste determination is not necessary based on generator knowledge and testing. In <br /> addition, the material leaving the facility is actually still being used for its intended purpose, <br /> rather than disposed of as a waste. <br /> The fertilizer product rinse-water material in question is nothing more than off-spec material <br /> accumulated as small amounts which are captured when a small product spill occurs and is <br /> washed down using city potable water. Captured product is immediately directed into a sump <br /> and then gravity fed into the collection tank. Since Yara can no longer sell this material as <br /> pristine product, it is recycled through a professional recovery company. This material is, in <br /> fact, a useful and valuable product —just in a more diluted form and it may or may not contain <br /> negligible amounts of oil from equipment/trucks that drip onto the ground surface and is <br /> captured in the rinsing process (the site has spill kits readily available should a significant spill <br /> occur). The contracted product recovery vendor YNA utilizes, Recovery Solutions, Inc., has <br /> been vetted as part of our internal due diligence process and YNA sees no reason to believe <br /> that the process is inadequate. In fact, prior to the product being used for its intended purpose <br /> (a low nutrient level fertilizer product) the recycling vendor is further purifying any impurities <br /> through a series of filtering and biological processes prior to crop field application. <br /> Again, there is nothing hazardous about this material and YNA does not dispose of this product <br /> as a waste. The product information sheets and technical information for these products are <br /> attached (Attachment 1) and accurately describe the product. This product is considered non- <br /> hazardous as it contains no hazardous constituents, including metals, based on extensive <br /> generator knowledge and historical analytical testing performed by both YNA and Recovery <br /> Solutions, Inc. (RSI). Additionally, the pH of each load is taken before loading into the vendor's <br /> truck. The results of the pH measurements for loads recycled from our facility, along with a <br /> custody receipt, are attached (Attachment 2). We've also included a brief description of the <br /> product purification process that occurs upon reaching the recycler's facility. Eric Bowman, <br /> President of RSI has ensured YNA that his handling and storage processes have been <br /> Yara North America, Inc. 100 N.Tampa Street, Suite 3200 Telephone: 813-222-5700 <br /> Tampa, Florida 33602 Telefax: 813-875-5735 <br />