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40 Page 1 of 1 <br /> Aris Cacapit [EH] <br /> From: Rick Daudert[RDaudert@wastequip.com] <br /> Sent: Thursday, September 08, 2011 12:03 PM <br /> To: Aris Cacapit[EH] <br /> Subject: Wastequip Inspection 9/7/2011 -Found this for U listed wastes <br /> Aris, <br /> Per our conversations I was doing some additional research and I found this (copied directly from <br /> http://www.fedcenter.gov/resources/facility_tour/hazardous/whatis/flowchart/#steo3) <br /> o P- and U-listed wastes: These two lists designate certain commercial chemical products as <br /> hazardous when disposed of unused. These unused chemicals may become wastes in a number <br /> of ways. Some can be spilled while in use while others can be intentionally discarded if out of <br /> specification. For a waste to qualify as a P- or U-listed waste, it must meet all three of the <br /> following criteria: <br /> ■ The formulation must contain at least one chemical on the P or U list <br /> ■ The chemical in the waste must be unused <br /> ■ The chemical in the waste must be in the form of a CCP. <br /> *A CCP is a chemical that is of technical(commercial) grade, 100% pure, and the only <br /> active ingredient in the formulation. <br /> There are hundreds of P- and U-listed wastes. Facility managers should look in 40 CFR 261.33 to see if <br /> chemicals present on-site are hazardous if disposed of unused. Please note that the chemicals with the <br /> "P" code are acutely hazardous. Generators with acutely hazardous waste are subject to different <br /> accumulation limits for those wastes. <br /> My interpretation of the above is since the U listed waste is use it is not applicable to the U list. Acetone is used <br /> as a line flush and then the line flush is added to the primer as a thinning agent(as discussed during our call). In <br /> addition, other materials in the analysis that may be in question are not CCP; they are components/mixtures <br /> within the paint formulation. <br /> I hope that this is helpful information for your internal discussions. <br /> Also thank you for your time today and all your information, very helpful. <br /> Regards, <br /> RICK DAUDERT <br /> Environmental Health and Safety <br /> Wastequip,Inc. <br /> Nationally Known for Personal Service <br /> Direct:773-569-7662 <br /> Fax: 773-409-8957 <br /> www.wastecuio.00m <br /> NOTICE: This e-mail message, including any attachments, is for the sole use of the intended <br /> recipient(s) and may contain confidential or proprietary information. Any unauthorized review, <br /> use, disclosure or distribution is prohibited. If you are not the intended recipient, immediately <br /> contact the sender by reply e-mail and destroy all copies of the original message. <br /> Twill <br /> ri <br /> SEP 08 2011 <br /> SAN JOAQUIN COUNTY <br /> 9/8/2011 ENVIRONMENTAL <br /> HEALTH DEPARTMENT <br />