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01/09/2015 17 : 26 From : Cooks Coll Jennifer Hartman ]Sing Page : 417 <br /> Michelle Henry <br /> January 9,2015 <br /> Page 3 *LIVE � <br /> JAN 12 2015 <br /> Response to Item No. 105: U�( �NMEN-`Q� <br /> All employees have been trained on hazardous materials and hazardous waste N-V@ <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(x). Disposed or caused disposal of HPV at an unauthorized <br /> point. <br /> • Envirobase High Performance ECH7080,flashpoint 104F and EC700,flashpoint <br /> 76 F'with pourable amounts were found in the trash can in the miring room. <br /> According to an employee onsite, the cans are allowed to air dry in the trash can. <br /> • Rondo waste analysis submitted to this office.hme 10, 2013 had selenium levels at <br /> 1.903rng/L and zinc levels at 581 mg/L. On September 11, 2013 all entail was <br /> received by this office with an indication a nets,product was being sampled to <br /> potentially replace the bondo product, That according to the analysis submitted, <br /> was a hazardous►+,aste when disposed of. Upon reviewing the file no further <br /> information had been received. At time of inspection on October 23, 2014 the <br /> bondo waste was in a hazar-dotts>vaste dru»r. It is not clear which bondo product <br /> is being used and when it was first started to be handled as a hazardous waste. <br /> • Hazardous wastes shall be disposed of only by transportation to a permitted <br /> hazardous waste treatment, storage, and disposal facility(TSDF). Immediately <br /> cease disposal of hazardous waste to the trash and ensure that all ftttrrre waste is <br /> hauled by a licensed hazardous waste transporter to a permitted 1S'DF. Class 1 <br /> 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%ve submitted to your office in 2013,is the most <br /> current waste analysis conducted by Cooks Collision for bondo dust for this facility. <br /> Item No. 204: HSC 25201(a), Failed to obtain a permit to treat hazardous waste. _ <br /> Envirobase High Performance ECH7080,flashpoint 104 F and EC700,flashpoint 76 F <br /> with pourable amounts werefound in the trash can in the mixing room. According to an <br /> 00015773.3 <br />