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(209)368-8881 1313 S.Stmkion Street n Lodi,CA 95240 U u E^E§-Vv-ED AU(; y 5 2005 INDUSTRIES ENVIR0ivMENT PERMIT/SERA EFSTN Aug 10. 2005 San Joaquin County Environmental Health Department 304 East Weber Ave,3 rd floor Stockton, CA 95202-2708 ATTN: Kasey Foley REHS&Dennis Catanyag REHS SUB: Class I Violation abatement progress statement Dear Kasey and Dennis: On July 11, 2005, we signed off on the alleged Class I Violation involving the disposal or the caused disposal of hazardous waste to an unauthorized point. This material is the displaced metal removed from low carbon steel plate when profile cutting is done with a plasma and or laser plate cutting process. In efforts to define the proper choice of disposal of this waste stream we have employed the skills and resource contacts of our hazardous waste management Service provider along with a representative from our waste management service consultant firm, CDMS. The first point to address is the classification of the material. Will the material be regulated as a hazardous waste or not. We took the time to test samples of the solidified metal removed form the cutting processes. If the materials in question are not RCRA regulated, we have a much different playing filed to work with. Just this morning I was provided with the results on the tests for the two process samples. We first had a TTLC done on each sample,testing for the presence of the eight RCRA metals. On the two samples,we found measurable amounts of Arsenic and Chromium. We than had a TCLP done for those metals showing measurable values in the TTLC testing. The TCLP results came back Nan Detectable for both metals in both samples. From this information we can simplify the equation by excluding the material from being a RCRA regulated waste. We still need to understand how the state will define this material. We are still in pursuit of obtaining a clear definition of the material form the Waste Identification and Recycling Section of the Hazardous Waste Management Program. We have sent a letter to this section requesting a clear definition of the material we are causing from our process and a reasoning as to it's being able to be classed as a scrap metal or not. Please refer to the attached copy of the letter to the Waste Identification and Recycling Section dated August 3, 2005. We have received a response form our request letter. Charles Corcoran, Chief of this section, through a voice conversation with Jim Carro, our consultant with Chemical Data Management Services, has informed us that he will need further information before he can provide an official response to the letter. To provide him with the additional materials and understanding of all views, a four way conference call has been proposed as soon as it cam be scheduled. With the opportunity to collective discuss the case, all parties can present their findings and opinions first hand.