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—3— May 13,2004 #88 Used oil filter drum in the satellite accumulation area did not have a proper accumulation start date. Item has been corrected. HSC 25201.16 If this facility continues to process aerosol cans it should comply with the referenced HSC. As recommended we will begin handling used aerosol cans as Universal Waste. CCR 66262.23 Generator must retain 2 copies of manifests generated at the facility. Item has been corrected. CCR 66262.23 Within 30 days of a hazardous waste shipment a manifest copy must be submitted to DTSC. In 2002 required copies were not sent to DTSC. As previously stated in item #27 & 30 above there was no manifested waste removed from this facility in 2002. Proper handling of future DTSC manifest copies has been implemented. #4&6 Waste wax is currently being transported and disposed of as non- hazardous waste to an unauthorized facility. According to a MSDS provided the wax is classified, as an oil product therefore should be handled according to hazardous waste laws and regulations. Begin immediately handling waste wax as a hazardous waste. Facility claims waste wax is excluded as a hazardous waste however HSC section 25143.2(e)(3) considers this waste hazardous. In correspondence with Charles Corcoran, Chief of the Waste Identification and Recycling Section of the Department of Toxic Substance Control, he states that while the waste wax does not qualify under any exclusion it is incorrect to consider it a hazardous waste simply because it contains petroleum substances. Mr. Corcoran, see attached, says that to be identified as a hazardous waste, the wax would have to exhibit at least one federal or state characteristic of a hazardous waste, or be/contain a listed hazardous waste. It is our contention that the waste wax is not a hazardous waste because it is not a federally fisted hazardous waste and it does not exhibit the characteristics of ignitability, reactivity, corrosivity or toxicity. Therefore our present method of transport and disposal of the wax for fuel blend is authorized and appropriate.