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Tuff Boy Sales, Inc. 5151 E. Almondwood Dr. Manteca, CA 95337 Phone: (209) 239-1361 • Fax: (209) 239-7086 September 27, 2013 _ Thuy Tran, REHS San Joaquin County 01� Environmental Health Dept. SEP 3® 2 1868 E. Hazelton Ave. L��LV Stockton, CA 95202 ��M E�o��5 Dear Ms Tran, On September 04, 2013, you visited our facility at 5151 E. Almondwood Dr. for the purpose of providing feedback to Tuff Boy relating to a Cam 17 analytical test report that indicated zinc levels exceeding allowable limits. At the time of your visit, you stated that Tuff Boy had been mistaken in the method that they interpreted the Cam 17 test results that was conducted by Castle Analytical Laboratory. Specifically, you pointed out that the test results showed a zinc content of 6500 mg/kg, which exceeded the California limit for disposed waste. You also stated that the limit for zinc is limited to 5000 mg/kg. In response, Tuff Boy made it clear that they had acted in good faith by taking samples and sending them off to the lab for the purpose of ensuring all waste materials were disposed of properly. In fact, Tuff Boy had Castle Analytical perform tests for both metals and flammability to best ensure that the waste materials were disposed of properly. Further, Tuff Boy responded that Castle Analytical had included specific language in the test results that indicated that all substances tested in the Cam17 test study were within the required control limits (see attached).. The conversation continued with you explaining that although Castle Analytical had written language into the body of the test report that stated all metals tested were within the control limits, the burden remains withTuff Boy to further inspect all the data present in the report. Tuff Boy acknowledged your comments and agreed to work with its paint supplier and Castle Analytical to ensure that all future waste materials are clearly evaluated for proper disposal. In fact, Tuff Boy plans to seek a third party expert to further evaluate the Lab's test results and ultimate conclusions prior to making any in house decision relating to disposal. You then informed us that we would need to submit a written explanation of how future paint dust waste would be managed, handled, stored and disposed of by September 30, 2013. As a result, I have prepared the following attachment detailing our efforts in addressing your concerns. 1