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Mr. Ray Von Flue January 26, 2010 Page 3 of 4 Sample CS-005 was collected randomly from 5 drums of hot and cold shot bead blast into one 4 oz glass jar. Cal Science Analytical Labs analyzed this sample for total chromium, hexavalent chromium, the TCLP test and the WET test. Results of the total chromium, hexavalent chromium, TCLP test and WET test are compared to hazardous waste criteria in Table 2. Lab reports for all of these analyses are presented in Exhibit B. A comparison of sample results gathered by the County and Central Spring Inc. with hazardous waste criteria clearly shows that the bead blast waste is a non-hazardous solid waste based on the following toxicity criteria: 1. Lab results for total chromium are significantly below the TTLC hazardous waste criterion (2,500 mg/kg). 2. Hexavalent chromium makes up less than 0.005% of the total chromium concentration. Hexavalent chromium is significantly below the TTLC hazardous waste criterion (500 mg/kg). 3. The concentration of total chromium, as determined by the TCLP test, is significantly below RCRA hazardous waste criteria(5 mg/1). 4. The concentration of total chromium, as determined by the WET test, is significantly below California hazardous waste criteria(560 mg/1). 5. The concentration of hexavalent chromium, as determined by the WET test, is significantly below California hazardous waste criteria(5 mg/1). 6. The aquatic toxicity of chromium, as determined by the acute 96-hour fish bioassay test, is significantly below California hazardous waste criteria(LC50<500 mg/1). The evidence provided in this response clearly demonstrates that the bead blast waste is a non-hazardous solid waste. We respectfully request that the violations listed in the November 30, 2009 NOV be rescinded. II. FUTURE HANDLING OF BEAD BLAST WASTE In the future the bead blast waste will be labeled, handled, transported and disposed of as non-hazardous solid waste. The waste will accumulate in 55-gallon drums. The drums will be sealed and transported by Fremouw Environmental Services, Inc. to the Phillips Services Corporation (PSC) yard in Benicia, California within six days of the time it is picked up at the Central Spring facility in Stockton. The waste will then be transported to the PSC facility in Fernley, Nevada within 10 days of its arrival in Benicia. The PSC facility in Nevada will then ship the waste to its final disposition as non-hazardous solid waste at Idaho Waste System's Simco Road Regional Landfill in Elmore County Idaho. A non-hazardous manifest will accompany the waste from the Central Springs facility to its final disposition. The Simco Road Regional Landfill was permitted in 1999 and is located in the and region of southwest Idaho, which experiences less than six inches of annual precipitation. The