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RECEIVED VIA EMAIL ON 09/24/2021 <br />RCRA Large Quantity Hazardous Waste Generator Inspection Report Violations Response <br />Heartland Steel 214 S Kelly St. Lodi CA <br />Violation <br />Item #102, CCR 66262.11: Failed to <br />determine if a waste is a hazardous waste. <br />OBSERVATIONS: Hazardous waste <br />determinations are needed for the following <br />items: <br />-powder coat stored south of Bay 1. The <br />following 250 pound containers of powder <br />coat were observed: 21 of Excel <br />Blue, 8 of Lozier Yellow, 6 of Sahara Tan, 6 of <br />HB2 Blue, 4 of Forest Green, 1 of Muslin <br />Biege, 8 of Unicor Gray, 6 <br />of Hannibal Orange, 8 of Lozier Gray, 10 of <br />Excel Ultra Orange, 6 of SR153 Blue, 6 of <br />Deco Green, and 2 of Vista <br />Green. <br />-approximately 300-400 used powder coat <br />filters stored in Bay 8 <br />-3 containers of oily booms & rags stored <br />north of Bay 4 <br />-1 half full 55 -gallon drum of metal grindings <br />stored south of Bay 1 <br />Response <br />TGIC powder coat paint will be disposed of as <br />hazardous waste at the rate of 10 barrels per <br />pickup. This is roughly 2,500 pounds disposed <br />of every 90 days. This violation will remain <br />open until all barrels have been disposed of. <br />Please provide the EHD with copies of the <br />manifest. <br />(We will continue to keep the EHD updated <br />as the material is sent off) <br />Contacted manufacture of the cartridge paint <br />filters and inquired about disposable process <br />of the filters. The filters themselves do not <br />process any hazardous material and can be <br />thrown away with the general trash. The only <br />other element is the powder coat paint <br />which is also non -hazardous and does not list <br />any hazardous chemicals on the SDS sheets. <br />Provide supporting documents for the <br />hazardous waste determination (ex. SDS <br />sheets) <br />(Attached to the email are the manufacture <br />specifications for the filter product showing <br />what material is used to make the filters) <br />M.L. Winters is Heartland's oil rag and oil <br />boom service cleaner. M.L. <br />Winters provides reusable geotextile rags <br />which is cleaned through a special process. <br />This does not constitute as hazardous waste <br />according to (Article 4. Section 25144.6 of <br />Health and Safety Code.) Provide the name <br />and address of the service cleaner along with <br />receipts. <br />(Attached is an invoice from 2019, Heartland <br />does not generate large quantities of oil rags <br />and booms. The yare only used for forklift <br />maintenance which does not happen very <br />often.) <br />The half full 55 -gallon drum as be <br />repositioned to the hazardous waste shed <br />and labeled accordingly. Provide a photo of <br />the drum and label. <br />