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1 <br />Alaniz, John [EHD] <br />From:Lon Kitagawa <LKitagawa@aascworld.com> <br />Sent:Wednesday, December 9, 2020 2:28 PM <br />To:Alaniz, John [EHD] <br />Subject:RE: SJC Inspection <br />CAUTION: This email is originated from outside of the organization. Do not click links or open attachments unless you recognize the <br />sender and know the content is safe. <br /> <br />Yes, we put lockouts on the compactors and they’re no longer in use. The average full drum weight of the <br />compacted waste was 221 pounds and now without compacting, the average weight is 99 pounds. So we’re <br />disposing of at least twice the number of drums and ordering empty drums more often. <br /> <br />From: Alaniz, John [EHD] <jalaniz1@sjgov.org> <br />Sent: Wednesday, December 9, 2020 1:28 PM <br />To: Lon Kitagawa <LKitagawa@aascworld.com> <br />Subject: RE: SJC Inspection <br /> <br />Hi Lon, <br />Thank you for the update. It is unfortunate that DTSC does not have anything else. So has AASC stopped compressing <br />the waste then? <br /> <br />John <br /> <br />From: Lon Kitagawa [mailto:LKitagawa@aascworld.com] <br />Sent: Wednesday, December 9, 2020 11:53 AM <br />To: Alaniz, John [EHD] <jalaniz1@sjgov.org> <br />Subject: RE: SJC Inspection <br /> <br />CAUTION: This email is originated from outside of the organization. Do not click links or open attachments unless you recognize the <br />sender and know the content is safe. <br /> <br />John: <br /> <br />DTSC told us that they considered compaction to be treatment based on their review of a HW permit from <br />Sandia Labs. Sandia uses the same compactor as us but they use it to compact solvent and oil contaminated <br />rags, wipes, filters, empty containers, glassware, PPE and can commingle all these wastes. In addition, the <br />permit allows them to add absorbent to fill empty spaces. Based on that permit, we disagree that it’s the <br />same as our wastestream since compacting glassware definitely changes the physical composition of the <br />waste and adding absorbent potentially changes liquids to solids. Despite it being totally different from what <br />we do, they indicated that we would have to obtain a Part B permit at a cost up to $200,000 if we continued to <br />compact our wastestream. Sandia Labs can definitely afford to get a permit, but AASC does not have the <br />money or resources to obtain the permit and comply with all the requirements. We mentioned the fact that a <br />category under Permit By Rule (PBR) should be created for instances similar to ours, where all we’re doing is <br />removing airspace to make more room in a drum. PBR does have a couple of categories which allow crushing,