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,IV ® <br /> memo <br /> AvR 20 <br /> I LTERNATIONAL�PAPER <br /> ENVIRONMENTAL H- L <br /> PERMITISERVICES 4 <br /> Date: April 19, 2016 From: Jim Dacayanan <br /> To: SJCEHD, att: Stacy Rivera Re: Notice To Comply,April 5, 2016 <br /> cc: MM,HM, VK, TS <br /> Please reference Item 102 of the Notice To Comply. <br /> I attach Analytical Report 1503989 dated 3/30/2015. This is a CAM 17 test where copper was <br /> found to be in excess of ten times the STLC limit. All other analytes in the CAM 17 test were <br /> within limits. An additional test was conducted on 4/13/2015. This is an STLC test for copper, <br /> Work Order 1503989 A. The STLC results show copper at 9.3 mg/1 which is below the threshold <br /> limit of 25 mg/l for this analyte. <br /> I also attach an Analytical Report, Work Order 1603C72. This is a CAM 17 test conducted on <br /> 3/30/2016. Similar to the previous year results, copper was found to be greater than ten times the <br /> STLC limit. All other analytes were below limits on the CAM 17. An additional test was <br /> conducted on 4/8/2016. This is an STLC test for copper. The test shows copper at 5.1 mg/1 which <br /> is below the threshold limit of 25 mg/1 for this analyte. <br /> We ship our filter cakes as non-hazardous on the basis of these test results. <br /> Reference Item 406 of the Notice to Comply. <br /> I attach a Bill of Lading, Invoice#064813, dated 4/19/2016. It documents the shipment of the <br /> four drums brought to question in this Item of the Notice. <br /> I also attach a refresher training record for our Employee with the duty of inspecting the waste <br /> storage area and its log. <br /> Reference Item 608 of the Notice to Comply <br /> Refer to the same Bill of Lading cited above for Item 406, Invoice#064813, dated 4/19/2016. It <br /> documents the shipment of the drained oil filters identified in the Notice. <br /> I also attach a refresher training record for our Employee with the duty of inspecting the waste <br /> storage area and its log. <br /> Enclosures: <br /> Return To Compliance Certification <br /> Selected(Training)Records Between Dates <br /> Analytical Report, 1503989,3/30/2015 <br /> Analytical Report, 1503989 A,4/13/2015 <br /> Analytical Report 1603C72,3/30/2016 <br /> Analytical Report 1603C72 A,4/8/2016 <br /> Bill Of Lading Invoice#064813 <br />