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run at this point. We are working with the metals, pH and VOC data. We fully intend to provide the waste/hazardous <br />waste disposal records for the impacted material to EHD when final disposition has been determined and executed. <br />Please let me know if you have any further questions at this time. <br />Sincerely, <br />Greg <br />Greg Meyer <br />Environmental Manager — Lathrop, CA <br />J.R. Simplot Company <br />Tel. (209) 858-6470 I Cell. (209) 401-9845 <br />Greq.MeverASimplot.com <br />Simplot <br />AGRIBUSINESS <br />From: Meyer, Greg <br />Sent: Thursday, February 3, 2022 10:50 AM <br />To: yang-Lee, Vicky [EHD] <vvang-lee@sigov.org> <br />Subject: RE: [EXTERNAL] RE: 16777 Howland Rd Notice to Abate, Record ID# CO6GVRMDI <br />Vicky, <br />Regarding the nature of our lined pond process water and determining its potential Non-RCRA toxicity as a result of a <br />spill, as I was indicating during your field visit, one of the primary building blocks of the fertilizers we manufacture at the <br />Lathrop Plant is Ammonium Sulfate (NPK: 21-0-0). Historical sampling of the process water in the North Pond (the <br />source of our spill) indicates elevated Ammonia as nitrogen, Nitrate as nitrogen, Sulfate, and TDS. Concentrations of <br />these analytes are generally higher in the summer and lower in the winter. These constituents are not listed in Appendix <br />X (22 CCR Div. 4.5, Ch. 11, App. X) as chemicals that create a presumption that a waste is hazardous waste. <br />While we do expect to find trace metals in the process water due to the potential for trace metal content from raw <br />materials used in our processes, there is no further introduction of metals in our processes. Since the water is recycled in <br />our process, we do not consider it a waste and as such do not typically conduct waste analysis (such as STLC or TCLP) on <br />the process water. However, in the rare cases of a process water spill, we have characterized the waste which is <br />composed of a mixture of the process water and backfill/soil materials using a total metals analysis confirming our <br />generator knowledge regarding toxicity from metals in the process water. As you can see from the last process water <br />spill (May 2021; see attached lab analysis), we affirmed only trace metal concentrations from process water. None of the <br />total metals results exceeded "20X the TCLP limit" for RCRA hazardous waste characterization (D Code listing); therefore, <br />TCLP analysis, which would determine if a toxicity characteristic for the RCRA 8 metals was applicable, was not <br />conducted. Similarly, the results from a MC analysis are used to determine if an STLC test is required. Using the "10x <br />rule" (based on the 10:1 extractant to sample ratio), if the result of a particular compound is 10X or higher than its STLC <br />limit, that compound will require STLC analysis. Note that in the attached laboratory report, no STLC analyses were <br />"triggered" or recommended by the lab (see results table footnotes). <br />The May 2021 analytical results also include fixed lab pH and VOC results. The pH value is in line with field pH values I <br />provided previously. The VOC analysis was requested by the disposal facility. <br />Please let me know if you have any further questions. <br />Greg <br />Greg Meyer <br />Environmental Manager — Lathrop, CA <br />4