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Page 2 of 3 <br />area with an accumulation start Is of January 11, 2011. The Used Oil drum •evacuated by Asbury Environmental <br />Services on March 28, 2011. Please see Exhibit 31 - Bill of Lading NO. N718462. As this drum is routinely evacuated during <br />pickups, we have maintained current dates. <br />4. Containers: (30) CCR 66261.7(f) An empty HW or Haz Mat container (larger than 5 gallons) was not marked with the date <br />it was emptied and/or not managed within one year of being emptied. <br />An empty 55 gallon drum during the inspection was labelled indicating the drum is "Empty". "Empty" drum labels also <br />include the day they were emptied. Please see Exhibit 30 -Empty Drum Storage w Date. <br />5. Hazardous Waste Tanks: (32) CCR 66265.191 Failed to comply with new HW Tank Assessment requirements <br />Prior to the inspection, SMM had determined a tank assessment was needed for the waste oil tank. That inspection was <br />scheduled for 8-22-11. SMM has received a preliminary report and are making the necessary modifications to the tank. A <br />final inspection of the waste tank has been scheduled so the PE may sign off that the work had been completed. <br />However, given the "Return to Compliance" date, a final copy is not yet available. Once the final Tank Assessment has <br />been approved, SMM will forward a copy to you at the address provided above. Please see attached: Stockton Tank <br />Assessment -Final <br />6. Universal Waste: (85) CCR 66273.39 Failed to keep records of each shipment of universal waste according to this section <br />As a Certified Appliance Recycler, SMM collects and disposes Universal Waste from a number of suppliers of recyclable <br />metals. Also, as SMM generates universal waste, its universal waste is accumulated with the universal waste that is <br />collected from its suppliers. As such, a Bill of Lading or a manifest is created for the disposal of all universal waste <br />shipments. Thus, SMM believes it has, and will continue to keep records of each shipment of universal waste. Please see <br />Exhibit 32. <br />Kind Regards, <br />Matt Zeiter <br />West Region Environmental Supervisor <br />Sims Metal Management <br />600 South 4th Street <br />Richmond, CA 94804 <br />United States <br />Office: 510-412-5300 <br />Direct: 510-412-5304 <br />Cellular: 510-715-7569 <br />Facsimile: 510-412-5423 <br />matt..zeiter@Simsmm.com <br />w .simsmm.com <br />NYSE:SMS ASX: SGM <br />Sims <br />Vv%METAL <br />MANAGEMENT <br />RIGHT. NOW. <br />This transmission may contain information that is privileged, confidential, proprietary, and exempt from disclosure <br />3/26/2012 <br />