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dO'jfieAAne <br /> March 18,2022 <br /> i <br /> Electronic Mail Only $ P x <br /> Garrett Backus <br /> Lead Sr. REHS, CUPA Programs <br /> San Joaquin County Environmental Health Dept. <br /> 1868 E. Hazelton Avenue <br /> Stockton, CA 95205 <br /> E-Mail: gbackus(aDsigov.org <br /> RE: Inspection Report Concerning the Former Marley Cooling Tower Company Inc. <br /> Facility,200 N Wagner Ave., Stockton,CA; CERS ID 10182275 <br /> Dear Mr. Backus: <br /> This letter, and the attachments, is a supplemental response to the San Joaquin County <br /> Environmental Health Department's (SJCEHD)Large Quantity Hazardous Waste Generator <br /> Compliance Review Report, dated March 3,2022 ("Inspection Report"),regarding the <br /> February 18,2022 inspection of the Former Marley Cooling Tower Company(MCTC) <br /> facility(the"Facility"),located at 200 N. Wagner Ave, Stockton, CA. As confirmed in your <br /> March 3,2022 email, SPX Cooling Technologies,Inc. (SPX)already submitted <br /> documentation correcting 12 of the 14 alleged violations set forth in the Inspection Report, <br /> with only Violation Nos. 102 (failed to determine if a waste is a hazardous waste)and 502 <br /> (failed to comply with new hazardous waste tank system assessment requirements)pending. <br /> Alleged Violation No. 102 <br /> Alleged Violation No. 102 regards the observation of"[o]ne unlabeled large tank and <br /> attached piping of waste water feeds to the filter press."This tank, which is part of the <br /> groundwater extraction treatment system(GETS), is labeled as the"Sludge Tank". This tank <br /> contains mixed solids and water undergoing treatment,where eventually the resulting solids <br /> (the filter cake)will be discarded as a waste manifested for off-site disposal and the liquids, <br /> after further treatment,will be discharged in compliance with a NPDES permit. Under 22 <br /> CCR§ 66261(d),listed or characteristic hazardous sludge is considered a waste at certain <br /> times in the lifecycle(when it is land-applied,burned for energy recovery,reclaimed, or <br /> accumulated speculatively). Here, GHD sampled the tank on March 2,2022 and analyzed for <br /> constituents of concern, including chromium. The sample revealed a chromium concentration <br /> of 65 mg/kg,well below the California Non-Hazardous Total Threshold Limit Concentration <br /> (TTLC) of 2,500 mg/kg. Those lab results are attached to the Corrective Action Statement. <br /> In sum,the tank was confirmed to be non-hazardous and does not need a"hazardous"label, <br /> regardless of whether the contents are considered a waste. <br /> 4857-6390-4275.8 <br /> SPX Corporation 6325 Ardrey Kell Rd, Suite 400.Charlotte, NC 28277 www.spx.com <br />