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February 6, 2018

February 6, 2018
To The Citizens Group
Of San Luis Obispo County

This report is being submitted in response to your request to conduct an
investigation of Charles K. Tenborg and his related companies; Eco Solutions,
Fond Farewells Inc., CEC Medical Waste Services Inc., CEC Electronic Waste
recycling, The Cleaner Earth Company Inc. and Stericycle, Inc. As further
described in this report, my team have issued numerous Public Record Act (PRAs)
requests to local government agencies, and have also conducted several interviews
with cooperating citizens located in the SLO area. The results of our investigation
are summarized below.
Unless otherwise stated, the information in this report is based upon information
and belief, this report is based upon my personal knowledge and if called upon to
testify, I could and would competently testify thereto.
Exhibit “A” attached hereto is a true and correct copy of my Curriculum Vitae and
accurately sets forth my qualifications and background.
1. I am the owner of Knudson Investigations (Knudson & Associates) and have
been since November 2000. I am a consultant within the area of forensic
accounting and fraud investigations. My clients include, among others, city and
county government organizations, non-profit organizations, insurance companies,
retail stores, electronic manufacturers, real estate companies, golf courses,
construction companies, banks, corporations, and the Federal Public Defenders’
Office in Los Angeles and Orange County. I consult, and sometimes conduct
investigations for my clients on issues regarding; conflict of interest, management
malfeasance, alleged laundering of monies, and purported embezzlement and
laundering of the proceeds by government employees, corporate officers and
contractors. I have consulted for the Federal Public Defenders Office in Los
Angeles and Orange County, California on tax fraud cases and mail fraud, wire
fraud, embezzlement schemes (sometimes known as Ponzi Schemes). I have also
consulted with CJA Panel attorneys, in their defense of clients accused of complex
financial crimes such as tax fraud, Medicare Fraud, bankruptcy fraud, mail fraud,
money laundering, identity theft and wire fraud and have testified in Federal and
State court proceedings regarding my findings and opinions.
2. As a consultant, I have also been engaged as an expert witness in connection
with federal and state court proceedings in approximately 100 cases. I have
testified as an expert witness at trial in eleven cases. My expert witness
engagements have been in the following areas: Medicare fraud, tax fraud, federal
and state money laundering schemes, federal money structuring schemes, wire
fraud schemes, mail fraud schemes, bankruptcy fraud schemes, SEC violations,
bank fraud schemes, loan fraud schemes, mortgage banking fraud, narcotics
trafficking, Ponzi schemes, Pyramid schemes, Telemarketing schemes, Identity
Theft schemes, Political Corruption schemes, and embezzlement schemes.
3. Prior to becoming a consultant, from June 1997 to October 2000, I was
employed as a director in the Financial Advisory Service practices at the Big 5
accounting firms of Price WaterhouseCoopers and KPMG. As a director, I
managed and conducted engagements into internal embezzlement schemes by
corporate officers employed at high tech companies, construction companies,
insurance companies, hotel management companies, hospitals, HMO’s, not-for-
profit organizations, city government and casinos. I coordinated investigative and
forensic accounting efforts with external counsel, general counsel, human
resources and the internal accounting staff. I traced flow of embezzled funds
through corporate books and records, bank accounts and internal backup
documents. As a director, I also consulted with national banking institutions
regarding purported money laundering schemes that had occurred at their bank(s)
and suspected malfeasance by a bank officer.
4. From May 1973 to June 1997, I was employed as a special agent with the
IRS, Criminal Investigation Division (“CID”). As a special agent, I conducted
numerous investigations into money structuring and money laundering cases
relative to narcotic traffickers and organized crime subjects. I worked with
banking institutions and local regulators in providing guidance into the
implementation of money structuring (USC, Title 31) and money laundering laws
(USC, Title 18, section 1956) and related banking regulations. I also conducted
joint investigations with the Federal Bureau of Investigations (FBI) related to
public corruption.
5. In connection with my employment with the organizations described in the
preceding two paragraphs, I received extensive training on auditing, accounting
and financial investigative techniques. In those positions, I participated in, and
conducted, hundreds of investigations of alleged criminal offenses, including tax
crimes, money laundering, structuring, wire fraud, mail fraud, health care fraud,
bankruptcy fraud, Ponzi schemes, pyramid schemes, bank fraud, embezzlement,
public corruption and other fraud related offenses.
6. As a result of my experience and training as shown above in paragraphs 2
through 4, I have become familiar with conducting the financial analysis of a
business operation; and the financial analysis of a person’s wealth and net worth.
As a result of my experience, employment and training, I have become aware of
how a business operates, generates revenue and pays its operating expenses. As a
result of my employment, I have reviewed financial records and bank documents
showing the financial status of individuals or companies. I have also analyzed tax
returns and tax return information in order to reconstruct the financial viability of
individuals and companies.
7. I have a Bachelor of Science degree in business administration. I am a
licensed private investigator in the State of California and a Certified Fraud
Examiner (CFE).

8. In or about September 2017, we were contacted by a group of citizens (The

Group) from the San Luis Obispo (SLO) area, who wanted us to conduct an
investigation of Charles K. Tenborg and his related companies. In particular, The
Group wanted us to contact local government agencies in the SLO area that had
business dealings with Mr. Tenborg or his companies during the period 2009 to the
present, and determine whether Mr. Tenborg had received notices of violations or
had been the subject of investigations of any type.
9. I was informed that Mr. Tenborg and/or his companies were involved in the
Hazardous Waste industry in the SLO area and was a contractor for the Integrated
Waste Management Association (IWMA) at 870 Los Osos Road, in the City of San
Luis Obispo and at the Household Hazardous Waste (HHW) site located at the
landfill known as Cold Canyon Landfill.
10. I further understood that the IWMA leased a portion of the Cold Canyon
landfill for the operation of the IWMA, HHW.
11. As part of our investigation, in or about October of 2017, we sent Public
Record requests to:
Ryan Egli
California Department of Resources Recycling and Recovery (CalRecycle)
1001 I Street, MS-23A
P.O. Box 4025
Sacramento, California 95812-4025

Custodian of Record
Department of Toxic Substance Control (DTSC)
1001 “I” Street
P.O. Box 806
Sacramento. Ca 95812-0806

Custodian of Records
San Luis Obispo County Integrated Waste Management Authority
870 Osos Street
San Luis Obispo, CA 93401

Kelly Wetmore
Director of Legislative and Information Services
City of Arroyo Grande
300 East Branch Street
Arroyo Grande, CA
Cold Canyon Landfill, Inc.
Waste Connections
Custodian of Record
2268 Carpenter Canyon Road
San Luis Obispo, CA

Pacific Gas and Electric Company

Custodian of the records
Mail Services Center, Room 101
77 Beale Street, San Francisco, CA 94105

The Central Coast Regional Water Quality Control Board

(Central Coast Water Board)
San Luis Obispo, CA

Mr. James P. Erb, County Auditor

1055 Monterey St,
San Luis Obispo, CA 93408

12. Further, We also contacted a number of government officials to obtain

clarifications to our PRA requests, and we have also contacted citizens located in
the San Luis Obispo area who have provided additional records and testimony
related to Charles K. Tenborg and his businesses.
13. On November 2, 2017, CalRecycle responded to my PRA request of
October 16, 2017 by email, and attached a number of documents that I had
requested. Included in the requested documents was a Notice of Violation
addressed to Charles Tenborg and CEC Electronic Waste Recycling Inc., dated
February 6, 2017 and stated; “CEC, while operating under CEWID #100228,
repeatedly made false statements on the payment claims listed below …As a result,
CEC falsely claimed in excess of $30,000.” On page 2 of violation notice, there
was a list of 17 violations for false claims beginning in March 2014 and ending in
July 2015. The Notice of Violation indicated that Form 196B, recycling claim
form had been submitted to CalRecycle for Cancellation of Non-CRT Covered
Electronic Waste (CEW) for each of the 17 violations which ran for 17 consecutive
months beginning in March 2014 and ending in July 2015 (Exhibit 1, Notice of
14. CalRecycle included two examples of the false claims for June 2014 and
June 2015 (Exhibits 2 and 3). It should be noted that the claim forms for 2014
and 2015 were both signed by Charles K. Tenborg “..under the penalty of perjury.”
15. The claim forms 196, Covered Electronic Waste Recycling Payment Claim
for June 2014 (Exhibit 2), showed under the Payment Claimed, Non-CRT
containing wastes canceled (attach Worksheet B) a number of 11,046 lbs and a
claim amount of $4,861.12. The 2nd page of the claim form 196 indicted that
under “Part 2,” there was a confirmation of the weight of 11,048 lbs and the
amount of $4,861.12. The amount was based upon a rate of .39 cents a pound.
Attached to the Claim Form 196 were 12 pages of handwritten “worksheets” to
support the 11,048 pounds claimed on the form.
16. As part of the CalRecycle response to my PRA request, they included their
summary worksheet where they determined that Tenborg’s worksheet B only
accounted for 6,728.8 lbs of canceled Non-CRTs, but claimed 11,048 lbs on the
claim form and thus overstating the weight by 4,319.2 lbs or .39 equaling $1,684
in over charges (Exhibit 2a, copy of spreadsheet summary).
17. The claim forms 196, Covered Electronic Waste Recycling Payment Claim
for June 2015 (Exhibit 3), showed under the Payment Claimed, Non-CRT
containing wastes canceled (attach Worksheet B) a number of 12,039 lbs and a
claim amount of $5,297.16. The 2nd page of the claim form 196 indicted that
under “Part 2,” there was a confirmation of the weight of 12,039 lbs and the
amount of $5,297.16. The amount was based upon a rate of .39 cents a pound.
Attached to the Claim Form 196 were 14 pages of handwritten “worksheets” to
support the 12,039 pounds claimed on the form.
18. As part of the CalRecycle response to my PRA request, they included their
summary worksheet where they determined that Tenborg’s worksheet B only
accounted for 7,552.5 lbs of canceled Non-CRTs, but claimed 12,039 lbs on the
claim form and thus overstating the weight by 4,486.5 lbs or .39 equaling $1,749
in over charges (Exhibit 3a, copy of summary spreadsheet).
19. Further, as part of CalRecycle’s response to my PRA request, they included
an email string dated November 20, 2015, where the apparent false claims were
first acknowledged by Mr. Tenborg (Exhibit 4, copies of emails).
20. Moreover, CalRecycle provided a copy of a “Stipulated Payment
Agreement” (Exhibit 5) dated February 21, 2017, whereby Charles K. Tenborg
agreed to the evidence set forth in paragraph 4 of the agreement and agreed to
repay CALRECYCLE $34,643.08 for “monies improperly claimed”. In particular,
paragraph 4 states in part that, “Upon review of CEC’s July 2015 Payment Claim
No. 3200, CALRECYCLE discovered inconsistencies with respect to CEC’s
reported weights in this claim and sixteen (16) prior Covered Electronic Waste
Recycling Payment Claims submitted to CALRECYCLE by CEC. These Payment
Claims contained certified statements by CEC stating that it had properly
processed or cancelled all claimed CEW.” However, as shown on each of the
sixteen (16) claim forms, Mr. Tenborg signed the forms and declared so “Under the
Penalty of Perjury.”

Department of Toxic Substance Control (DTSC)

21. On October 17, 2017, we issued a PRA request for records related to Charles
K. Tenborg and his related companies to: The Custodian of Record, Department of
Toxic Substance Control, 1001 “I” Street, P.O. Box 806, Sacramento. Ca
22. Based upon our request, DTSC provided the following documents;
a. Summary of Violations (Exhibit 6), dated September 17, 2008 to
CEC Electronic Waste Recycling.
b. Summary of Violations (Exhibit 7) dated October 28, 2009 to CEC
Electronic Waste Recycle Inc. located at 2112 Carpenter Canyon Road, San
Luis Obispo, CA. What was noted that under EPA ID Number the inspector
noted “None.” The summary stated; As a result of this inspection, violations of
hazardous waste laws, regulations, and requirements listed on the attached
pages were discovered.” The Summary was signed by Charles Tenborg,
President on”10/28/2009.”
The attached pages of the 5 violations noted that at “1” CEC failed to obtain a
California ID Number.
c. Summary of Violations (Exhibit 8) dated September 20, 2011 to Cleaner
Earth Company. The company representative accepting the summary of
violations was “Maurice Tenborg, CEC Ops Manager.” In a follow up letter
dated April 4, 2012 (Exhibit 8a) from DTSC to Charles K. Tenborg. The
DTSC letter stated in part, “DTSC sent you a letter dated October 24, 2011,
with comments regarding the documents and the glass breaking process. In our
letter we stated that revisions to the documents had to be submitted to DTSC for
review and approval before Cleaner Earth Company could start the CRT glass
breaking operations.” “Since we have not received the revised documents, we
assume that you have decided not to pursue operating the CRT glass breaking
facility at this time.”
d. Report of Investigation (Exhibit 9), dated August 26, 2014 with a Date of
Complaint shown as May 19, 2009, State of California, Department of Toxic
Substance Control. The report indicated that the “Subject” was Charles
Tenborg, dba, aka, Eco Solutions with an address of 427 Plomo Court, Arroyo
Grande, California. The allegation listed was “Unlawful transportation and
disposal of hazardous waste.”
Of interest on the report it was noted ”EPA Number “none” or “Hauler Reg.
Number “none.”
The report stated, “This investigation was opened as an illegal recycling
handler/facility of e-waste, Investigator Valerie Alvarez observed and followed
a vehicle driven by Charles Tenborg who operates Eco Solutions Inc.
In the details section of page 2 of the report it was written: “Investigator
Alvarez conducted research into the operation of ESI (Eco Solutions Inc.) and
the operations of the Household Hazardous Waste facilities at the landfills by
Tenborg DBA ESI. Although there were questions and appeared to be issues
regarding the handling and transportation of e-waste as well as other chemical
wastes at these facilities Alvarez was unable to prove any violations before she
had to take a medical retirement.”
Note: I have been informed that Ms. Alvarez passed away due to Cancer.
Note: See section of report “Reichert” at paragraph 23 below.
23. Interview of Andy Reichert on October 6, 2017. Mr. Reichert provided
the following information (in substance):
• He had observed Eco Solutions trucks parked on Huasna Road, Ikeda Way
and Plomo Road for many months and possibly over a year that he believed
were carrying hazardous waste. He took many pictures of the various trucks
and trailers with the ECO Solutions Logo that were carrying electronic
components, such as TVs and Computers and containers containing
markings of Hazardous Waste. See pictures provided by Reichert dated
March 9, 2009 below.
• In March of 2009 Reichert attended Arroyo Grande city council meeting
where he spoke for 15-minutes with a slide show of the pictures he took of
the Tenborg vehicles and what he believed to be Hazardous Waste.
However, he was ignored.
• Tenborg had another truck with a lot of miscellaneous equipment in its
trailer parked in nearby cul-de-sac (brother’s house).
• The Arroyo Grande community rep agreed that there was an issue, but stated
that the occupant of the property had moved elsewhere in Arroyo Grande.
• Mr. Reichert’s had a flash drive that contained all of the images he took. We
copied the contents of the flash drive on our Surface computer.
• Reichert felt that hazardous waste containers have a proper protocol for
transport, storage, and disposal that wasn’t being followed.
• Reichert contacted the Tribune newspaper with his photos and never
received a response. He contacted Karen Velie of CalCoast News and
exchanged a number of emails with her during March of 2009.
• Reichert saw random boxes and containers left on the sidewalk and
driveway in front of Tenborg’s house on Ikeda Way as people left them for
disposal (hazardous e-waste?)
23a. I have included a few of the many photographs provided to us and
taken by Mr. Reichert as shown below:

Reichert Pictures
24. Interview of Paul Schmidt, Arroyo Grande Citizen who provided the
following information:
• He had been in business with Tenborg in 2009 and had invented a paint can
crusher that Tenborg used to crush paint cans.
• He lives on the street where Tenborg parked his ECO Solutions commercial
vehicles, and saw e-waste and hazardous waste barrels in trailers on Plomo
street, but he didn’t know if the barrels were full or empty.
• He recalled that Tenborg had a contract with PG&E to clean waste out of
their electrical vaults and had a special nozzle attachment that was designed
to suck up the waste from the vaults.

City of Arroyo Grande

25. On October 18, 2017, we issued a PRA request to the City of Arroyo Grande
and received the following letter (Exhibit 10) dated January 22, 2010 that Tenborg
sent to Mr. Jim Bergman, Planning Manager for the City of Arroyo Grande. In the
letter, Tenborg stated that, “I am writing this letter notifying your department that
all complaints regarding storage of trailers at our former business address of 131
Ikeda Way have been corrected. Since July of 2009 all trailers and cargo trucks are
being stored at our facility located at the Cold Canyon Landfill. Prior to that date,
we did not have storage available.”

Central Coast Regional Water Quality Control Board

26. On December 21, 2017, we issued a PRA request to the Central Coast
Regional Water Quality Control Board (Water Board) and on January 22, 2018, we
received a response to our request. I learned through my investigation that the
Water Board had jurisdiction over the Cold Canyon Landfill and I was therefore
interested in any violations that had occurred at the landfill.
27. In response to my PRA, the Water Board provided a string of emails dated
November 2015 (Exhibit 11) between Ryan Lodge at the Water Board and
Benjamin Gray at Waste Connections regarding “Waste Handling Complaint.” Mr.
Gray in his email to Lodge stated:

“In May of 2013 I learned that EcoSolutions Inc., which runs the HHW
facility for the County at our Cold Canyon Landfill, had dumped some soil over
the NE portion of the HHW facility. This area is an unlined, non- landfill
portion of the Cold Canyon property.
I investigated the area in question and confirmed that some type of soils
appeared to have been dumped in the area described above. I then obtained
analytical data of the material from Charles Tenborg, the owner of
EcoSolutions, which he admitted to have dumped by the HHW area. Charles said
the soil in question was “build up” from wind and animals in transformer boxes
owned by PG&E that EcoSolutions had serviced.

After reviewing the analytical data, our Environmental Specialist for the
Western Region informed me that the sampled material did not meet
“unrestricted” use and needed to be placed into a lined portion of the
landfill. The material was not hazardous waste, but could not be dumped in the
area that it had been. I provided Charles a special waste application which he
completed and provided to our Environmental Specialist, who then issued special
waste permit….Charles then cleaned up all soils that were dumped by the
HHW and disposed of the soil on September 18, 2013 into Cold Canyon
Landfill under special waste permit ColdCanyon-13-003.”
28. The email from Lodge talked about a video that had been posted on Youtube
that “claimed to show Tenborg dumping soils at the Cold Canyon recycling area
that may be toxic.” However, there was no indication in the attached email string
that any further action had been taken?
29. I have reviewed the video that is on the YouTube website and is narrated by
a purported EcoSolutions employee at the HHW work site at the Cold Canyon
Landfill. In the video I noticed images of barrels that were double-stacked in the
HHW area and bore a striking resemblance to the pictures taken by Mr. Reichert of
a barrel marked “Hazardous Waste” (page 12 of this report) contained in a Tenborg
vehicle parked on a street in Arroyo Grande in 2009.
30. The evidence provided by the Water Board indicates that the 2013 incident
was not reported to the Water Board by Waste Connections until November 2015,
over two years later and only after an inquiry from Ryan Lodge. Further, from the
emails between the Water Board and Waste Connections, there is no discussion as
to whether the Water Board or Waste Connections independently sampled the soil
at the HHW site in order to confirm that the site was free and clear of any of the
chemicals listed on the PG&E chemical analysis.
31. Moreover, it appears, from the information that we have gathered that
Tenborg had been collecting Vault Waste from PG&E beginning at least in 2009,
and there is no indication where he was properly disposing of this waste. I have
reviewed sworn statements of Mr. Tenborg where he admitted to disposing of
“clean” soils from PG&E in 2013, and that PG&E were not clients prior to 2013.
These sworn statements from Mr. Tenborg seem to conflict with the evidence cited
in this report where Cold Canyon described the soils as “restricted” and could not
be dumped at the HHW site where they had been dumped. Tenborg’s own billing
statements to the IWMA and a statement from a prior business partner indicated
that PG&E was a client dating back to 2009.
32. In or about October 6, 2017, we attempted to interview employees at the
Cold Canyon Landfill and were referred to Waste Connections counsel Mr. John
Perkey. On October 9, 2017, I spoke with Mr. Perkey who advised me that he did
not want us talking to the employees of Cold Canyon Landfill.
33. On October 13, 2017, we sent a PRA request to the Cold Canyon Landfill
(Waste Connections) asking for information related to Charles K. Tenborg or his
companies. I was subsequently contacted by Mr. John Perkey, counsel for Waste
Connections on October 27, 2017 who advised me that Waste Connections was not
a public company and therefore they would not be responding to my request.

34. On October 18, 2017, we sent a PRA request to PG&E for information
related to Charles K. Tenborg and was subsequently contacted by the PG&E legal
department who advised me that they were not a public company and would
therefore not be responding to my request regarding Charles Tenborg or his

San Luis Obispo County Auditor

35. On October 18, 2017, we sent a PRA request to Mr. James P. Erb, County
Auditor, 1055 Monterey St., San Luis Obispo, CA 93408. Mr. Erb responded to
our request with copies of the records requested related to IWMA payments to
Charles Tenborg or his companies. We have not included all of the documents
provided by Mr. Erb in this report. Rather, we are including one invoice received
by the IWMA from CEC Eco Solutions, Inc. with an invoice date of 7/31/2009
(Exhibit 12) The invoice had an attachment to apparently substantiate expenses
claimed on the invoice to the IWMA. The attachment is an invoice from “Borg
Building Consultants” dated “8/7/2009” to Eco Solutions, 131 Ikeda Way, Arroyo
Grande, CA for a series of hourly charges for:

“Contract Services, PGE Vault Cleaning Lompoc”

“Contract Services, Crusher Repair, Cold Canyon Landfill”
“Contract Services, HHW Supply Distribution to all sites & Hauling”
“Contract Services, Hauling tubes and propane tanks to Cold Ca.”

It does not appear that the $300 charge for the PGE Vault Cleaning Lompoc was
charged to the IWMA. The Reichert photographs taken of Tenborg’s trucks and
trailers parked on the residential streets of Arroyo Grande in or about March of
2009 shows propane tanks and what appears to be electronic equipment all
together in containers or trailers (page 12, pictures).
36. Based upon my research of Borg Building Consultants, 429 2nd Street, Des
Moines, IA it appears that this business is associated with Maurice Tenborg, the
brother of Charles Tenborg.

37. Based upon our initial investigation and the documents obtained from
CalRecycle, Water Board, and the DTSC it is clear that Charles K. Tenborg was
cited numerous times for the violation of California’s Hazardous Waste Laws,
which were related to his business operation located at the Cold Canyon Landfill.
Further, the evidence provided by the Water Board documented the dumping of
“restricted” PG&E soils at the HHW facility located at the Cold Canyon Landfill in
May of 2013. The evidence obtained during the investigation showed that
beginning in 2009 and ending in 2013, Tenborg and his companies were collecting
vault waste from PG&E vaults but we found no evidence documenting where this
vault waste was discarded except for the one incident in May of 2013. The
evidence shows that Mr. Tenborg acknowledged the DTSC notices of violations
that were sent to him by certified mail.
38. Although this is a preliminary report, we have concerns that the
environmental consequences of the unauthorized dumping of “restricted” or
potentially hazardous materials at the HHW site at the Cold Canyon Landfill by
Mr. Tenborg have not been thoroughly investigated.

39. I would recommend that this report be shared with local law enforcement
authorities to determine whether Tenborg should be prosecuted for repeatedly
making false statements on seventeen (17) consecutive payment claims to
CalRecycle during the period March 2014 to July 2015, which were made under
the penalty of perjury.
40. Further, I would recommend that law enforcement authorities investigate the
unauthorized dumping of PG&E vault waste at the Cold Canyon Landfill by the
Tenborg companies to determine whether “hazardous” waste was being collected at
the PG&E vaults, transported by the Tenborg companies to the HHW site at the
Cold Canyon Landfill, and stored at the HHW site without the proper permitting by
the Cold Canyon Landfill or approval of the appropriate government agencies. .,
Further, it is our recommendation that a comprehensive sampling by a certified
laboratory be conducted of the HHW located at the Cold Canyon Landfill in and
around the area where the “unauthorized” dumping was documented.

41. I would further recommend that the witness names identified in this report
be redacted unless waivers are received from them personally.
Respectfully submitted,

Carl R. Knudson, CFE, PI (#19339)

Knudson Investigations

INTRODUCTION ….………………………………………………………… 1
THE INVESTIGATION ……………………………………………………… 4
CALRECYCLE ………………………………………………………………. 6
INTERVIEW OF ANDY REICHERT ………………………………………… 10
INTERVIEW OF PAUL SCHMIDT ……………………………………….…. 12
……………………………………………….. 13
BOARD .. 14
CONCLUSIONS ………………………………..……………………………… 18
RECOMMENDATIONS …………………………………………………….….19
LIST OF EXHIBITS …………………………………………………………… 21

-1- CalRecycle Notice of Violation 2/6/2017

-2- CalRecycle Worksheet B, June 2014 Claim
-2a- CalRecycle Analysis of Billings 2014
-3- CalRecycle Worksheet B, June 2015 Claim
-3a- CalRecycle Analysis of Billing 2015
-4- CalRecycle Emails re Tenborg Billings
-5- CalRecycle Stipulated Payment Agreement 2/21/2017
-6- DTSC Summary of Violations 9/17/2008
-7- DTSC Summary of Violations 10/28/2009
-8- DTSC Summary of Investigation 8/26/2014
-8a- DTSC Summary of Violations 4/4/2012
-9- DTSC Summary of Violations 9/20/2011
-10- City of Arroyo Grande – Letter 1/22/2010
-11- WaterBoard emails 9/20/2015
-12- SLO County Auditor re Eco Solutions 7/31/2009