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L ame, State Bar number, and address) Craig Walters Premier Coating, Inc., dba Premier Finishing 7910 S. Longe St., RECEIVED Stockton, CA 95206 TEtEpnoNENo:209-982-5585 FAxxofoerro,a ):209-983-4055 AUG 0 5 2014 Ehl RA DRESS craigCcilprentierfinishing.com AITORNE R AME: ENVIRONMENTAL HEALTH SUPERIOR COURT OF CALIFORNIA, COUNTY OF- San Joaquin STtEET ADD&Ess: 222 E. Weber DEPARTMENT MARLING AOORESR: C=MDWc0DE: Stockton, Ca., 95202 IN PLATIFF/PETITIONER: SJ County Environmental Health Department ` Number DEFENDANT/RESPONDENT: Craig Walters, President, Premier Finishing I am addressing a misunderstanding between myself and Mr. Raymond Von Flue (the lead inspector with the San Joaquin County Environmental Health Department). During the inspection on June 16, 2014 at Premier Finishing I made the statement, ..... we add hardener to our paint". Unfortunately, Mr. Von Flue took that statement out of context and concluded that we were intentionally adding hardener to paint for the purpose of disposing of it. I sincerely regret this misunderstanding, because nothing could be further from reality. Furthermore, this misunderstanding has led Mr. Von Flue to cite our company for a Class I violation under HSC 25201(a) "Failure to obtain a permit to treat hazardous waste." - Based on the premise that what we are doing is disposing of paint by adding hardener. If this were true, then indeed, we agree that we would be in violation. However... It is extremely important that I describe our fundamental process; the basis for everything we do using this type of paint (which is classified as hazardous material). The first thing we have to do is catalyze it (add Hardener). This initiates the chemical reaction which allows the paint to achieve its performance characteristics, its hardness, its gloss, its texture and its drying. Without the addition of the catalyst (hardener) the paint would simply not be useable. As an example, please see figure 1, an extract from a typical paint product used at Premier. We simply would not use this product, or any other, without the product mix of hardeners, and or reducers. Without doubt, I did say that we add hardeners to our paint. I now understand the source of the confusion is that Mr. Von Flue was thinking about the paint after it had become a waste product. I was referring to the paint before we use it. There would simply be no need to catalyze (add hardener) to the paint left over after a production job, because it is already catalyzed. I certainly regret this misunderstanding because it has become the source of numerous assumptions which do not have merit. Premier does not catalyze (harden) waste, excess, overrun paint. —4CARDINAL Figure t:Technical data sheet from Cardinal Industrial Finishes. Product Number: 6400 / 340 SG Series. Shows Mix requirements for paint with catalyst and reducer. If this is not followed, the paint will not function correctly. Our requirement to our customers Is achieving proper paint performance. Aal•I'vo Afterefors n9Ne eatalys M ix only mix cornporlenl 1 before addingg cede at. My only to amaudl Of mabdal readetl. The base m ousted proportion must be measured eocumbly. by volume onlyy. to obtain ppemum ghn pmpertles. Co not use mtluras Nat conbin water or atcolol; Mese read YAM Ne catayst and can cause a variety of problems. ...w.. �a. Bs axare al appy -able poi ofe. Brushing, roa, ad Gipping ora no! nmmendad. MIX FAnos: Tarn mmporenls must be mus, pn Wy to oblaln coatng perfomlance. Thinning depends on I declare under penalty of perjury under the laws of the Sate of California that the foregoing is true and correct. Date: • Craig Walters (TYPE OR PRINT NAME) (SIGNATURE OR DECLARANT) to