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corrected. On December 26, 1996, 1 conducted a routine hazardous waste inspection at Valley Industries. Fred Baumbach was the representative from Valley Industries who accompanied me during the inspection. During the inspection I noted that a waste stream referred to as "wheelabrator waste" was previously managed as a hazardous waste, but was currently being managed as a nonhazardous waste, scrap metal. I asked Mr. Baumbach why this waste was no longer being managed as a hazardous waste. He explained their metal recycler told him they could handle this waste stream. I noted the management of the wheelabrator waste as a violation and documented it as with several other violations of the California Health and Safety Code, and Title 22, California Code of Regulation, on the Notice to Comply issued to Baumbach, on December 26, 1996 . On December 27, 1996, 1 faxed Baumbach sections 25143.10, 25160 (b) (3) and 25244.19 of the California Health and Safety Code. I also included the phone numbers of where he could call to get copies of Title 22, and the California Health and Safety Code. On January 6, 1996, 1 faxed to Baumbach, section 66262.42 of Title 22, CCR. On March 6, 1997, 1 received a Certification of Return to Compliance for the violations noted on the notice to comply issued to Valley Industries on December 26, 1996. A letter was attached to the certification statement explaining what was done, or was planned to be done to correct the violations. On March 25, 1997, 1 sent a memo to Baumbach identifying the corrections that needed to be made regarding the December 26, 1996, notice to comply. I did not receive a response to this memo. On November 14, 1997, Kasey Foley and I conducted a routine hazardous waste inspection at Valley Industries. During the inspection I followed up on the items noted on the memo I sent to Baumbach on March 25, 1997. When I asked Baumbach about the analysis of the waste stream referred to as "wheelabrator waste", he gave me analytical results for Total Threshold Limit Concentration (TTLC), of three waste streams that were analyzed on June 18, 1997. The results showed that the waste stream referred to as "polishing bag house fines" exceeded the TTLC of 2500mg/kg value for copper. Baumbach also gave me a copy of analytical results for two other waste streams referred to as "FAB Center Bag House Fines", and "Wheelabrator Bag House Fines". The analysis showed that the results were within the Soluble Threshold Limit Concentration (STLC), and the TTLC. Further analytical testing was required to determine if these wastes were hazardous wastes. Baumbach also gave me a copy 4