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Sent Via Certified Mail <br />7004116o 0003 7526 3119 <br />February 11, 2005 <br />Environmental Fees Section, MIC:57 <br />State Board of Equalization <br />P.O. Box 942879 <br />Sacramento, CA 94279-0057 <br />• <br />central Valley Waste Services, Inc. <br />A WASTE MANAGEMENT COMPANY <br />1333 E. Turner Road <br />P.O. Box 241001 <br />Lodi, Califomin 95241-9501 <br />Sent via Facsimile (209) 369-8274 <br />916-327-0859 (209) 369-6894 Fax <br />RE: Petition for Redetermination; Account Notice of <br />Determination ID Number 0000 3182 o82 dated 13 January 2005; <br />Central Valley Waste Services <br />Ladies and Gentlemen: <br />Central Valley Waste Services, a wholly owned subsidiary of Waste Management, <br />Inc., is hereby submitting a formal appeal to the subject Notice of Determination. <br />Please find enclosed a copy of the Petition for Redetermination (Enclosure (1)) <br />which appeals the entire Hazardous Waste Generator Fee, Penalty and Interest <br />levied in the amount of $7,996.74. In addition, please note that Central Valley <br />Waste Management is also appealing the 2004 Hazardous Waste Generation Fee <br />of $167.00. <br />The Petition for Redetermination is based on the following information. <br />Approximately 95% of the waste that was assessed by the Board of <br />Equalization for the period of tool through 2003 for Central Valley Waste <br />Services was a non -hazardous vehicle wash sludge. Although this waste <br />was mistakenly shipped on hazardous waste manifests, it is not a <br />hazardous waste under the California regulations and as such is not <br />subject to the hazardous waste generator fee levied by the Board of <br />Equalization. <br />This waste characterization as non -hazardous is based primarily on <br />generator knowledge of both the specific waste stream at the Central <br />Valley Waste Services facility and the process waste stream as it is <br />generated at over 30 locations for similar Waste Management facilities in <br />California. <br />Extensive waste characterization data have been compiled by Waste <br />Management over the last 10 —15 years in managing vehicle wash sludge <br />generated at its solid waste hauling facilities and accepted for disposal at <br />