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(209)368-8881 <br /> 1313 S.Stockton Street <br /> Lodi,CA 95240 <br /> INDUSTRIES <br /> Aug. 3,2005 <br /> Waste Identification and Recycling Section Committee <br /> Hazardous Waste Management Program <br /> Department of Toxic Substances Control <br /> P.O. Box 806 <br /> Sacramento, CA 95812-0806 <br /> Dear Committee; <br /> We have been issued a Class 1 violation from the San Joaquin County Environmental Health <br /> Department for moving metal dross mixed with scrap metal off the site as a recyclable scrap metal. <br /> This dross is derived from plasma and laser cutting of low carbon steel plate. Through some basic <br /> research by our consultants, we have been informed that this type of waste stream is somewhat of an <br /> attribute call within the regulations. Metal dross is not named in the regulations but some opinions have <br /> been expressed by members of the Environmental Health community as to how it is defined and what <br /> can legally be done with it as dross from metal plate. <br /> Would your committee or members therein be able to provide my company with an official description <br /> of metal dross that would not meet the category of scrap metal and possibly explain why it would not? <br /> At the time of the issuing of this citation letter, it was suggested that an out of state secondary smelter <br /> could legally handle the material. Can you confine that this is an acceptable recycling avenue before <br /> we put forth the efforts to set up such a disposal source and find ourselves still not meeting the scrutiny <br /> of the County EHD? A copy of the Violation Summary letter is attached. <br /> We thank you for your help in our efforts in correcting this issue with the San Joaquin county EHD. <br /> Sincerely, <br /> Fred Baumbach <br /> Plant Engineer <br /> Attachment: <br />