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August 3, 2015 Ralph Torres, Branch General Manager Safety-Kleen Systems, Inc. Salida CA Branch RE: Recent General Waste Characterization Survey of Salida Branch Oily Water (Non -Industrial) Vacuum ("Vac") Waste Customers as Non -Hazardous As you are aware, many customers ask to use Safety-Kleen derived waste characterization data from surveys we routinely make of certain wastestreams. One such wastestream is oily water from non- industrial (typically automotive/equipment related) Vac Waste customers. We recently completed the survey of random samples from customers at your branch. The results are attached to this memo. The results more than adequately confirm with a high degree of confidence what we see throughout California and elsewhere in the nation: the oily water from these non -industrial vac waste customers is certainly predicted to be non -hazardous. All general hazardous waste characteristics, from metals to VOCs to Semi -VOCs to flashpoint to pH to aquatic toxicity show that a robust and random sampling of the oily water vac waste customers serviced by your branch would be non -hazardous under both RCRA (40 CFR Part 261) and California regulations (Title 22 CCR Chapter 11 starting at §66261). All of our Vac Waste customers are required as the "generator of the waste" to make their own waste determination and waste characterization; Safety-Kleen can assist our customers with this process, but it remains a generator responsibility. However, these Vac Waste oily water non -industrial customers can make this determination by the appropriate application of generator knowledge regarding the process generating the waste and/or the use of laboratory analytical testing data. Should a State of California (e.g., DTSC) or local CUPA inspector want to challenge our customer's waste determination and/or waste characterization, then the agency personnel are certainly fully capable of sampling the waste themselves under their specific inspection authority and sending the sample for laboratory testing to challenge the customer's waste determination/characterization. Should you have any questions or need any additional explanation about this issue, then please do not hesitate to contact me directly. Sincerely, 0/16� Billy R. Ross, P.E. (CA #C49651) Vice President of EHS — North American Branches I Safety-Kleen I A Clean Harbors Company Richardson, TX bill.ross(?safety-kleen.com 406.468.9192 (o) 530.304.6915 (c)