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amazon April 1, 2020 CONFIDENTIAL Delivered by Email Lydia Baker Environmental Health Department of San Joaquin County 1868 East Hazelton Avenue Stockton, California 95205 Email: Ibakerimsigov or¢ RE: In Response to RCRA Large Quantity Hazardous Waste Generator Inspection Report Dear Lydia, Amazon is responding to the above -referenced RCRA Large Quantity Hazardous Waste Generator Inspection Report (dated March 3, 2020), in connection with your onsite Inspection of the Amazon facility of SMF3 located at 3923 South B Street, Stockton, California 95207 (the "Facility"), Alleged Violation: Item# 102 CCR 66262.11 Failed to determine if a waste is a hazardous waste. The facility must immediately stop disposing of the items in the fertilizer & grass seed drums as non -hazardous waste. The facility must immediately stop recycling metal fines. The facility must make a complete hazardous waste determination for each waste and manage it according to Title 22 CCR. The facility must demonstrate current storage and labeling for wastes determined to be hazardous wastes. • Facility's Response: Amazon has stopped the recycling of metal fines. A sample of the metal fines was collected by Stericyle on Thursday, March 25, 2020 and the sample will be tested using the Toxic Characteristic Leaching Procedure and Bioassay Test to make a hazardous waste determination. Once Amazon receives the results, we will determine hazardous waste applicability and will label and manage the waste appropriately. Amazon has stopped disposing of fertilizer and grass seed as non -hazardous waste. The waste profile has been updated and labeling of the drum has been corrected to document it will be handled and disposed as hazardous waste. Please see updated profile and picture labeled drum (Attachment A). 2. Alleged Violation: Violation Item# 105 CCR 66262.40(b), 66262.41 failed to submit Biennial Report to DTSC or retain onsite for three years. The facility must immediately prepare and submit the required Biennial Reports to the California Department of Toxics Control website. • Facility's Response: Please see 2019 Biennial Hazardous Waste Report (Attachment B). This report was filed through Federal EPA's RCRA Info. System. 3. Alleged Violation: Item# 112 CCR 66262.20 Failed to prepare manifests for transportation of hazardous waste. The facility must provide a corrective action statement and any supporting documentation from this facility for off-site transfer, treatment, storage or disposal. • Facility's Response: Please see Stericycle's response to correcting the manifesting of white goods and gel packs (Attachment C).