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1515 N Main St, Manteca <br />5/17/2018 <br />PHOTO # 9 <br />np waste for the clarifier is hazardous or not <br />9-wYYY <br />August 3, 2015 <br />Ralph Torres, Branch GeWana8er <br />Safety-Kleen Systems. Inc. <br />Salida CA Branch <br />Record ID PRO514068 <br />RE: Recent General Waste Characterization Survey of Salida Branch Oily Water <br />(Non -Industrial) Vacuum ("Vac") Waste Customers as Non -Hazardous <br />As you are aware, many customers ask to use Safety-Kleen derived waste characterization data from <br />surveys we routinely make of certain wastestreams. One such wastestream is oily water from non- <br />industrial (typically automotive/equipment related) Vac Waste customers. We recently completed the <br />survey of random samples from customers at your branch. The results are attached to this memo. The <br />results more than adequately confirm with a high degree of confidence what we see throughout <br />California and elsewhere in the nation: the oily water from these non -industrial vac waste customers is <br />certainly predicted to be non -hazardous. All general hazardous waste characteristics, from metals to <br />VOCs to Semi -VOCs to Flashpoint to pH to aquatic toxicity show that a robust and random sampling <br />of the oily water vac waste customers serviced by your branch would be non -hazardous under both <br />RCRA (40 CFR Part 261) and California regulations (Title 22 CCR Chapter I 1 starting at ¢66261). <br />All of our Vac Waste customers are required as the "generator of the waste" to make their own waste <br />determination and waste characterization; Safety-Kleen can assist our customers with this process, but <br />it remains a generator responsibility. However, these Vac Waste oily water non -industrial customers <br />can make this determination by the appropriate application of generator knowledge regarding the <br />process generating the waste and/or the use of laboratory analytical testing data. <br />Should a State of California (e.g., DTSC) or local CUPA inspector want to challenge our customer's <br />waste determination and/or waste characterization, then the agency personnel are certainly fully <br />capable of sampling the waste themselves under their specific inspection authority and sending the <br />sample for laboratory testing to challenge the customer's waste determination/characterization. <br />Should you have any questions or need any additional explanation about this issue, then please do not <br />hesitate to contact me directly. <br />Sincerely,DD-- <br />� /� 6*1_ <br />Billy R. Ross, P.E. (CA #C49651) <br />Vice President of EHS — North American Branches I Safety-Kleen I A Clean Harbors Company <br />Richardson, TX bill.rossnsafety-kleen.com <br />406.468.9192 (o) 530.304.6915 (c) <br />John Alaniz, REHS Page 9 of 9 <br />