COMPLIANCE INFO_PRE 2019 - Laserfiche WebLink

Home Browse Search

CARPENTER 6 ENViRONMIENTAL FIE AI-111 preMIT cFFVIr,E 03 JUL 22 PM 12: 29 July 18, 2003 Mr. Raymond Von Flue San Joaquin County Environmental Health Department 304 E. Weber Avenue Stockton, CA 95202 Subject: Toluene Diisocyanate Filter Neutralization Dear Mr. Von Flue: As requested, here is brief procedural information and reasoning for our practice of neutralizing used toluene diisocyanate (TDI) filters. This procedure is utilized in the interest of safety and consists of reacting out the residual TDI on used filters with a solution of 89%water, 10% alcohol and 1% ammonium hydroxide. This reaction produces urea, a non-RCRA hazardous waste. We classify the waste as such (as we believed correct) and send the material offsite to a permitted facility for disposal. This practice eliminates the reaction of TDI with moisture in the air, of which a byproduct is carbon dioxide gas. This gas byproduct, in a sealed waste vessel, will build pressure and create a serious safety hazard. We have reviewed the procedure after your inspection, and although there appear to be grey areas of interpretation here, we have elected to change our procedures out of an abundance of caution. We will cease the neutralization of the TDI on the filters and will utilize a method by which any pressure build up in the drum will be relieved as needed (pressure relief bung cap). We will reclassify the filters in our internal procedures as TDI waste and will declare and manage them as such for offsite disposal. Thank you very much for your time and efforts on this matter and if you need any additional information or have any concerns about our procedural change please contact me at your convenience. Sincerely, 4b��1�� Justin Hippie Pouring Manager CARPENTER CO. 17100 SOUTH HARLAN ROAD P.O. BOX 279 LATHROP. CALIFORNIA 95330 209 982.4800 We bring comfort to your life