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amazon <br />April 1, 2020 <br />CONFIDENTIAL <br />Delivered by Email <br />Lydia Baker <br />Environmental Health Department of San Joaquin County <br />1868 East Hazelton Avenue <br />Stockton, California 95205 <br />Email: (baker@sjgov.org <br />RE: In Response to RCRA Large Quantity Hazardous Waste Generator Inspection Report <br />Dear Lydia Baker, <br />Amazon is responding to the above -referenced RCRA Large Quantity Hazardous Waste Generator <br />Inspection Report (dated March 3, 2020), in connection with your onsite inspection of the Amazon <br />facility 507, located at 188 South International Parkway, Tracy, California 95377 (the "Facility"), <br />1) Alleged Violation: #102 CCR 66262.11 Failed to determine if a waste is a hazardous waste. The <br />facility should immediately stop recycling metal fines, make a hazardous waste determination for <br />each waste and manage it according to Title 22 CCR. The facility must submit a statement and <br />supporting documentation with the hazardous waste determination. The facility must demonstrate <br />current storage and labeling for wastes to be hazardous waste. The facility must provide disposal <br />records for wastes determined to be hazardous wastes and stored longerthan the number of days <br />specified in Title 22 CCR for hazardous waste generator status. <br />• Facilit,/s Response: Amazon has stopped the recycling of metal fines. A sample of the metal <br />fines was collected by Stericyle on Thursday, March 25, 2020, and the sample will be tested <br />using the Toxic Characteristic Leaching Procedure and Bioassay Test to make a hazardous <br />waste determination. Once Amazon receives the results, we will determine hazardous waste <br />applicability and will label and manage the waste appropriately. <br />2) Alleged Violation: #112 CCR 66262.20 Failed to prepare manifests for transportation of hazardous <br />waste. The facility must provide a corrective action statement and any supporting documentation <br />from this facility for off-site transfer, treatment, storage or disposal. <br />• Facility's Response: Please see Stericycle's response to the manifesting of white goods and <br />gel packs for transportation (Attachment A). <br />Alleged Violation: #118 Violation #118 CCR 66265.16 Failed to maintain complete hazardous waste <br />training record. The facility must immediately train all employees who work with hazardous waste in <br />compliance with the time frame and training materials required. The documentation must include a <br />list of training topics, date of training, job title, name of employee, written job description <br />(qualifications and duties), and employee signed (or certified) record that documents the training. <br />• Facility's Response: Please see Table 1 Regulated Waste Training Requirements by Program <br />Job Title (Attachment B). This table provides the job title of the associates who work with <br />hazardous waste, their written job description (qualifications and duties), and the list of <br />training topics they must be trained on. <br />