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Vang-Lee, Vicky [EHD] <br /> From: Meyer, Greg <Greg.Meyer@simplot.com> <br /> Sent: Thursday,January 27, 2022 9:03 AM <br /> To: Vang-Lee, Vicky [EHD] <br /> Subject: 16777 Howland Rd Notice to Abate, Record ID#CO6GVRMDI <br /> CAUTION:This email is originated from outside of the organization. Do not click links or open attachments unless you recognize the <br /> sender and know the content is safe. <br /> Vicky, <br /> As promised, I am circling back via email to clarify our notification thought process. State and Federal law cited in the <br /> CalOES guidance indicates the following <br /> State law: Handlers, any employees, authorized representatives, agent or designees of handlers shall, upon discovery, <br /> immediately report any release or threatened release of hazardous materials(Health and Safety Code §25510). <br /> Federal law: Notification to the National Response Center is required for all releases that equal or exceed federal <br /> reporting quantities: <br /> • (EPCRA) Owners and Operators to report, and <br /> • (CERCLA) Person in Charge to report <br /> As you know,we notified SJV EHD on Monday 1/24 at 4:28 pm. Given our Waste Discharge Requirements associated <br /> with the lined ponds,we notified the Regional Board (Mr. Brandon Kenny) shortly thereafter via email. <br /> Given that the spilled material was a relatively low pH material, we began to evaluate the likely reportable quantity(RQ). <br /> Per the EPA List of Lists (Consolidated List of Chemicals subject to EPCRA, CERCLA, and Section 112(r)of the Clean Air <br /> Act), a generic low pH liquid only has an RQ if it has a characteristic of corrosivity. See excerpt from the List of Lists <br /> below.The associated RQ is 100 pounds—found on page 102 of 131 of the PDF linked here. <br /> https://www.epa.gov/sites/default/files/2015- <br /> 03/documents/list of lists.pdf?Versionld=8We.OedeRCrHOOgArFv6CYKNYiH.E09. <br /> RCRA RQ NAME <br /> CODE <br /> P001 100 Unlisted hazardous wastes characteristic of ignitability <br /> UO2 100 Unlisted hazardous wastes characteristic of corrosivity <br /> D003 100 Unlisted hazardous wastes characteristic of reactivity <br /> Unlisted hazardous wastes characteristic of toxicity: <br /> A corrosive characteristic waste is defined as having a pH less than or equal to 2 based on the regulatory definition <br /> below. <br /> §261.22 Characteristic of corrosivity. <br /> (a)A solid waste exhibits the characteristic of corrosivity if a representative sample of the waste has either of the <br /> following properties: <br /> (1) It is aqueous and has a pH less than or equal to 2 or greater than or equal to 12.5, as determined by a pH meter <br /> using Method 9040C in "Test Methods for Evaluating Solid Waste, Physical/Chemical Methods," EPA Publication SW- <br /> 846, as incorporated by reference in § 260.11 of this chapter. <br /> (2) It is a liquid and corrodes steel (SAE 1020) at a rate greater than 6.35 mm (0.250 inch) per year at a test <br /> temperature of 55 °C(130°F) as determined by Method 1110A in "Test Methods for Evaluating Solid Waste, <br /> Physical/Chemical Methods," EPA Publication SW-846, and as incorporated by reference in § 260.11 of this chapter. <br /> 1 <br />