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Stacy Rivera [EH] • • Pagel of 3 From: Matt Zeiler [Matt.Zeiter@simsmm.com] Sent: Monday, March 19, 2012 4:09 PM To: Stacy Rivera [EH] Cc: Matt Zeiter Subject: Updates for SMM-Stockton to County of San Joaquin Importance: High Attachments: Stockton Tank Assessment-Final.pdf; Stockto InHouse UWaste Generation.pdf; EXHIBIT 29 - Collection Jar for Fines.jpg; EXHIBIT 30 -Empty Drum Storage w Date.JPG; Exhibit 31 -Used Oil Bill of Lading NO. N718462.pdf; Exhibit 32-Stockto InHouse UWaste Generation.pdf Hello Stacy, Please see the continued response for our commitment to the corrective actions observed in the Sims Metal Management Stockton Facility on 08-17-2011. In reference to our last phone conversation, we have modified the response with updated site conditions noted in red. File size will not allow me to send the other two items in this email. They will follow. 1. Operations: (7) CCR 66262.11 Failed to determine if a waste is a hazardous waste Following this observation, a small amount of metal fines were generated as a result of the grinder and were swept from the ground and accumulated into a jar. Given the volume of the fines collected, there was not sufficient material for a waste determination. Since the observation, a vacuum device has been installed to the grinder to remedy any airborne debris from its operations. Once enough volume is accumulated, a sample will be submitted to a certified laboratory. Grinding operations are minimal, and thus may take additional time to collect a sufficient sample. The collection container for the metal fines is labeled "Metal Fines — Pending Analysis 8-17-2011" Please see Exhibit 29 -Collection Jar for Metal Fines. 2. Preparedness: (11) CCR 66265.31 Facility not maintained to minimize the release of a hazardous waste Immediately following the inspection, the car crusher was cleaned of debris; Adsorbent material was spread in the car crusher's secondary containment, and concrete surface. Any oils absorbed in the area were swept clean and properly disposed of into the nearest hazardous waste drum. The facility will monitor the car crusher for any further evidence of leaks. If a leak is observed, a work order will be issued to remedy this problem immediately. Please see Exhibits 1, 2, 3 Car Crusher (photos). 3. Storage: (I8) HSC 15201(a) Stored hazardous waste on site longer than 90 days without permit or authorization At the time of inspection, the two 5 gallon buckets containing solid debris and soil were immediately placed into the proper Hazardous Waste drum. Appropriate labelling and signage were confirmed to be accurate for the drum used which is located at the accumulation site. As noted it was corrected onsite. During the inspection, it was noted that there were two black steel drums with Hazardous Waste labels dated April 29, 2011 and May 17, 2011; However, these drums were determined to be Re -Usable Adsorbent and not a waste. Refresher training with facility personnel has been completed to ensure compliance. The facility manager corrected this observation by removing the HW label. During the facility inspection, it was observed that one steel drum containing PCB ballasts had expired the accumulation date. The steel drum of PCB ballasts were transported by Veolia ES Technical Solutions on 9/01/2011. Please see Exhibit 4 -PCB Manifest tracking number 000511944VE5. A red steel drum of Used Oil was observed in the appliance recycling 3/26/2012