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M11 <br />MASONITC. <br />October 3, 2017 <br />Stacy Rivera, <br />Senior REHS <br />San Joaquin County <br />Environmental Health Department <br />1868 East Hazelton Avenue, Stockton, California 95205-6232 <br />RE: September 7, 2017 Inspection Response & Certification of Compliance <br />Facility: Masonite Corporation <br />Address: 433 W. Scotts Avenue, Stockton, CA 95203 <br />CERS ID: 10183255 <br />Dear Ms. Rivera: <br />This correspondence constitutes Masonite Corporation's formal response to issues cited in <br />the inspection report issued to the above facility on 9/07/17. Per the request listed in the <br />Report instructions, please find below a written description of each item and Masonite's <br />response and corrective actions taken to correct and prevent recurrence. <br />102 CCR 66262.11 Failed to determine if a waste is a hazardous waste <br />A. Metal grindings generated from cutting of steel are being recycled as scrap metal <br />without first determining particle size or hazardous properties. Any person who <br />generates a waste shall determine if the waste is a hazardous waste. <br />Corrective Action: <br />Masonite stopped recycling the metal while a waste profile was confirmed with <br />Safety Kleen, a licensed waste management company. A waste collection container <br />with proper labeling has been established. Masonite is managing the metal <br />according to the waste regulations. The Waste Profile is attached. <br />B. The waste glue and glue drips in the facility are being managed as non -hazardous <br />waste. However, the spilled glue is being rinsed into a containment pit and the pit <br />water is being managed as hazardous waste. Any person who generates a waste <br />shall determine if the waste is a hazardous waste. <br />Response, <br />The drum of waste glue, the inspector questioned only contains the water based <br />PVA glue ... which by itself is non -hazardous. It's not contaminated with oily water <br />such as the glue which is rinsed into the containment pit and shipped out as <br />hazardous. Attached is the Safety Data Sheet for the PVA adhesive confirming the <br />non -hazardous characteristics. <br />104 CCR 66262.34(d)(2) No modified contingency plan. <br />An emergency coordinator and modified contingency plan information is lacking. There <br />must be at least one emergency coordinator on site or on call to coordinate emergency <br />response measures, and the following information must be posted by a phone: the name <br />and phone number of the emergency coordinator; location of fire extinguishers, spill control <br />equipment, and if present, fire alarm; and the phone number of the fire department, unless <br />masonite.com Open to extraordinary. <br />