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0 <br /> RESPONSE TO RCRA LARGE QUANTITY GENERATOR INSPECTION REPORT <br /> To assist and support AASC's operations, and to provide guidance to address and correct some <br /> of the San Joaquin County Environmental Health Dept. findings,Applied Aerospace c,p� <br /> Corp., retained the services of NES, Inc. R I <br /> #102. Failed to determine if a waste is a hazardous waste. JUN 26 2017 <br /> CORRECTIVE ACTION ENVIRONMEW iAL <br /> Rage Gold body filler—managed as non-RCRA hazardous waste HEALTH DEPARTMENT <br /> This wastestream consists of swabs, cups, and wipes used to mix and apply Rage Gold body <br /> filler and a cream hardener. The actual waste is predominately the swabs, cups, and wipes that <br /> are contaminated with cured Rage Gold and hardeners. Once cured, the Rage Gold and hardener <br /> constituents do not exhibit the characteristics of ignitability, corrosivity, or reactivity. However, <br /> there are constituents that are presumed to create a hazardous waste (e.g., benzoyl peroxide and <br /> styrene). AASC has used generator knowledge to characterize this wastestream as a non-RCRA <br /> toxicity characteristic waste. The profile is being updated by the TSDF. <br /> Mold release booth filter solids—Chris Hansen escorted the inspector to the area of the baghouse <br /> which we believe was erroneously called the mold release booth filter solids. That material is <br /> not hazardous waste and is a combination of dry material consisting of wood, aluminum, <br /> fiberglass, carbon fiber, and plastic. <br /> Used oil filters are not going to be managed as an"Excluded Recyclable Material". They are <br /> drained of free flowing oil and will be marked with the following information: Drained Used Oil <br /> Filters, Accumulation Start Date. The TSDF however, may list it as an Excluded Recyclable <br /> Material on the Bill of Lading. <br /> Fluorescent dye—A representative sample of this wastestream will be collected on 6/23/17 and <br /> will be analyzed for flash point and toxicity(96-hour fish bioassay). <br /> #110. Failed to maintain a hazardous waste contingency plan onsite and submit to <br /> required agencies. <br /> CORRECTIVE ACTION <br /> The contingency plan with updated contact information was mailed to the local police, <br /> department, fire department,hospitals and state and local emergency response teams on June 21, <br /> 2017. <br /> #111. Contingency plan not current. <br /> CORRECTIVE ACTION <br /> The contingency plan was updated with the current contact info. <br />