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QUEST INDUSTRIES LLC,2518 E BOEING WAY, CERS ID: 10184627, PR0538472 <br /> Corrective Action Statements <br /> RE: November 04,2020 Hazardous Waste inspection report <br /> Violation 102-Failed to determine if a waste is a hazardous waste. <br /> 0 Corrected <br /> 0 Violation Corrected by: April 15,2021 <br /> 0 Supporting Documents Included(analytical data) <br /> Corrective Action: <br /> i. The powdered paint waste accumulated in the one-cubic yard cardboard boxes stored in Rack 3 <br /> will be managed and disposed of as a non-RCRA hazardous waste based upon generator knowledge <br /> and pending analysis for further characterization. <br /> ii. The twelve 5-gallon buckets containing solid paint waste material have been consolidated with the <br /> contents of the powdered paint waste cardboard containers. Paint waste solids will be disposed of <br /> as a non-RCRA hazardous waste based upon generator knowledge and pending analysis for further <br /> characterization. <br /> iii. Water from the old 55-gallon paint treatment system was consolidated into the liquid paint waste <br /> totes and will be disposed of as a non-RCRA hazardous waste based upon generator knowledge <br /> and pending analysis for further characterization. <br /> iv. Wash water waste was sampled by Clean Harbors on June 23, 2020. The resulting analytical data <br /> (attached) supported a non-hazardous waste determination. Wash water from the 5-gallon buckets <br /> identified in the compressor room has been consolidated into poly totes provided by the waste <br /> hauler. Each tote has an approximate capacity of 300-gallons. As a precaution, the wash water <br /> waste will be disposed of as a non-RCRA hazardous waste by Clean Harbors on a Uniform <br /> Hazardous Waste Manifest,pending further characterization. <br /> V. The seven unlabeled 55-gallon containers with unknown contents have been moved indoors from <br /> the boneyard. Based on generator knowledge of materials used onsite the drums were consolidated <br /> into the liquid paint waste totes to be disposed of as non-RCRA hazardous waste based upon <br /> generator knowledge and pending analysis for further characterization. <br /> vi. The three unlabeled 55-gallon containers of various wastes including filters,gloves and paint solids <br /> observed in the compressor room will be disposed of as non-RCRA hazardous waste based upon <br /> generator knowledge and pending analysis for further characterization. <br /> vii. The 275-gallon unlabeled tote containing liquid paint waste outside the compressor room will be <br /> disposed of as non-RCRA hazardous waste based upon generator knowledge and pending analysis <br /> for further characterization. <br /> viii. The 5-gallon buckets in the conex box contain reclaimed solid paint material to be recycled into <br /> production.Facility personnel working on implementation of a reclaimed paint tracking system by <br /> April 15, 2021. This system will aid Facility personnel in documenting how long the material is <br /> stored onsite before being recycled or becoming a waste.Paint waste will be managed and disposed <br /> of as non-RCRA hazardous waste based upon generator knowledge and pending analysis for further <br /> characterization. <br />