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Thank you for providing your Return to Compliance documents on time. I have closed items 304 and 403. Remaining open are 102, 605, and 608. For item 102, you wrote "This violation was not on the field inspection report....." The initial report I went over with you on 11/26/19 was only a checklist. On 12/03/19, 1 emailed the full inspection report explaining each item needing correction. You will note that I removed violations, 115 and 601 , from the initial checklist, pertaining to the lead acid battery found at the yard and the open drum of oily solids. However, I consulted with my supervisor and he asked me to remove those and issue 102 for failure to determine a waste is a hazardous waste. On the report under item 102 is: OBSERVATIONS: One 55 gallon drum containing oily cardboard, oily rag, oily container, and an aerosol was stored outside the storage shed without a lid or determination being made. One lead acid battery was observed on top of a five gallon container with no determination being made. REGULATION GUIDANCE: Any person who generates a waste shall determine if the waste is a hazardous waste as specified in Title 22 California Code of Regulations (CCR). There are wastes that are listed as hazardous wastes. There are wastes that exhibit one or more of the hazardous waste characteristics: toxic, corrosive, reactive or ignitable. CORRECTIVE ACTION: Immediately make a hazardous waste determination for each waste , and manage it according to Title 22 CCR. Use Safety Data Sheets (SDS), waste sampling and test results or other knowledge to support your hazardous waste determination. Waste testing must be done using methods specified in Title 22 CCR including sections 66261.20-24. Submit a statement and supporting documentation with your hazardous waste determination. Demonstrate current storage and labeling for wastes determined to be hazardous wastes. Provide disposal records for wastes determined to be hazardous wastes and stored longer than the number of days specified in Title 22 CCR for your hazardous waste generator status. So Bob, I will need two statements, one for the open drum of oily waste and aerosol and another statement for the lead acid battery. First statement should include how you will be managing the open drum. If it is determined to be hazardous waste and will be disposed of, I will need a disposal record showing quantity, how it was transported and by who and where it will be taken to (just like the information on a consolidated manifest). Or, if it is within the 180 days and an accumulation date is known, label with hazardous waste label and add the 6 items of required information and a lid for the drum. If it is deemed non-hazardous, you will need to provide documentation such as analytical lab testing results showing material is non-hazardous. Second statement 5