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APPi07 77��, LIED 3437 South Airport Way AEROSPACE Stockton,, CA 95206 STRUCTURES CORPTl 1�. Tel:209-982-0160 .l Fax:209-983-33753375 November 14, 2013 RECEIVED Stacy Rivera MAY 12 2014 San Joaquin County EHD ENVIRONMENTAL HEALTH Stockton, E. Main Street Stockton, CA 95202-3029 DEPARTMENT RE: CORRECTIVE ACTION Dear Stacy: Per our conversation on Nov. 4, 2013, the following addresses: Item#108, 2.—Failed to determine if a waste is a hazardous waste. In Building 3, items are being moved from one rinse/cleaning tank to another,while dripping in between tanks. Several of the tanks contain a phosphoric acid solution. The liquid is allowed to drip onto the floor under the tanks without additional clean up. The bottom of tank#7 (labeled phosphoric acid anodize 77 f 5°/F), in the basement below the main room, was observed with several accumulation points of a white solid both on and next to the tank. CORRECTIVE ACTION The FPL(Forest Products Laboratory) process of moving parts from one tank to another is a Boeing licensed process. Only tank#7 contained the phosphoric acid solution. The others were the phosphoric acid initial rinse and the phosphoric acid final rinse which only contain water. We must use water to spray rinse the phosphoric acid solution from the parts from the time they are pulled out of the tank until they are placed into the subsequent phosphoric acid rinse tanks to prevent the parts from drying out. The parts must be looked at to ensure a water break free surface. We must also prevent too much rinsing over the phosphoric acid tank to prevent the dilution of the solution. Towards the end of the work day;the area under the tanks will be inspected and cleaned up, if necessary. Any standing accumulation of solution/water will be rinsed to a sump which can then be pumped to our chromium treatment process (operated under Permit By Rule), for pH neutralization, and chromium reduction.