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0 <br /> Jeff Wong [EH] <br /> From: Jeff Wong [EH] <br /> Sent: Thursday, March 20, 2014 2:28 PM <br /> To: Larry "Butch" Waddle (Twaddle@sjgov.org); dmccann@sjgov.org <br /> Subject: 1810 Hazelton HW Return to Compliance (RTC)follow up <br /> Butch, Dan: <br /> In your RTC letter it was stated thate metal "Grindings will be sent to the Household Hazardous waste facility". Since <br /> you are a Small Quantity Generator(SQG), disposing of hazardous waste at the HHW facility is not allowed; HHW facility <br /> can accept HW only from Conditionally Exempt SQG (CESQG). However,you may still use HHW facility for your Universal <br /> Waste. <br /> The violation cited was to remind you that you need to make a "size" and "hazardous waste" determination for waste <br /> metal fines. Waste metal fines determined to be hazardous can still be "recycled" rather than disposed as HW as long as <br /> the particle size is bigger than 100 microns. Hazardous waste metals 100 microns or less must be managed as hazardous <br /> waste. Therefore, instead of disposing all "grindings"as hazardous waste (although you can always"declared" a waste <br /> to be hazardous and dispose it as such),first make a size and hazardous determination of metal fines. <br /> Best Regards, <br /> Jeff Wong <br /> 1 <br />