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• 0 6RECEIVED (reference program 2220, item 3030) AUG 0 5 2014 Stripper Sludge to be Recycled ENVIRONMENTAL HEALTH (DEPARTMENT The claim being made is that we have a secondary material that we store incorrectly and have accumulated speculatively. We respectfully disagree that the material is "secondary material' as defined in CCR section 66261.4 (a) (5) and I do not believe that this material is subject to this section. We do believe this material is subject to CCR section 66261.3(a) (1) and is excluded from classification as a waste. We do believe this material is excluded from classification as a waste under HSC section 25143.2(b) or 25143.2 (d). SB14 requires Hazardous waste generators to seriously consider source reduction as the preferred method of managing hazardous waste (S'1314 Introduction and Overview). HSC section 25244.13(f) reads "It is the intent of this article to promote the reduction of Hazardous waste at its source and wherever source reduction is not feasible or practicable to encourage recycling." A recyclable material is as defined in CCR section 66260.10 "Recyclable material" (c) "A material that is contaminated to such an extent that it can no longer be used for the purpose for which it was originally purchased. We believe our stripper sludge is as described by this definition because we have a contaminated primary material and that is not a secondary material. We have a primary material that is contaminated by paint. This is exactly the purpose for which this product was manufactured, purchased and we use it in the intended manner. This section also specifically mentions stripping solutions as an example of possible materials to be recycled. A material that is "Accumulated speculatively" as defined by CCR Section 66260.10 "Accumulated Speculatively' says "A material is not accumulated speculatively, however, if the person accumulating it can show that the material is potentially recyclable and has a feasible means of being recycled" This material is capable of being recycled as per Jemchem.com website, Jemstrip 427, Benefits, (6), "Stripper may be recycled". The machine to recycle this material is commercially available, manufactured in the USA. One such manufacturer is Becca Inc, Beccainc.com. There are several different manufacturers available. The recycled material would be returned to the strip tank for where the contaminated material was removed originally. When material is subject to CCR Section 66261.3(a)(1), and excluded from classification as a waste, it can be held in a container or a tank. HSC 25143.9(a) In conclusion, the "Stripper Sludge to be Recycled" is a recyclable material, stored in acceptable containers and is not been accumulated speculatively. Premier Finishing is trying to comply with the goals of SB14. We have documentation to confirm we have been pursuing this effort for sometime. We have continued to collect the stripper sludge because we have had very encouraging results in testing. Like any R&D effort there is cost in development — it is our hope we can recover some of your investment with successful recovery of this material. inspection item 3030_stripper sludge