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Alaniz, John [EHD] From: Robert Job <rjob@condorearth.com> Sent: Thursday, April 1, 2021 6:42 PM To: Alaniz, John [EHD] Cc: Joel McDonald; Mills, Michael; Henry, Michelle D [EHD]; Backus, Garrett [EHD];Jordan Johnson Subject: RE: Second out of compliance letter-EHD Attachments: Quest analytical.pdf, Clean Harbors pickup confirmation.pdf; IMG_0695 jpg CAUTION:This email is originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Good Afternoon John, We are providing you a progress update on behalf of Joel MacDonald at Quest Industries regarding the corrections made at the Stockton facility.This update follows the format of your March 8, 2021 email, but updates are provided only for those violations you indicated remain open. VIOLATION 102- Waste determination and reclaimed paint management: Additional analysis of waste materials was completed on March 19, 2021. Five waste streams were tested including the two types of filter media, solids, and the two types of liquid paint waste. Individual samples were selected from various containers in each waste stream and composited at the laboratory. Composite samples were used to provide data that was more representative of the overall waste stream. Analytical results for each waste stream have been included for your reference. In brief: • Liquid paint waste totes (1,2,3) sample data supports a non-hazardous determination (non-regulated material). • Liquid paint waste totes (4,5,6) sample data supports a non-hazardous determination (non-regulated material). • Solids paint waste box containers (1,2,3) sample data supports a non-RCRA hazardous waste determination. • GCC filter media (1,2,3)sample data supports a non-RCRA hazardous waste determination (GCC is a designation to indicate the manufacturer of the paint). • VNR filter media (1,2,3) sample data supports a non-RCRA hazardous waste determination (VNR is a designation to indicate the manufacturer of the paint). Waste profiles for these waste streams are being prepared to reflect these recent analyses. In anticipation that they will be approved by Clean Harbors, Clean Harbors has scheduled the pickup of wastes from Quest.The earliest the pickup can occur is April 21, 2021.A copy of the scheduled pickup confirmation from Clean Harbors is included for your reference. Documentation records of the transportation and disposal of these wastes will be provided after shipment and disposal. As previously reported, Quest is developing procedures for managing reclaimed solid paint material. Quest is currently labelling the reclaimed paint containers with the date collected and contents and developing a tracking system. VIOLATION 117—hazardous waste training: Quest staff have signed up for the April 6 hazardous waste training provided by San Joaquin County. Upon completion, the training form included with the inspection report will be filled out and provided to the County. VIOLATION 201—filter waste disposal: See response to Violation 102. Filter media is scheduled for pickup on April 21, 2021 for disposal as a non-RCRA hazardous waste. Quest is developing procedures to track waste generation. VIOLATION 202—soil cleanup: See SOIL CLEANUP paragraph near the end of this email update.