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1Ui20i1993 15: 18 FROM R. U. CIRCUITS, INC. TO 14159u27372 P.01 <br /> ZU'd 1tl104 ., __________________'_ <br /> 4L 4-1 <br /> t <br /> �1 METAL FINISHING CONSULTING SERVICES <br /> Iy <br /> 1733 S street <br /> Sacramento California 95814 �. <br /> ( 916 ) 442 6453 <br /> Oct . 20 , 1993 <br /> To: Art Smith <br /> :From: D. A. Nola <br /> Subject : Hazardous Materials Storage and Reuse of Containers . <br /> 1 . During your recent inspection by the San .Joaquin County <br /> Environmental Health Department two issues of concern were expressed <br /> by the agency . One was the distance from the property line for <br /> storage of hazardous materials . The other was the storage of waste <br /> in a container that formerly contained an incompatible material . <br /> 2 . In the California Code of Regulations Title 22 , Division 4 . 5 , <br /> Section 66264 . 176 it states that Ignitable or Reactive materials <br /> must not be store within 50 feet of the property line . Most of the <br /> materials on your premises are aqueous solution , caustics , acids , I <br /> and metals . None of those materials would be classified as ignitable <br /> or reactive . You do have some organic materials most of which do not <br /> have a flash point below 140° F. The only materials that you may have <br /> that Could be classified as ignitable are small quantities of <br /> solvents . Some oxidizers can be classified as reactive ; however , the <br /> small quantities you have on hand would not fall under that <br /> classification . Unless there is a local or county requirement that <br /> supersedes the state rcgulatlons , it does not appear that the 50 <br /> feet limit applies to your facility . <br /> 3. The handling of containers and co-mingling of hazardous materials <br /> are covered in sections 66261 . 7 , 66264 . 17 , and 66264 .177 . Reuse of <br /> containers is allowed as long as the requirements specified in those <br /> sections are met . In your situation as long as the containers are <br /> properly rinsed they can be roused for containing a material <br /> incompatible with the former material . I highly recommend that this <br /> practice not be used even though it is allowed . The only time you <br /> might consider doing this is in an emergency situation. Whenever a <br /> container is emptied it is always good practice immediately triple <br /> rinse the container and remove the former label . It the Container is <br /> to be reused , it must be properly labeled . <br /> CK <br /> //�; � 4.Q�t1V IR0NMEhrH <br /> D. A. Mole , Chemist , REA <br /> w <br /> a No. 04o43 a <br /> * EnplrC$_ (3-.3x94 <br /> S <br /> r�7c .i.P <br /> TOTAL P. 01 <br />