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Michelle Henry <br /> May 21, 2015 <br /> Page 4 <br /> All employees have been trained on hazardous materials and hazardous waste <br /> management. Compliance training is conducted annually. On January 5,2015,all <br /> employees received detailed training on the proper handling and disposal of hazardous <br /> materials. Attendance logs for this training session are enclosed as Attachment E. <br /> Item No. 202: HSC 25189.5(a). Disposed or caused disposal of HW at an unauthorized <br /> point. <br /> • Envirobase High Performance ECH7080,flashpoint 104F <br /> and EC700,flashpoint 76 F with pourable amounts were found in the trash can in € <br /> the mixing room. According to an employee onsite, the cans are allowed to air <br /> dry in the trash can. <br /> • Bondo waste analysis submitted to this office June 10, 2013 <br /> had selenium levels at 1.903mg/L and zinc levels at 581 mg& On September 11, <br /> 2013 an email was received by this office with an indication a new product was <br /> being sampled to potentially replace the bondo product, that according to the <br /> analysis submitted, was a hazardous waste when disposed of. Upon reviewing the <br /> file no further information had been received. At time of inspection on October <br /> 23, 2014 the bondo waste was in a hazardous waste drum. It is not clear which <br /> bondo product is being used and when it was first started to be handled as a <br /> hazardous waste. <br /> • Hazardous wastes shall be disposed of only by <br /> transportation to a permitted hazardous waste treatment, storage, and disposal <br /> facility(TSDF). Immediately cease disposal of hazardous waste to the trash and <br /> ensure that all future waste is hauled by a licensed hazardous waste transporter <br /> to a permitted TSDF. Class I violation. <br /> Response to Item No.202: <br /> Pourable amounts of Envirobase High Performance ECH7080 and EC700 are used in <br /> operations and,therefore, are not waste. Any amount of paint that is not used in <br /> operations is collected in 55-gallon drums designated for collection of waste paint. Once <br /> waste paint is poured from the paint container into the 55-gallon drum designated for <br /> waste paint,the empty paint container is immediately placed into a closed drum for <br /> removal by Corrick Enviro Services,Inc. Cooks Collision has contracted with Corrick <br /> Enviro Services,Inc, to ensure full compliance with proper handling of all paint <br /> containers. <br /> Regardless of the bondo product used at the facility, Cooks Collision manages all bondo <br /> dust as hazardous waste. All employees have been trained to manage bondo dust as € <br /> hazardous waste. (Please see Attachment E.) Accordingly,the May 28,2013,waste <br /> characterization for bondo dust,which we submitted to your office in 2013,is the most h <br /> current waste analysis conducted by Cooks Collision for bondo dust for this facility. <br /> u <br /> Supplemental Response to Item No. 202: <br /> 2990 Lava Ridge Court,Suite 190 <br /> Roseville,CA 95661 fi <br /> Phone 916-786-2943 Fax 916-786-2992 <br /> www.cookscollision.com <br />