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J.R.SIMPLOT COMPANY / 16777 HOWLAND ROAD / P.O.BOX 198 <br /> Simplot LATHROP,CALIFORNIA 95330 / (209)858-2511 <br /> September 22, 2022 <br /> Sent via email to: fernest@sjgov.org <br /> San Joaquin County Environmental Health <br /> Attn: Frederick Ernest <br /> 1868 E Hazelton Ave. <br /> Stockton, CA 95205 <br /> Subject: Hazardous Waste Inspection and Return to Compliance Certification <br /> On August 23, 2022, the San Joaquin County Environmental Health Department (EHD) <br /> conducted an inspection at the J.R. Simplot Company (Simplot) fertilizer manufacturing facility <br /> located at 16777 Howland Rd., in Lathrop, CA. On the following day, the EHD issued Simplot <br /> the official inspection report which requires correction of violations and/or disputes of any <br /> violations within 30 days using the Corrective Action Statement. The Corrective Action <br /> Statement is attached and certified, however the discussion for each item are detailed in this <br /> letter. <br /> Violation for Item #102 — Failed to determine if a waste is a hazardous waste <br /> This violation has been corrected. <br /> 1. Two 5-gallon containers of unknown waste stored east of the auto shop. <br /> The waste is a clear liquid with no noticeable odor. The pH of the waste is 7 and could <br /> not be ignited in the on-site laboratory. Simplot is working with ACT Environmental to <br /> assist in characterizing the waste for proper disposal. <br /> 2. Acidic lab waste being neutralized before discharge down the sink. <br /> Laboratory procedures have been evaluated to identify processes that utilize reagents. <br /> Based on SDS review, two procedures use reagents (silver sulfate, ammonium <br /> metavanadate and ammonium molybdate) that could cause waste generated to exhibit <br /> characteristics of a hazardous waste. Therefore, Simplot has established a satellite <br /> waste accumulation area in the laboratory to accumulate the waste generated through <br /> the laboratory processes utilizing these reagents. Simplot is presumptively managing <br /> this waste as a hazardous waste until lab results are received to determine if the wastes <br /> exhibit characteristics of a hazardous waste or not. If any analytical methods result in a <br /> hazardous waste, Simplot will update the lab procedure to reflect hazardous waste <br /> handling and disposal requirements. If the analytical methods do not result in a waste <br /> with hazardous characteristics, Simplot will use the neutralization procedures for proper <br /> management. <br /> Final waste determinations will be completed by October 15, 2022 and proper disposal, <br /> will be completed as quickly as possible. If off-site disposal is required, the disposal is <br /> expected to occur no later than November 18, 2022. <br /> Page 1 of 4 <br />