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4EGEIVE& Michelle Henry JAN 1 January 9,2015 2 2015 Page 3 [AVI O rCN A Response to Item No. 105: All employees have been trained on hazardous materials and hazardous waste management. Compliance training is conducted annually. On January 5,2015,all employees received detailed training on the proper handling and disposal of hazardous materials. Attendance logs for this training session are enclosed as Attachment E. Item No. 202: HSC 25189.5(a). Disposed or caused disposal of HW at an unauthorized point. • Envirobase High Perfortnance ECH7080,flashpoint 104F and EC700,flashpoint 76 F tivith pourable amounts there found in the trash can in the mixing room. According to an employee onsite, the cans are allo►ved to air dry in the trash can. • Bondo waste analysis submitted to this office June 10, 2013 had selenium levels at 1.903mg/L and zinc levels at 581 mg/L. On September 11, 2013 an email ivas received by this office with an indication a nein product ir�as being sampled to potentially replace the bondo product, that according to the analysis submitted, was a hazardous tivaste when disposed of. Upon revietiving the file no fin•ther information had been received. At tune of inspection on October 23, 2014 the bondo waste was in a hazardous►waste drian. It is not clear which bondo product is being used and when it)vas first slat-led to be handled as a hazardous tivaste. • Hazardous tivastes shall be disposed of only by transportation to a permitted hazardous tivaste treatment, storage, and disposal facility(TSDF). Immediately cease disposal of hazardous tivasle to the trash and ensure that all f:r!►rre waste is hauled by a licensed hazardous tivaste transporter to a permitted TSDF. Class 1 violation. Response to Item No.202: Pourable amounts of Envirobase High Performance ECH7080 and EC700 are used in operations and, therefore, are not waste. Any amount of paint that is not used in operations is collected in 55-gallon drums designated for collection of waste paint. Once waste paint is poured from the paint container into the 55-gallon drum designated for waste paint,the empty paint container is immediately placed into a closed drum for removal by Corrick Enviro Services, Inc. Cooks Collision has contracted with Corrick Enviro Services, Inc. to ensure full compliance with proper handling of all paint containers. Regardless of the bondo product used at the facility, Cooks Collision manages all bondo dust as hazardous waste. All employees have been trained to manage bondo dust as hazardous waste. (Please see Attachment E.) Accordingly, the May 28, 2013, waste characterization for bondo dust, which we submitted to your office in 2013,is the most current waste analysis conducted by Cooks Collision for bondo dust for this facility. Item No. 204: HSC 25201(a). Failed to obtain a permit to treat hazardous tivaste. Envirobase High Pe►formance ECH7080,flashpoint 104 F and EC700,flashpoint 76 F with pourable amounts ivere found in the trash can in the mixing room. According to an 00015773.3