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Backus, Garrett <br /> From: Backus, Garrett <br /> Sent: Monday, March 2, 2020 3:25 PM <br /> To: 'Chris Young' <br /> Cc: Alaniz, John; Henry, Michelle D <br /> Subject: RE: Treatment violation 214 <br /> Attachments: rtc 214 complete packet.pdf, analysis plan with highlights.pdf <br /> Hi Chris, <br /> I have reviewed the attached document received today and need more information to close out violation 214. 1 also <br /> included the waste analysis plan with highlights. <br /> 1. Section 1: Background—In the second paragraph it states that the wastewater generated from tanks A, 1, 3,5, <br /> 12 and 14 are not pumped to the 750 gallon treatment tank. What happens to this waste water? <br /> 2. Section 1: Background - From the SDS sheets, Tank 3,Alumate Etch has a pH of>13.5 and Tank 5, Deoxidizer <br /> 710 has a pH <1.0. These waste waters when disposed of are D002 corrosive wastes. Is the pH adjusted? Add <br /> this information to the waste analysis plan and go to CERS and indicate that the pH is adjusted as part of the PBR <br /> treatment permit. <br /> 3. Section 2: Constituents& Characteristics—in the second paragraph it states that D002 corrosive waste is <br /> sequestered and hauled off site as hazardous waste. Is Alumate Etch and Deoxidizer 710 waste handled this way <br /> or is the pH adjusted on site before discharge to sewer? <br /> 4. Section 2.3: Sample Collection Procedures—second paragraph states that the contents of the tanks are replaced <br /> and transferred to the 750 gallon tank. This seems to contradict information in section 1 and 2. <br /> 5. Process#1—A SDS for CC 50 L was provided and shows this chemical mixture to contain phosphoric acid and <br /> sodium molybdate. The process#1 line is not included in the hazardous waste treatment system but since this <br /> solution is low pH and contains molybdenum,this solution may be a hazardous waste at the point of waste <br /> generation. Please provide hazardous waste determination information for this waste stream. It looks like the <br /> points of waste generation are when the waste water leaves the#2 phosphate tank and the#3 ultraclean <br /> tank. Sampling and analysis for pH and cam 17 may be required at these points to determine if it's hazardous <br /> waste. <br /> Garrett Backus, Ld. Sr. REHS, CUPA programs <br /> San Joaquin County Environmental Health Department <br /> 1868 E Hazelton Ave, Stockton, CA 95205 <br /> (209)468-2986 gbackus(@sjgov.org <br /> https://www.sigov.org/department/envhealth/ <br /> N JOAOUl <br /> r.OUNTY <br /> From: Backus, Garrett <br /> Sent:Thursday, November 21, 2019 3:25 PM <br /> To: 'Chris Young' <chris@premierfinishing.com> <br /> Cc:Alaniz,John <jalanizl@sjgov.org> <br /> Subject:Treatment violation 214 <br /> Hi Chris, <br /> 1 <br />