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HOLT of California Notice of Processing Hazardous Waste Aerosol Cans Holt of California located at 1521 W. Charter Way, Stockton, CA (EPA # CAL000827892) is dedicated to the proper handling of all our waste streams in acc- ordance with federal, state, and local regulations. This notification is to confirm that as a generator, our aerosol can process is in compliance. Using the California H&S Code Section 25201.16, CCR Title 22, and the fact sheet from the DTSC on Senate Bill 1158 our process was developed. Knowing that certain hazardous wastes which are commonly generated that pose a relative lower risk to people and the environment than other hazardous waste, "universal wastes are regulated based on a relaxed set of standards" more appropriate to the specific hazard they pose. SB 1158 Section 25201.16 made processing hazardous waste aerosol cans a universal waste handler activity. The following is an account of our "aerosol can processing." • Deeming an aerosol can a waste: At the time a Holt of California employee has determined that one of the criteria in H&S Code25201.16 (2)(A) occurs, we now have a hazardous waste. • Estimated volumes: Due to the fluctuation in market share that Holt represents, and our recycling efforts, the amount of waste we generate has declined. With that said, a conservative estimate would be: 8-15 cases a month (calculated @ 12 cans per case). This waste is accumulated at or near the point of generation for not more than one year. For that duration, on average, we have not exceeded one foot in a 55 drum that we have had Asbury haul off and recycle. • Management of hazardous residuals: We used appendix V, CCR Title 22 division 4.5, chapter 14, MSDS of all aerosols', and our environmental consultants from HDR & NES for guidance on incompatible wastes. The types of product propelled -form aerosol cans are: paints, adhesives, cleaners, and lubricants. We have a strong understanding of the consequences with regards to the interactions of incompatible chemicals and this is our basis for establishing proper chemical handling procedures. The product line we represent has no chemical which can be propelled from an aerosol can that is incompatible once comingled that would have a reaction nether mild- or violent, immediate or delayed, generation of heat, toxic gas, pressure, fire, explosion, toxic by product or the solubilization of a toxic substance. DeMenno/ Kerdoon in Compton, CA is the destination facility: EPA ID # CAT080013352. This waste is recycled, waste code: H061. • Equipment description: The manufacture of the three can puncture station is AeroVent3. It mounts via a two inch steel pipe bung to a UL listed drum provided by contracted hauler. • Management of containers: This applies to both the container holding the aerosol cans and the container holding the residue post puncturing the can. Holt of California follows Title 22 subsection 66265.173 and those of H&S 25201.16 P.O. Box X• Sacramento, CA 95813-1306.7310 Pacific Avenue • Pleasant Grove, CA 95668-9708 • (916) 991-8200 • (800) 452-5888 Toll Free • (916) 991-8290 Fax