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• Page 2 September 2,2004 Analytical results of the 31 samples referred to above is include for your review. 2. SJCEHD Question: Were samples taken from the sludge and waste water separately prior to making the determination to handle these waste streams as non-hazardous?(If so,please provide a copy to this department.) Response: SafetyaCleen did not separate the waste water and sludge prior to sampling. Safety-Kleen used the EPA reference guide, Sampling Drums "Sampler & Sampling Procedure for Hazardous Waste Streams" EPA 600/2-80-018; Method US EPA SW 846, CH 9, RCRA, Sampling Draft Technical Guidance Planning Implementation and Assessment, July 1999 and its updates. A COLIWASA sampler was used to collect the oil water separator samples. 3. SJCEHD Question: The fact sheet that you provide your customer states that, For vacuum services waste from industrial customers (non-automotive), Safety-Kleen uses a thorough 5-point RCRA/-SCA test. Please clarify how the automotive waste source from the above referenced sites can be used in your vacuum services program when your fact sheet states otherwise. Response: As stated above SafetyXleen makes a distinction between industrial non-automotive customers and automotive customers.The fact sheet that you refer to informs customers that if they are an industrial non-automotive customer the required 5-point RCRAffSCA testing will continue to be used in the appropriate characterization of the waste material. Accordingly, the analytical results of industrial non- automotive customers are not applied to automotive customers. The analytical results of the 31 samples taken are applied to the characterization of the automotive customers and are attached for your review. 4. SJCEHD Question: Please explain your routine sampling process performed prior to disposal. Response: As mentioned in the response to question two above, Safety-Kleen typically uses COLIWASA samplers to obtain samples of industrial vacuum waste. Samples are taken so as to be representative of the waste generated and would include all possible phases (e.g. oil, water, sludge, etc). Collected samples are then sent to our corporate laboratory for analysis. Also as mentioned in the response to the first question above, sampling and analysis for the 5-point RCRA/TSCA parameters is required for all industrial based vacuum waste. Only those wastes coming from automotive Oil Water Separator Waste Services are exempt from the required sampling and analysis. This exemption for analysis is based on the generators knowledge of the material, on the consistency of the waste stream, Safety-ICleen knowledge of the waste material, and the data evaluated in January of this year.