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Complaint Investigation Summary Report #: 5105 COMPLAINT ID: C00054015 Site Location: 9999 S AUSTIN RD Activity Summary Activity Date Recorded by 9:54 am, received an email from Rob Ashe rashe@JLPrecision.com (Bay Area Metal Finishing Facility (MSF) Manager), with cc to Terry McGuinness TerryM@AIICleanHaz.com and Jason Torres jtorres@mfinish.com, with an attached letter signed by Robert Ashe asking for transportation of drums back to 1325 El Pinal Road, Stockton indicating that all material will be reused as product into the automated process line. Sent a response email back asking to make an inventory of every chemical and its quantity that will be received from Forward Landfill. Called Jason Torres (Chad- environmental contact also present during the call), let him know that I wanted to make it clear that I am not approving the transportation of hazardous waste without a manifest and their facility may be issued a violation for it-and that EHD is not approving or giving permission for transportation of containers back as product and the received letter signed by Rob Ashe only served as the notice of their intent to the EHD. Jason indicated that he understood EHD's position. Also, discussed with Terry McGuinnes letting him know that EHD is not approving the transportation of the waste back to the facility and the letter was just the notification of what facility is going to do, reiterated the violation applicability for the transportation of the hazardous waste without a manifest to an unauthorized point, told him that he is aware of this before he removes waste offsite. Terry indicated that he understood. Sent an email to the following prior to All Clean leaving the site to document EHD's position: Rob Ashe <rashe@JLPrecision.com>; Terry McGuinness <TerryM@AIICleanHaz.com>; Jason Torres <jtorres@mfinish.com>; Presto, Carol [END] <cpresto@sjgov.org>; Elianna (eflorido@sjgov.org); Backus, Garrett [EHD] gbackus@sjgov.org: "Per my discussion with Jason Torres (with your facility) and Terry McGuinez (with All Clean), it is a violation to transport hazardous waste without a hazardous waste manifest, and the letter that we received from MSF has served as a notification to the EHD of your intent to transport the containers as a product for re use (without a hazardous waste manifest) from Forward Landfill to your facility at 1325 El Pinal Road, Stockton, CA and not the approval of the EHD of transportation of the hazardous waste without a hazardous waste manifest." The crushed drums, excavated soil, and rags used to wipe drums down, were all placed in one overpack 85-gallon container and labeled as hazardous waste to be left onsite at Forward Landfill for disposal at a later date. Ruben indicated that he had concerns with leaving the waste onsite, told him that as the property owner he can tell the responsible party to not leave the waste and to manifest it out, he said the will discuss it with his people. In the end Ruben with Forward Landfill had no objections of leaving the overpack 85-gallon drum onsite pending disposal. All 55-gallon containers and 5-gallon containers (with the exception of the one 85-gallon overpack container labeled as hazardous waste) were loaded onto the All Clean truck to be transported back to 1325 El Pinal Road; containers left the site around 11:30 am. 07/09/2021 Provided an update to M. Henry (enforcement coordinator). Provided an update (personal meeting) to M. Naidu (assistant EHD director) and J. Kang (EHD director). Emailed the letter received from Rob Ashe [mailto:rashe@JLPrecision.corn] along with my response to M. Nissin (program coordinator) and M. Naidu (assistant director). Updated complaint narratives. Reviewed inspection pictures. Created Prop 65. Called Jason Torres 209-990-9395, asked if facility inventoried the liquids that came back from Forward Landfill, he indicated that they will be doing that on Monday. Let him know we will follow up with him on monday concerning the inventory. MANZO 5105.rpt Page 6 of 9