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Stockton Propeller, Inc., OCI Case #15242 <br /> Date Samples Collected: June 3, 2021 <br /> Sample SP-04A exceeds the TTLC for chromium and chromium VI, and the STLC for antimony, <br /> cadmium, and chromium. Pursuant to California Code of Regulations, title 22, section <br /> 66261.24(a)(2), this sample exhibits the characteristic of toxicity. <br /> It should be noted that the results were out of holding time, however, the results still exceed the <br /> thresholds for chromium V1 using the EPA 7199 standard. Chromium VI concentrations would be <br /> expected to decrease over time as there are many more pathways for the reduction of chromium <br /> VI to chromium III than there are for the oxidation of chromium III to chromium VI so the value <br /> would be slightly higher if analyzed sooner. However, the concentrations of chromium VI found <br /> in the sample was high enough that the change in concentration would not be expected to be <br /> significant. <br /> The laboratory also analyzed the data as a liquid for both chromium and chromium VI instead of <br /> a solid. Because of this the results are in mg/L (converted from ug/L for chromium VI) and not <br /> mg/kg. Converting the mg/L to mg/kg to compare with the TTLC is approximately 1:1 with the <br /> levels recovered so high the minor difference is a moot point. <br /> Sample SP-04A also exceeds the TCLP concentration for cadmium, and chromium, which <br /> pursuant to California Code of Regulations, title 22, section 66261.24(a)(1)(B), shows the sample <br /> exhibits the RCRA characteristic of toxicity and hence is a RCRA hazardous waste. <br /> The pH for this sample is 2.16 which does not exceed the regulatory threshold. <br /> As noted above, we have not received the laboratory results for Sample SP-04B for neither <br /> cyanide nor the Fish Bioassay, when the results come in and if they are deemed significant, we <br /> will make an addended report. <br /> Sample SP-05A/B: <br /> The samples were collected in the warehouse from an unlabeled, one third full, white poly 55- <br /> gallon container with no top of"Alodine" rinse water solution. M. Belmont and Stockton Propeller, <br /> Inc. staff confirmed that the unlabeled container was another "Alodine" rinse solution. M. Belmont <br /> stated that staff dips metal plane parts in the "Alodine" solution and then into the rinse water to <br /> complete the process. M. Belmont stated that they allow the rinse water to evaporate to dispose <br /> of it and hook up a heating unit to the barrel to accelerate the evaporation. When we were there <br /> the heating unit was attached to this container. The rinse water is a waste because they <br /> evaporate it to dispose of it into the atmosphere <br /> The samples were tested for total metals, WET, TCLP metals, pH, chromium VI, and Fish <br /> Bioassay. <br /> Sample SP-05A exceeds the TTLC for chromium and chromium VI, and the STLC for antimony, <br /> cadmium, and chromium. Pursuant to California Code of Regulations, title 22, section <br /> 66261.24(a)(2), this sample exhibits the characteristic of toxicity. <br /> It should be noted that the results were out of holding time, however, the results still exceed the <br /> thresholds for chromium VI using the EPA 7199 standard. Chromium VI concentrations would be <br /> expected to decrease over time as there are many more pathways for the reduction of chromium <br /> V1 to chromium III than there are for the oxidation of chromium III to chromium VI so the value <br /> would be slightly higher if analyzed sooner. However, the concentrations of chromium VI found <br /> Page: 10 <br />