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From: Florido, Elianna Sent:Thursday, March 26, 2020 12:23 PM To: Randi Beghtel <randi@stocktonfenceco.com> Cc: 'Phil Beghtel' <phil@stocktonfenceco.com>; 'Edward Brown' <edward@stocktonfenceco.com> Subject: Re: Stockton Fence & Material -2020 Hazardous Waste Inspection Hi Randi, I reviewed your 3/25/20 response to my email regarding the violations. The violations, except for those listed below, have been closed, per your response. The following information is needed to close the remaining open violation: - Violation 102: Your response to this and the other violations indicate that Ramos Environmental placed the metal fines into the drums containing the oily absorbent and soil, and managed this waste as non-RCRA (California-regulated) waste under the manifest 021323642JJK (Exhibit C). However, how do you know that the metal fines are not also RCRA (Federally-regulated) waste?To determine if the waste is also RCRA, a complete analysis of the metal fines is needed. The analysis you provided is incomplete, thus the metal fines hazardous waste determination is still incomplete. You have two options to correct this violation: 1. Perform a complete analysis of the metal fines to show the metal fines are a non-RCRA hazardous waste and not a RCRA hazardous waste, OR 2. Submit a written statement documenting that the metal fines will be disposed of as both non-RCRA and RCRA hazardous waste, and include which state and federal waste codes will be used for the metal fines. Also, a manifest correction letter for manifest 021323642JJK must be submitted to the Department of Toxic Substances Control (DTSC). Go to https://dtsc.ca.gov/hazardous-waste-manifest-information/for more information on what needs to be included in the manifest correction letter. Please let me now if you have any questions. Thank you, Elianna Florido, REHS 5