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Complaint Investigation Summary Report #: 5105 <br />COMPLAINT ID: C00053079 Site Location: 4863 E CARPENTER RD <br />Activity Summary <br />Activity Date Recorded by <br />02/08/2021 Reviewed confirmation soil sample results received on 2/5/2021 from John Pallen. FLORIDO <br />The sample results are as follows: <br />Sample 1 = 0.91 mg/kg Glyphosate <br />Sample 2 = 18 mg/kg Glyphosate <br />Sample 3 = 0.44 mg/kg Glyphosate <br />Reviewed 40 CFR 180.364 - Glyphosate; tolerances for residues. Reviewed US <br />EPA's R.E.D Facts for glyphosate. It was determined that the sample result's max <br />detection of glyphosate of 18 mg/kg does not warrant further excavation, <br />considering canola's seed allowable glyphosate residue is 20 ppm, according to <br />40 CFR 180.364 - Glyphosate; tolerances for residues. This determination also <br />considers glyphosate's relatively low oral and dermal acute toxicity to humans and <br />glyphosate's minimal effect on birds, mammals, fish and invertebrates, according <br />to the US EPA's R.E.D Facts document for glyphosate. <br />Emailed John Pallen notifying him that based on the sample results, 40 CFR <br />180.364 - Glyphosate; tolerances for residues, and US EPA's R.E.D Facts <br />document for glyphosate, no further excavation is needed. <br />02/08/2021 Emailed Elena Manzo, Ld Sr REHS, the first and second soil sample confirmation FLORIDO <br />soil results, and my photo log of the second samples being taken, for her review. <br />02/08/2021 Further review of 40 CFR 180.364 - Glyphosate; tolerances for residues, and US FLORIDO <br />EPA's R.E.D Facts for glyphosate. <br />02/09/2021 Received a call from John Pallen who asked why the facility was billed for this spill, FLORIDO <br />since he did not request EHD's services but was only notifying us of the spill as <br />required by regulation. Explained to John that EHD has the authority to oversee <br />and recover our costs for oversight of hazardous spill clean-ups, according to <br />regulations. Emailed John EHD's Spill Response Authority Summary, including <br />California Health & Safety Code sections 25187.1 and 25187.2. <br />02/18/2021 Emailed John Pallen asking him if he has made a hazardous waste determination <br />for the waste generated from this spill clean-up and if he is having samples of the <br />waste analyzed. <br />02/22/2021 Reviewed emails received from John Pallen on 2/18/2020 stating he is in the <br />process of weighing the waste containers and getting a cost for disposal at <br />Kettleman, he will provide the numbers as soon as he receives them, and the <br />waste will be disposed as hazardous waste. <br />FLORIDO <br />FLORIDO <br />51 05. rpt <br /> Page 6 of 8