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e � The wastewater in question was generated from the cleaning of stormwater drain lines at the Site. To properly profile the waste, the water sample was collected and analyzed for total petroleum hydrocarbons (TPH), metals (CAM 17), and a fish bioassay. Analytical results, as reviewed by San Joaquin County, showed detected levels to be below hazardous levels. I PNP disputes this alleged violation. EPA Method 200.8 may be used to determine total recoverable metal concentrations in waters, wastewaters, sludge, and soil samples (See EPA Method 200.8: Determination of Trace Elements in Waters and Wastes by Inductively Coupled Plasma-Mass Spectrometry, Revision 5.4). This method is appropriate for the analysis of the wastewater generated at the Site. In addition, the results of the fish bioassay showed a 100% survival rate, indicating that the wastewater was not hazardous. Therefore, the wastewater was properly characterized and disposed of as a non-hazardous waste and Site's waste determination was not incomplete. Designated Facility Manifest Copy-#115 and #116 In the Inspection Report, San Joaquin County alleged that designated facility manifest copies for 11 manifests were not kept by the Site. The County directed the Site to locate the missing manifest copies and to file an exception report with the Department of Toxic Substances Control (DTSC) and EHD if the designated facility copy could not be located. All missing copies of the manifests listed were located and are maintained by the Site. On the day of the inspection, time was limited during the County's review of the manifests, and the Site was not provided sufficient opportunity to locate the manifest copies listed in the Inspection Report. In fact, when the inspectors left the Site, they stated they would finish their review of their manifests after they left the Site. Designated facility copies of the manifests as listed in the Inspection Report are provided in Attachment 2 of this response. Exception reports were not filed for these manifests as they were not missing. Land Disposal Determination -#117 During the inspection, San Joaquin County observed that three Land Disposal Restriction(LDR) forms were not signed. These forms have been reviewed and signed as required. Copies of the signed forms are provided in Attachment 3. Staff were reminded of the requirement to also sign LDR forms along with the associated waste manifests. Training Records-#118 According to the Inspection Report, records for Emergency Action Plan training in 2019 and Certified Used Oil Collection Center training (a tailgate meeting) were not available during the inspection. Copies of the training records for these topics are provided in Attachment 4. Page 2 of 6 Stocktonlnsp Resp_County_20200116