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The contents in the 9 bulk poly tanks were identified by facility personnel as liquid <br /> fertilizer product. The tanks, which were originally in the fertilizer tank farm containment, <br /> had been pumped out prior to being moved to the Simplot-leased parcel in January. The <br /> pumping could not remove all of the product, leaving a small heel of material inside the <br /> tank. The heel in the tank is not discarded material, but is a product that can be used <br /> directly as a fertilizer in its current state without any chemical or physical modifications. <br /> The plan is to transfer out the remaining product, and once the tank is clean, cut up the <br /> tank for recycle or disposal per Federal and State rules. If you need additional <br /> documentation for these fertilizer products, such as safety data sheets or labels, please <br /> let us know and we will provide for you. <br /> In regards to violation #3010, concerning management of tanks: <br /> • For item #1, you are requesting submittal of proof of correction for failure to notify <br /> your department prior to initiating cleaning of the diesel tank. The tank cleaning <br /> occurred on January 15th, which predates the inspection on February 261H <br /> Please inform what is needed to provide proof of correction for this item. <br /> • For item #2, we have requested the contractor who cleaned the diesel tank, <br /> Starbuck Construction, to complete the Hazardous Waste Tank Closure <br /> Certification form, and to mail or fax a copy to your attention prior to April 41H <br /> Starbuck Construction has already provided a Certification of Triple Rinsing for <br /> the tank, which is attached to this letter. <br /> • For item #3, tank-32 and the 9 poly tanks listed in your report contained liquid <br /> fertilizer, which is a product and not a hazardous waste. Per 22 CCR 67383.1(d), <br /> the requirements of this chapter do not apply to these tanks because the tanks <br /> are not a hazardous waste per chapter 11 of 22 CCR. We ask that you vacate <br /> this violation. <br /> If you have any questions, please call be at (208) 867-2627 or email me at <br /> 0ohn.pallen(a)simplot.com. <br /> Sincerely, REINED <br /> MAR 20" 2016 <br /> ENVIRONMENTAL <br /> J.R. SIMPLOT COMPANY HEALTH DEPARTMENT <br /> John J. Pallen, CHMM <br /> EHS Manager <br /> cc. S. Woods <br /> P. Simpson <br /> P. Derig <br /> B. Ackerman <br /> � d. i. �. a .r. i .. i � a � r. a a a ,r a � � a + a a i .► .. a .a. t o ., t a a .► t o .. t .r .b y 1 a i .r t t i i a ♦. + .r .. + + � <br /> iiiiiiiiA <br />