WASTE MANAGEMENT

February 7, 2017

CERTIFIED MAIL (70 1135000003 1588 7076)

Ryan Batty Department of Toxic Substances Control 8800 Cal Center Drive Sacramento, California 95826-3268

WASTE MANAGEMENT

35251 Old Skyline Road P.O. Box 471 Kettleman City, CA 93239

REQUEST FOR A RESPONSE EXTENSION FOR THE NOTICE OF DEFICIENCY FOR THE PERMIT RENEWAL APPLICATION FOR THE CHEMICAL WASTE MANAGEMENT, INC., KETTLEMAN HILLS FACILITY HAZARDOUS WASTE FACILITY, 35251 OLD SKYLINE ROAD, KETTLEMAN CITY, KINGS COUNTY, CALIFORNIA, 93239, ENVIRONMENTAL PROTECTION AGENCY INDENTIFICATION NUMBER: CAT000646117

Dear Mr. Batty:

On November 18, 2016, the Department of Toxic Substances Control (DTSC) issued a Notice of Deficiency (NOD) in regards to the revised Hazardous Waste Facility Permit Renewal Application (Revised Application) dated May 15, 2013. The November 18, 2016, NOD included three (3) General Comments, thirty-nine (39) Specific Comments, a memorandum from the DTSC's Geological Services Branch, dated August 14, 2015, a memorandum from the DTSC's Human and Ecological Risk Office, dated January 14, 2016, and a memorandum from the DTSC's Permitting Division, dated October 26, 2016 (cover letter) and September 15, 2015 (memorandum). The NOD specified a required response date by February 15, 2017.

Chemical Waste Management, Inc. - Kettleman Hills Facility (KHF) has completed its review of the Revised Application NOD issued by the DTSC on November 18, 2016. KHF has also participated in discussions with DTSC regarding the NOD on December 12, 2016, in Sacramento at the DTSC's Offices, again on January 12, 2017, in Kings County at the Kettleman Hills Facility and again on January 26, 2017, via a conference call. KHF continues to openly communicate with DTSC its desire to renew its Hazardous Waste Facility Permit and appreciates DTSC's cooperation in achieving this goal.

Pursuant to the required responses listed in the NOD, and the direction given by the DTSC during the meetings since the issuance of the NOD, KHF respectfully requests a response time extension, with a new due date of August 15, 2017. KHF has attached a Submittal Timeline Forecast in order for DTSC to schedule their various subject matter experts to review the draft submittals. The timeline outlines the required tasks and establishes a deliverable date.

From everyday collection to environmental protection, Think Green~ Think Waste Management.

@ Printed on 100% post-consumer recycled paper_

WASTE MANAGEMENT

February 7, 2017 DTSC: Request for Response Extension for Notice of Deficiency for Permit Renewal Application for CWMI Kettleman Hills Page 2

If you have any questions or need additional information, please contact me at (559) 386-6151.

Sincerely, Chemical Waste Management, Inc.

~U Reyna Verdin Environmental Manager

Attachment

cc: Ms. Frances Wicher Waste Management Division (WST-4) US Environmental Protection Agency, Region 9 7 5 Hawthorne Street San Francisco, California 94 105-390 I

Mr. Lynn Baker California Air Resources Board 1001 I Street Sacramento, California 95812

Mr. Arnaud Marjollet San Joaquin Valley Unified Air Pollution Control District 1990 East Gettysburg A venue Fresno, California 93726

Mr. Dave Warner Director of Permit Services San Joaquin Valley APCD 1990 E. Gettysburg A venue Fresno, California 93 726

Mr. Wayne Lorentzen, P.E. Branch Chief Permitting Division Department of Toxic Substances Control 8800 Cal Center Drive Sacramento, California 95826

From everyday collection to environmental protection, Think Green :- Think Waste Management.

@ Printed on 100% post-consumer recycled paper.

WASTE MANAGEMENT

February 7, 2017 DTSC: Request for Response Extension for Notice of Deficiency for Permit Renewal Application for CWMI Kettleman Hills Page 3

cc: Robert Henry, WM Jim Sook, WM Andrew Kenefick, WM

From everyday collection to environmental protection, Think Green r;s> Think Waste Management.

@ Printed on 100% post-consumer recycled paper.

Chemical Waste Management, Incorporated KettlemanHlllsFaclllty

7-Feb-17

DTSC Part B Permit Renewal Application Notice of Deficiency SubmittalTimelineForecast

OO(lfMINT NUMBER DESCRIPTION

Permitting Division 18-Nov-16

memorandum

Geological Services Branch

memorandum

Human and Ecological Risk Office

14~Jan-16

memorandum

Permitting Division 26-0ct-16

cover letter 15-Sep-15

memorandum

General Comments

Specific Comments

General Comments

Specific Comments

General Comments

Specific Comments

Specific Comments

FIRST NOTICE OF DEFICIENCY FOR CHEMICAL WASTE MANAGEMENT, INC., KffTLEMAN HILLS FACILITY, EPA ID NO. CAT000646117

MajorChanges(Chapter51) Pertinent Reference Documents

VerbiageRestrict1on "oranyrevisionthereof"

Topographlcmap,Figure4-Z Topographic map, Figure 4-2

Identification of the Uppermost Aquifer, Chapter 25

4 Plume Description and Delineations, Chapter 9.1 s Seismic and floodplain Information, Chapter 5.2 Floodplain Report

s .1 Seismic and floodplain Information, Chapter 5.2 Floodplain Report 6 Seismic and floodplain Information, Chapter 5.2 Floodplain Report

7 Traffic,Chapter10 8 Chemical and Physical Analyses, Chapter 11.5 Chemical and Physical Analysis Data

9 Specific Information for Tank Systems, Chapter 15.0

10 WasteAnalyslsPlan,Chapter12

PartAPermitApplicatlon 12 WasteAnalysls Plan,Chapter12

13 WasteAnalysisPlan,Chapter12

14 Containers

15 Tanks 16 Polychlorinated Biphenyls(PCBs) 17 Exemptions, Extensions, and Variances to Land Disposal Restriction, Chapter 13

18 Variance from a Treatment Standard 19 Specific Information for Containers, Chapter 14 20 Specific Information for Containers, Chapter 14

21 Specific Information for Tank Systems, Chapter 15 22 Specific Information for Tank Systems, Chapter 15

23 Specific Information for Tank Systems, Chapter 15

24 Specific Information for Surface Impoundments, Chapter 17 25 SpedflclnformationforSurfacelmpoundments, Chapter17

26 Specific Information for Surface Impoundments, Chapter 17 27 Specific Information for Surface Impoundments, Chapter 17

28 Specific Information for Surface Impoundments, Chapter 17

29 Specificlnformationforlandfllls,Chapter19

30 Specific Information for Landfills, Chapter 19 31 Specific Information for lanctfllls, Chapter 19 32 Specific Information for Surface Impoundments, Chapter 17

33 Specific Information for Containers, Chapter 14 34 Procedures to Prevent Hazards 35 SpecificlnformatlonforWastePiles

36 tnspectlon Program,Chapter31

37 Containment Buildings ContingencyPlan,Chapter35 ContingencyPlan,Chapter35

Review of the Part B Permit Appllcatlon, Chemical Waste Management (CWM) - Kettleman Hills Facility, Kings County, CaUfomla, Project No. 25005/100032-33/20028684

Reference to Documents Which Are Not Included in the Permit Application

1 ThePhrase "orthelatestrevlslonthereof"

PointsofCompliance(Sectlon8) PlumeDescrlption(Section9) Flow Rate and Direction of Groundwater (Section 25)

4 Environmental Monitoring Programs (Section 261

Detection Monitoring Program (Section 27)

EvaluationMonltoring(Sectlon28) 7 CorrectlveActlon(Section29)

Chemical Waste Management, Inc., Kettleman Hiiis Facility (KHF), Kings County, California, CAT000646117

1 Documentlncluslon

Ambient Air Concentration studies by CARB, EPA, and independent firms in 1980, 1983, two in 1984, 1 and198S 1 Air Quality Solid Waste Assessment Test Report, 1988, independent firm, NUS Corporation

3 Gaseous Tracer Study at the Chemical Waste Management Kettleman Hills Facility 1988, CARB 4 KHF VOC Air Monitoring Program, KC, over nine years from April 1986 through July 199S

1994 Topographical, Meteorological and Airborne Contaminant Characterization at Kettleman Hills

5 Facility, independent firm 6 California Air Toxics "Hot Spots", 1996, SJVUAPCD

7 Ambient Air Monitoring Program, October 2006 to the present, DTSC, with CARB

AAMP Annual Screening Level Health Risk Assessments

Dioxin-Like PCB Congeners Study, 2009, EPA-IX 10 CEQA SEIR for B18/B20, (CH2M HILL, 2009)

11 Storm Water Management Plan (Centra Consulting, 2009)

12 Rainy Season Preparedness Plan (Centra Consulting, 2009) 13 Storm Water Pollution Prevention Plan (Waste Management, Inc., 2011) 14 RWQCB Resolution 88-051, (March 25, 1988)

15 ContlngencyPlan(yearnotspeclfled)

REVIEW OF THE CLOSURE AND POST CLOSURE COST ESTIMATE FOR KETTLEMAN HILLS FACILITY, 35251 OLD SKYLINE ROAD KETILEMAN CITY, CA 93239 (EPA ID CAT 000646117)

How and When Each HWMU will be Closed Pursuant to Closure Performance Standards

2 How and When the Facility wlll be Closed Pursuant to Closure Performance Standards

3 Removal of Hazardous Waste Inventory

Clean Closure Owner and Engineer's Certification Maximum Cost of Final Closure as Indicated In the Closure Plan

7 Cost Estimate Based on hiring a Third Party to Close the Facility Post-Closure Monitoring Activities and Frequency

Owner and Engineer's Certification

NOTE(S):

PREPARATION OF FINAL SUBMITTAL (REVISED APPLICATION) SCHEDULED FROM AUGUST 1, 2017 THROUGH AUGUST 15, 2017

MINOR CHANGES TO BE INCLUDED IN THE FINAL SUBMITIAL

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