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From:Alaniz,John [mailto:jalanizl@sjgov.org] <br /> Sent:Tuesday, April 14, 2020 12:08 PM <br /> To: 'Arcee San Pablo' <arcee@aic-coatings.com> <br /> Cc:Steve Hockett<steve@aic-coatings.com> <br /> Subject: RE:Automatic reply: Update <br /> Hi Arcee, <br /> Thank you for getting back to me. I have a couple of questions/comments with the open violations. <br /> Violation 102-Failed to determine: <br /> When I reviewed my records,there are three waste streams currently still in question: <br /> Nuisance powder/dust: In the last statement I received from you, it was determined that the dust was non-hazardous. I <br /> need to know how the powder was determined to not be a hazardous waste. The determination has to be made at the <br /> point of generation before it is baked. Please send us the SDS. <br /> Ash Waste from paint stripper: I am OK with the Cardinal answer. However, you stated that Cardinal consisted of 9S <br /> percent of paint used. What about the other paints. <br /> Paint filters/ Rag Waste: The shop sample came back as 20,200 mg/kg for Zinc and the booth sample came back as <br /> 11,800 mg/kg for cadmium. Both of these numbers passed the TTLC threshold and automatically become California <br /> regulated hazardous waste. The cadmium could potentially be RCRA. <br /> The high zinc/cadmium levels bring in concern with the other S percent of paints. What could have caused the high <br /> levels? What other paints are used? If the paint is not cardinal, how would it be disposed of? In addition, if the rags <br /> have acetone on them, there is concern for flammability. <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 /> 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 /> Thank You, <br /> John Alaniz <br /> REHS <br /> San Joaquin County <br /> Environmental Health Department <br /> 1868 E Hazelton Avenue <br /> Stockton, California 95205 <br /> Phone: (209)468-3147 <br /> Fax: (209) 468-3433 <br /> 2 <br />