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- 2 - <br /> 3. "At the time of inspection, 5 waste oil drums did not have <br /> labels or accumulation start dates." This is true. After <br /> the inspection, we purchased the labels, filled them out <br /> and labelled each barrel to comply. We will continue to <br /> do so in the future. <br /> 4. "One used solvent parts cleaner drum was not labelled." We <br /> believe that the reool-t is referring to a half barrel which <br /> was split from top to bottom and made into a portable parts <br /> cleaner. Unfortunately, a picture was not available to <br /> verify this fact. A portable parts cleaner is used for <br /> machinery overhauls on location in the Plant. Since this is <br /> a portable parts cleaning station, which is normally emptied <br /> after each use, we feel it is exempt from the requirement <br /> of a "hazardous waste" label. However, if you wish, we will <br /> label it. <br /> 5. "At the time of inspection, Bulk Transport bin for zinc <br /> phosphate had no hazardous waste label." It is true that our <br /> zinc phosphate bin had no hazardous waste label. The bin is, <br /> however, labelled "CORROSIVE" by the Dept. of Transportation, <br /> (D.O.T. ) . We believe that the zinc phosphate is not a <br /> hazardous waste because, it does not meet the definition of <br /> a waste per the California Health and Safety Code Section 25124. <br /> I have attached a copy of the Health and Safety Code Section <br /> 25124 for your reference. (Attachment 1) <br /> The zinc phosphate, which is in the container, is sold as an <br /> ingredient for fertilizer. It is not a waste. It is not <br /> discarded, abandoned, recycled, mislabelled, or packaged in <br /> deteriorated or damaged containers. <br /> The zinc phosphate is stored in a Department of Transportation <br /> approved container, which is properly stickered as a "CORROSIVE". <br /> It is used in a fertilizer in which the zinc, iron and inert <br /> materials are essential ingredients. It is stored in the <br /> approved container until it is shipped for use in the fertilizer. <br /> The zinc phosphate is completely consumed in the fertilizer. <br /> Thus, we at SWPC, feel that the zinc phosphate is a useful <br /> by-product and not a hazardous waste. We feel that the <br /> container is properly labelled. <br />