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Backus, Garrett [EHD] From: Backus, Garrett [EHD] Sent: Monday, May 17, 2021 7:41 AM To: 'Adalberto Cuevas' Cc: Manzo, Elena K. [EHD] Subject: RE: metals analysis - Eclipse metal fab Attachments: STK2134667rptSub1-2000014.pdf Hi Al, After receiving the attached TCLP results: The Sanding / Debur and CNC/Saw waste streams can be recycled as scrap metal. The Laser/NC waste stream is RCRA hazardous waste for chromium since the reporting limit (RDL) is 25 mg/L, which is above the hazardous waste level of 5 mg/L. The ND result only means the waste is no more than 25 mg/L chromium. It is also non-RCRA hazardous waste for copper and nickel. Make sure your hazardous waste hauler uses waste codes D006 (chromium), and 172 (non-RCRA metal dust) on the hazardous waste manifest. Please send back an email describing how the three different waste streams will be handled to close the last open violation for hazardous waste determination. If the Sanding / Debur and CNC/Saw waste is going to a metal recycler then keep receipts showing the name and address of receiving facility. Also provide the name and address of your current metal recycler. Thank you, Garrett Backus, Ld. Sr. REHS, CUPA programs San Joaquin County Environmental Health Department 1868 E Hazelton Ave, Stockton, CA 95205 Desk: (209) 468-2986 Cell: (209) 616-3030 Email: gbackusQsigov.org Free CUPA training classes signup: https://www.sigov.org/department/envhealth/ From: Backus, Garrett [EHD] Sent: Thursday, May 13, 20212:23 PM To: Adalberto Cuevas <al@eclipsemf.com> Cc: Manzo, Elena K. [EHD] <emanzo@sjgov.org>; haztechenv <haztechenv@comcast.net> Subject: RE: metals analysis - Eclipse metal fab Hi Al, From the results provided so far: The Laser/NC waste stream is non-RCRA hazardous waste for copper and nickel and cannot be recycled as scrap metal. It may be RCRA hazardous waste depending on the TCLP results for chromium. The Sanding / Debur waste stream can be recycled as scrap metal.