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Gaitan, Jason From: Mootz Eric J <EJMootz@Hormel.com> Sent: Monday, March 2, 2020 2:44 PM To: Gaitan, Jason Subject: RE: Return to Compliance. Attachments: Waste Profile Lead Acid Batteries 2020.pdf; Waste Profile Metal Fines 2020.pdf; 1.28.20.pdf; 2001811.pdf; Used oil filters hazardous waste label.jpg; Used oil hazardous waste label 2.jpg; Used oil hazardous waste label.jpg; Metal Shavings Hazardous Waste Labeljpg Follow Up Flag: Follow up Flag Status: Flagged Hey Jason, Sorry for the delayed response. It took longer to get a hazardous waste profile for the metal shavings than I planned. Violation 102: 1 have acknowledge the batteries being managed as lead acid batteries.This violation will remain open pending on the analytical results. Please note:testing required will have to address waste testing methods specified in Title 22 CCR sections 66261.20-24. Another note to consider: If metal fines are determined to be larger than 100 microns,they can be recycled as scrap metal. • I have attached the analytical results and hazardous waste profile for the metal fines, and the hazardous waste profile for the lead acid batteries. Going forward we are using safety kleen to dispose of both wastes. Violation 301:This violation will remain open pending on analytical results. Note: Hazardous waste testing is not necessary for this violation. I have attached a guidance document regarding used oil to this email. California Health and Safety Code (HSC section 25250.4) classifies used oil including used hydraulic oil as a hazardous waste. Another note: Federally used oil is not classified as a hazardous waste, however the state of California requires that businesses generating used oil are required to manage them as hazardous waste, unless certain requirements are met. • We are now acknowledging our used oil as a hazardous waste and have labeled it as such. Violation 605:The hazardous waste labels for the two 55 gallon containers with used oil provided in the RTC, is lacking a physical state and hazardous properties. In this case, physical state would be liquid and hazardous properties will be Toxic. I have attached minimum requirements for hazardous waste labels form to this email. Please send documentation/statement for correcting both hazardous waste labels. • We are now using the labels you provided on our 55 gallon used oil containers. I have attached pictures. Violation 608: 1 have a question regarding the used metal oil filters. Are they being managed as hazardous waste or as scrap metal? If they are being managed as hazardous waste then the hazardous waste labels for used metal oil filters are lacking a physical property and hazardous property. In this case it would be solid and toxic. If managed as scrap metal you can keep the yellow label provided by safety kleen and include the accumulation start date. Note: if managing as scrap metal please follow the guidelines in email attachment titled used oil filters. • We are now acknowledging our used metal oil filters as a hazardous waste and utilizing safety kleen to dispose of them. I have attached pictures of the hazardous waste label on the drum we store them in. I