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WASTE MANAGEMENT PROCEDURE NexFrame 4819 Fite Court Stockton, CA 95215 2/8/2008 Background NexFrame manufactures prefabricated galvanized sheet steel residential and commercial building components including wall panels,trusses and floor systems. These components are fabricated from coils of flat galvanized sheet steel ranging in thicknesses from 18 to 24 gauge. The facility uses numerous computer controlled roll forming systems to generate the various wall panels. Once the galvanized sheet steel coil stock is converted into the desired profile it is cut to the correct length by a metal shear on the roll forming equipment. The roll forming operation is accomplished with a series of sequential metal forming dies in the roll former that converts galvanized sheet steel flat stock into the final stud configuration. During the fabrication of the roll formed components,holes are punched into the studs for the passage of wet and dry utilities including electrical,plumbing, and data services. The amount of material removed is a small percentage of the total metal roll formed into the fabricated element, and is collected at each machine. Facility cleanliness and safety are maintained with the use of a self powered sweeper. In addition to removing particulates from the facility floor the sweeper utilizes a fine water spray to control surface dust and facilitate surface cleaning. The periodic sweeping results in the collection of water and particulates, which are removed from the sweeper and transferred to a storage container. Approximately 30 gallons of sweeper residue is generated each month, consisting of 80%water and 20%metal bearing sludge. Laboratory analysis of the sweeper residue(see attached)established that the liquid phase of the sweeper residue is not a hazardous waste/material. The sludge phase consists of settled metal particles. The City of Stockton Municipal Utilities Department(MUD)was contacted to determine if the clear water could be discharged to the City's sanitary sewer. Although the decanted clear water was chemically analyzed and determined to fall within the MUD's discharge requirements the MUD staff declined to permit the discharge of the water to the Sanitary Sewer System. The MUD staff accepted the disposal concept of having the clear sweeper residue water transported from the site as a non-hazardous material for subsequent disposal. The metal bearing particulate sludge is removed from the settling container and allowed to air dry. After sufficient drying the metal particulates will be added to the generated process scrap metal for recycling and reuse. -1-