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Alaniz, John <br /> From: Arcee San Pablo <arcee@aic-coatings.com> <br /> Sent: Wednesday, April 15, 2020 2:01 PM <br /> To: Alaniz, John <br /> Cc: 'Steve Hockett' <br /> Subject: RE: Automatic reply: Update <br /> Hi John, <br /> The dust/powder nuisance is the waste powder.That is the powder that is baked.The Department consist of 95% <br /> Cardinal coating this coating does not require rags or acetone. I will send you an SDS of the most commonly used <br /> powder if you still need it. <br /> Paint Filters and Rags both contain liquid paint and Acetone. Same waste stream on both.The rags are used while <br /> cleaning the guns and the filter catches what is sprayed.These materials are the ones that came in high in Zinc and <br /> Cadmium. Since these levels have passed the TTLC threshold will the results from the STLC/TCLP even matter? <br /> The ash from the burn off oven is used for the Line Department. Which consist of the Cardinal powder. <br /> Note* the liquid paints that need to be stripped is done in the Chemical stripper which is already being handled as <br /> hazardous and shipped as stripper waste/sludge. <br /> Violation 113: No consolidated manifest. I wrote the following for the report: Used oil that is generated from the compressor <br /> area is taken to San Joaquin County Business Hazardous Waste. Copies of hazardous waste disposal records for the last three years <br /> were not found on site. <br /> You said that you were going to double check to see if you could locate any more records. If not,that is fine, I just need a statement <br /> and I will close the violation. <br /> I did check and did not find any other records. Since then, we have contracted a different company to handle <br /> maintenance on our compressors and they are responsible for disposing all waste generate during service checks. We no <br /> longer have used oil in our facility. <br /> Violation 605: Failed to label hazardous waste containers. <br /> The following violation was written: In the paint area, one 275 gallon container that had powder waste and two 16 gallon drums <br /> containing nylon waste were observed without hazardous waste labels. <br /> During our discussion you mentioned that the waste was not hazardous but that it had to be disposed of as hazardous so <br /> it could be gotten rid of. While I understand what you are saying, since the facility handles the waste as hazardous, it <br /> needs to be labeled as such. <br /> You are absolutely correct. We were using those 16 gallon drums as a satellite until we can place it into the 275 gallon <br /> tri-wall bin. We are now moving the Nylon directly into the 275 Gallon bin. We no longer hold waste Nylon is the 16 <br /> Gallon containers. <br /> Hope this clears everything up. But, please let me know if you need further clarification. <br /> Thanks, <br /> Arcee <br /> 1 <br />