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STATE OF CALIFORNIA—HEALTH AND WELFARE AGENCY GEORGE DEUKMEJIAN, Gorornor DEPARTMENT OF HEALTH SERVICES TOXIC SUBSTANCES CONTROL DIVISION ; NORTHERN CALIFORNIA SECTION July 12 , 1985 4250 POWER INN ROAD SACRAMENTO,CA 95826 (916) 739-3145 r � � JUL 16 1985 Mr. Michael McAlexander ENVIRUMEvTAL HEALTH Luster-Cal Nameplate Corporation FERMIT/SERVICES P.O. Box 439 Lodi , California 95240 Dear Mr. McAlexander : LUSTER-CAL NAMEPLATE CORPORATION, VARIANCE DETERMINATION TO CONTINUE DISCHARGING HAZARDOUS WASTE INTO THE SEWER SYSTEM On March 13 , 1985 , you applied to this Department for a variance from the Hazardous Waste Facility Permit requirements in Chapter 30 , Division 4 , Title 22 , California Administrative Code (CAC) . A review of your application and an inspection of your facility indicated the following: Luster-Cal manufactures nameplates and labels of anodized aluminum. Chemicals used in this process are NaOH, ammonium bifluoride, 1,1,1- trichloroethane, and resins . The sheets of aluminum are etched in a caustic soda bath and, in some instances, an ammonium bifluoride bath. The spent NaOH solution is discharged to the sewer system at the rate of approximately 40 gallonq4aeek. Drag out goes into an open drain and ultimately into the sewer system. The 1 , 1 , 1- trichloroethane is recycled on-site and the sludge is sent to a Class I disposal site. The City of Lodi has Luster-Cal on a Pre-treatment Program with semi-annual monitoring of their effluent. Results from the analysis of cadmium, copper, chromium, lead, nickel, silver, zinc, cyanide in August, 1984 and March, 1985 are well within the PSES discharge requirements. Based upon these findings and pursuant to Section 25143 , Health and Safety Code and Section 66310 , Title 22, CAC, we find that the NaOH and ammonium bifluoride currently being discharged into the sewer system are being disposed of pursuant to the regulations of the City of Lodi in a manner which is consistent with the Hazardous Waste Management Provisions of this Chapter and which will not result in a hazard to human health and safety, livestock or wildlife. Therefore, you are granted a variance from the Hazardous Waste Facility Permit requirements of the CAC to continue discharging the NaOH and ammonium bifluoride baths to the sewer system.