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Alaniz, John <br /> From: Steven Slater <sslater@usrscrap.com> <br /> Sent: Tuesday, May 19, 2020 8:13 AM <br /> To: Alaniz, John <br /> Subject: RE: San Joaquin County Haz Waste Inspection <br /> Attachments: Signed LDR for UHWM 006148983 GBF.pdf, LDR Initial Statement Supporting <br /> Details.docx; antifreeze-mixed oil clarification letter.pdf <br /> Good day John, <br /> The signed LDR from UHWM 003528712 GBF 12/19/2017 (Return to Compliance Attachment F) represents the first <br /> manifest that was signed be me as a representative of Universal Service Recycling, Inc requiring an LDR for Freon <br /> contaminated oil (chlorodifluoromethane) picked up by American Valley Waste Oil and shipped to Stericycle.According <br /> to both Fed and State regulations (see supplemental attachment in this email "LDR Initial Statement Supporting <br /> Details.docx") explains the requirement for only the initial LDR is required as long as the waste stream and destination <br /> remain the same. For the sake of returning to compliance I have also attached the signed copy of the LDR specific for <br /> UHWM 006148983 GBF. However for the sake of argument and my many years of only signing one initial LDR per waste <br /> stream requirements and the multitude of Hazardous waste disposal contractors that I have worked with; please verify <br /> this from your regulatory side that this is in fact accurate and satisfactory. I have never seen anyone sign every shipment <br /> in over 15 years' experience. Also of note;the TSDF's that I have dealt with in those 15 years do not require a signed <br /> copy for every shipment of same materials profiled for approval. <br /> In regards to the American Valley Waste Oil "milk run" Invoice 181871 manifested on 006454163 GBF shows 1250 <br /> gallons of"Non-RCRA Waste Liquid Used Oil/Mixed Oils" as picked up on 4/7/20.This is accurate as the container <br /> labeled "Used Antifreeze"was more oil than antifreeze and picked up with the used oil as "mixed". Upon inspection and <br /> on-site testing by the transporter the contents passed all transported requirements for disposal along with the used oil. <br /> The Invoice 181871 manifested on 006454163 GBF is accurate and included the contents found in the drum labeled as <br /> Used Antifreeze upon your inspection. I am including an attachment from Mc Dougall Environmental to support this <br /> statement; "antifreeze mixed oil clarification letter". <br /> 4@�k <br /> Steven Slater,OHST <br /> EHS Manager <br /> Universal Service Recycling,Inc. <br /> Universal Service Recycling,Merced Inc. <br /> Universal Service Recycling,Nevada LLC <br /> t: (209)944-9555 <br /> c: (209)751-9946 <br /> £(209)343-3760 <br /> e: sslatergusrscrap.com <br /> 1 <br />