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0 0 <br />Central Valley Waste Services <br />1333 E. Turner Road <br />P.O. Box 241001 <br />Lodi, California 95241-9501 <br />Sent Via Certified Mail <br />7004 2890 0003 0167 7806 <br />May 9, 2005 <br />State Board of Equalization <br />Property and -Special Taxes Department _ - <br />400 N Street <br />P.O. Box 942879 <br />Sacramento, CA 94279-0057 <br />Attention: Mr. Kevin Sparks, Senior Tax Auditor <br /> <br /> <br /> 2005; Central al Valley Waste <br />Services <br />Dear Mr. Sparks: <br />This letter is submitted in response to your letter of 12 April 2005 regarding the subject Petition of <br />Redetermination. <br />Reclassification of Vehicle Wash Sludge Waste Stream and Submittal of Additional Data <br />Central Valley Waste Services (CVWS) is seeking to reclassify the vehicle wash sludge waste <br />stream that was shipped on hazardous waste manifests in error. The non -hazardous <br />classification is based on generator knowledge described and analytical data submitted with the <br />CVWS letter dated 11 February 2005. To further substantiate that the vehicle wash sludge waste <br />stream is not a hazardous waste per California criteria, a second sample of the sludge was <br />analyzed. The results of the analysis confirm that the vehicle wash sludge waste stream is not a <br />California -regulated hazardous waste. A copy of the analytical results is attached in Enclosure <br />(1) <br />Manifest Information for Wastes Shipped <br />As requested in your letter of 12 April 2005, Enclosure (2) contains a summary of manifests <br />shipped for the years 2001, 2002, 2003, and 2004 along with copies of the manifests. The <br />summary tables indicate the waste stream and whether it is a hazardous waste or, in the case of <br />the vehicle wash sludge, a non -hazardous waste misclassified as hazardous. The vehicle wash <br />sludge makes up the bulk of the material shipped. The weight of the other waste streams <br />shipped is estimated at less than 5 tons for each of the years under review. <br />2004 Claim for Refund <br />Thank you for clarifying the correct procedure for addressing the 2004 taxes. As you noted, the <br />amount of the 2004 tax stated in the CVWS letter dated 11 February 2005 was in error. The <br />correct amount of the 2004 tax is $1,333.00. CVWS is claiming a refund for the full amount. This <br />is based on the estimated weights given in summary for 2004 in Enclosure (2). <br />