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The following is an itemized list of hazardous waste violations that have not been <br />addressed for UFP Thornton LLC as of February04, 2021. <br />Open violations from December 03, 2020 inspection <br />Violation #102 -Failed to determine if a waste is a hazardous waste. <br />OBSERVATIONS The facility has a prime line to coat material. Approximately 3-4 times a month, the facility will <br />run a line containing "Waterguard for Exterior Wood." The colors used for the line can be white, brown, or grey. <br />The safety data sheet (SDS) information for the colors list chlorothalonil as one of the ingredients. The SDS shows <br />that chlorothalonil has an acute LC50 of 17.1 micrograms for the 96 hour exposure test using Oncorhynchus <br />mykiss. <br />After a production run has been completed, the line is flushed out using water, and is mixed with wood chips to <br />absorb the waste water. Once the wood chips have dried, the waste is thrown into the trash. Any residue that <br />hardens on the production line, is also thrown into the trash. <br />REGULATION GUIDANCE: Any person who generates a waste shall determine if the waste is a hazardous waste <br />as specified in Title 22 California Code of Regulations (CCR). There are wastes that are listed as hazardous <br />wastes. There are wastes that exhibit one or more of the hazardous waste characteristics: toxic, corrosive, reactive <br />or ignitable. <br />Title 22 CCR section 66261.2 —Definition of Waste <br />Title 22 CCR section 66261.3 —Definition of Hazardous Waste <br />CORRECTIVE ACTION: Immediately cease disposal, make a hazardous waste determination for the "Waterguard <br />for Exterior Wood;' and manage it according to Title 22 CCR. Use Safety Data Sheets (SDS), waste sampling and <br />test results or other knowledge to support your hazardous waste determination. Waste testing must be done using <br />methods specified in Title 22 CCR including sections 66261.20-24. <br />Submit a statement and supporting documentation with your hazardous waste determination. Demonstrate current <br />storage and labeling for wastes determined to be hazardous wastes. Provide disposal records for wastes <br />determined to be hazardous wastes and stored longer than the number of days specified in Title 22 CCR for your <br />hazardous waste generator status. <br />❑ This violation was corrected <br />❑ Supporting documents included <br />❑ This violation will be corrected by (date): <br />Describe actions taken or will be taken to correct violation: <br />Page 1 of 6 <br />