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Corporate Offfces + 3Potrero Ave D Mo South El CA 1 Phone:626444-9274 Fa:c 526-01-0382 WWW.C2rWnalp21nt.com 13&C Painting Solutions,Inc. 107 Val Dervin Parkway Stockton,CA 95206,US Attn: Nom Lumpkin May 17,2019 To Whom It May Concern: Cardinal Paint&Powder does not intentionally utilize pigments or other ingredients which contain heavy metals listed in 22 CCR 66261.24. I have included a copy of the pertinent language of this regulation for your review. The question as to whether a waste is hazardous involves several issues. First is it a list waste? Federal and State authorities have designated certain materials as hazardous waste per se. If the waste is not listed then you have to ask if it demonstrates the characteristic of a waste. These would be reactive,corrosive,flammable,or toxic. Powder coatings are not reactive,corrosive or flammable. The State of California has developed a list of metals which if present could render the waste hazardous,if not present the waste would not be considered toxic. I am forwarding copies of analysis performed on our powder coatings by an independent laboratory. Ifyou compare the test result with the regulatory limit established in 22 CCR 66261.24 you will find that there are no constituents present that exceed regulatory limits. In cases where a particular constituent shows a result considerably above non detect we have also performed the STLC(soluable threshold limit concentration)analysis. This test result appears at the bottom of the TTLC(total threshold limit concentration)testing. You may notice that barium sulfate has a higher result than other constituents. If you look at 22 CCR 66261.24 the footnote marked+-F you will see that barium sulfate is specifically excluded from barium and or barium compounds. Respite this fact the STLC for barium has been performed and the result is listed at the bottom of the TMC analysis. Barium sulfate has been delisted from the category"barium compounds"on the list of toxic chemicals for which reporting is required under sec.313 of the Emergency Planning and Community RIGHT-TO-KNOW Act of 1986 (EPCRA)since lune 28,1996.40 CFR Part 372. In addition Cardinal has performed a Hazardous Waste Screen Bioassy(CAL)on each series of our powder products. In this analysis the product is fed to fish at various concentrations for various Iengths of time. The results of this analysis show that these coatings caused no death at any of the established intervals. These results show that these coatings are not harmful to aquatic Iife. The test data provided is from 2001. No changes have been made to these formulas since the analysis were conducted. I am including a copy of a recent test performed on powder coating materials contained in our dust collection system. This would be an aggregate of all the coatings we manufacture. The results indicated no California metals present at or + near the regulatory limit. We strongly recommend that you perform similar analysis on the material of which you plan to dispose in order to certify that your waste does not contain heavy metals above the limits established in 22 CCR 66261.24. If you have E any further questions please call me at 626-937-6767. Sincerely l Mike Shirey Laboratory Manager SOUTH F1 MONTE.CA.CITY OF 114DVSTRY,CA .SAN JOSE,CA . PHOENDC AZ .DEVJM CO -HM POINT,NC . WOODINV LLE,WA WARREN,PA . I.AKEMLLE,MN . MARYLAND HEIGHTS.MO .DALLAS,TX.HONG KONG