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Cc:Suszycki, Michael [EHD] <msuszycki@sjgov.org>; Craig Feaga <cfeaga@lamartoolanddie.com>; Brian Kolsters <br /> <bkolsters@ lama rtoolanddie.com>; Nick Snoreen <nsnoreen@lamartoolanddie.com>; Robert Jackson <br /> <rjackson@lamartoolanddie.com>; Donald Ning<dning@keramida.com> <br /> Subject: RE: PR0522736-4101 Arch Rd. - PBR <br /> Good afternoon Andrew, <br /> Thank you for sending us a response. To answer your questions: <br /> 1. You are correct,treated non-hazardous waste streams are not regulated by PBR. <br /> 2. Although this is fine, the question also has to be asked if all waste streams are consistent. For <br /> example, if oily waste is added and the concentration varies. <br /> I also recommend speaking with the Modesto facility. I know this has been brought up before, but <br /> they appear to have PBR for the same waste streams. <br /> Respectfully, <br /> John Alaniz <br /> From:Andrew Guglielmo<aguglielmo@keramida.com> <br /> Sent: Monday,April 20, 2026 3:01 PM <br /> To:Alaniz,John [EHD] <jalanizl@sjgov.org>; Sammons, Lynsey [EHD] <Isammons@sjgov.org> <br /> Cc:Suszycki, Michael [EHD] <msuszycki@sjgov.org>; Craig Feaga <cfeaga@lamartoolanddie.com>; Brian Kolsters <br /> <bkolsters@ lama rtoolanddie.com>; Nick Snoreen <nsnoreen@lamartoolanddie.com>; Robert Jackson <br /> <rjackson@lamartoolanddie.com>; Donald Ning<dning@keramida.com> <br /> Subject: Re: PR0522736-4101 Arch Rd. - PBR <br /> Hi John, I believe that clears things up a little more. However, and unfortunately for you,we have more questions <br /> than answers now. I hope you can help us address the following so that we get this right. <br /> 1. We are planning to sample each waste stream at the point of generation. <br /> a. If we identify and evaporate only non-hazardous waste,then the PBR requirements would be void, <br /> correct? <br /> 2. If one of the waste streams return as non-RCRA or RCRA, it will not go to the evaporator and be managed <br /> accordinly. <br /> 3. If the coolant waste returns as non-RCRA,we will proceed with the PBR requirements. <br /> Please let us know what else we owe you to return to compliance for the remaining compliance items. I believe <br /> Lyndsy recommended we need to add hazardous materials to the annual training.Attached is the updated training <br /> slides. <br /> Best, <br /> Andrew Guglielmo, MS, QSP, QSD/P <br /> Senior Project Manager, CA Compliance Services <br /> 2 <br />