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1 <br />Christine Lawrence <br />From:Christine Lawrence <br />Sent:Tuesday, September 17, 2019 1:32 PM <br />To:'R and J Dondero Inc' <br />Subject:RE: Todays Training <br />Hello Cindy, <br /> <br />I do not see the names of the mechanics listed on this training record. I am looking for training in hazardous waste <br />management, and not just spill response. The spill response is important for the hazardous materials business plan but <br />as a hazardous waste generator, your mechanics, those who are dealing with the used oil, oil filters, metal fines, etc <br />need to be trained. I don’t see that happening at R and J Dondero. I recommend sending the shop staff to one of our <br />NES classes here at the EHD. You can sign them up here. I recommend the Basic Hazardous Waste Management (10/8, <br />11/19, 12/3) or the Auto Industry Hazardous Waste Management (no more offerings in 2019). <br /> <br />I am unclear on how the spilled oil is being managed. Is the spill being covered in kitty litter and then put into the used <br />oil tank? Or is there a separate drum for oily solids? You stated previously in an email from 9/4/19 ,“ Vince said that both <br />of these [metal fines and oil spills] are non-hazardous materials. He said it is food grade oil, and he said the metal <br />shavings are also non-hazardous. They are disposed of in the trash.” Then in an email from 9/10, you stated “they are <br />treating the metal shavings as hazardous waste and set a waste bucket up for it and then when it is full we will have it <br />properly disposed of”, and again on 9/12, “ It is all handled as hazardous, and they put it into the hazardous waste <br />container.” <br /> <br />The metal shavings: If they are >100 microns in size and are recycled (taken as scrap metal), you may continue to store <br />the metal fines in the bucket as you are now. If the metal fines are truly handled as hazardous waste and they are <br />disposed of on a manifest, then the container must have a hazardous waste label. You must also submit disposal records <br />to the EHD to close the present violation, as there is a time limit for the accumulation of hazardous waste, and it cannot <br />be determined how long the waste has been on site. <br />The spills: If a spill is of a hazardous material and it is cleaned up using absorbent, rags, etc, then the absorbent and rags <br />must be handled as hazardous. Rags soaked in hazardous waste like used oil may be rung out into the hazardous waste <br />container and commercially laundered, or they may be disposed of as hazardous waste and stored in an appropriate <br />container with a hazardous waste label. The same for absorbent materials, if hazardous they must be stored in an <br />appropriate container and labeled accordingly. If a waste is non-hazardous then you may take more liberties in the <br />method of disposal but a determination must first be made whether or not the waste is hazardous. <br /> <br />I hope I have provided some clarification in these matters. If you have any questions, please contact me at (209) 468- <br />3562. <br /> <br />Thank you, <br />Christine Lawrence <br /> <br /> <br />From: R and J Dondero Inc <rjdonderoinc@msn.com> <br />Sent: Tuesday, September 17, 2019 8:56 AM <br />To: Christine Lawrence <clawrence@sjgov.org> <br />Subject: Todays Training <br /> <br />Hi Christine, <br />Here is todays training record.