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4'e ASCO Power Technologies P.O.Box 1995,95201 Carlton Ave. EMERSON.. Sr ck n,CA9 203 Net1work Power T(209)941-4111 F(209)948-1375 June 14,2007 Kasey Foley, CUPA Program Coordinator Certified Unified Program Agency(CUPA) San Joaquin County Environmental Health 600 E. Main St. Stockton, CA.95202 REG: Handling Universal Waste Aerosol Cans Health &Safety Code 25201.16 Notification Requirements ASCO Power Technologies, LP USEPA ID CAD981373947, SIC CODE 3613 Dear Ms. Foley: In accordance with our telecon this day, I am both emailing and certified mailing with return receipt this letter as written notice to you of our process of Universal Waste Aerosol Cans so that we may be exempt from permitting. We certify that the equipment and process used for processing the cans onsite meets the requirements of Health and Safety Code 25201.16 inclusive, but not limited to the following: • We use one Aerosolv Puncturing Machine attached to one 20 gallon steel DOT Hazmat Drum for puncturing non-empty aerosol paint spray cans.(Refer to attachment) • The Aerosolv Machine is operated manually by pull down lever which punctures the can allowing both propellant and contents(paint)to be expelled into the drum without releasing any propellant or contents into the atmosphere. • The Aerosolv Machine by Justrite incorporates a combination filtering system comprising a coalescing filter and an activated carbon filter. • Both the Aerosolv Machine and the Drum are grounded at all times. • The entire unit is located inside a secondary,seamless,containment basin on a concrete floor inside the plant away from any heat and electrical sources and inside our Hazardous Material Storage Area. • All appropriate and require labels are in place on the Machine and Drum and Hazmat Area. • Further,we have an ISO Policy by which we do not accumulate these cans but, instead,we process them on a daily basis as they are used.These Biel 2oz& 16oz cans of touch-up paint.The volume of cans being processed is approximately 6 cans per week. • All empty cans are thrown into the Stockton Scavenger Bin the same day that they are processed. • The contents of the Drum is classified as RCRA Hazardous Material, EPA Code D001,Waste Paint, DOT 3 UN 1263 PG!!. • Safety-Kleen picks up the Drum and transports it,manifested,to their own treatment facility in Denton,Texas,where the contents is recycled. Safety-Kleen Corp. USEPA ID TXR000050930 5050 Salida Blvd., Salida, CA. 95368 209-545-1011 If you have any questions, please contact me at 209-941-5268 or email bvenkus a0asco.com. Regards, Bill Venkus,Environmental Coordinator di see Power f�s.7�e Technologies B��@fl6d Power