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1141 Sibley Street,Folsom,CA 95630 <br /> (916)353-2360/(800)NES-ADVISE/Fax(916)353-2375 <br /> www.nesglobvr3 al.net <br /> Technical Analysis Memo <br /> Prepared on behalf of: <br /> Cozad Trailer Sales, LLC <br /> 4907 E Waterloo Rd <br /> Stockton, CA 95215 <br /> Background <br /> On November 5, 2019, Cozad Trailer Sales, LLC (Cozad) received an amended inspection report <br /> from San Joaquin County Environmental Health Department.Violation Item# 102 from this report <br /> stated hazardous waste determinations must be made for sanding dusts from the primer operations <br /> in the Paint Shop. <br /> Statutory & Regulatory Overview <br /> California Code of Regulations, Title 22 (22 CCR) 66262.11 states that all generators of waste <br /> must determine if the waste is hazardous.Verbiage in 22 CCR 66260.24 summarizes characteristic <br /> of toxicity hazardous waste and includes regulatory threshold values for metal toxicity (Table I <br /> and Table II). As a footnote to Table II [22 CCR(a)(2)], if soluble chromium as determined by the <br /> Toxicity Characteristic Leaching Procedure(TCLP)is less than 5 mg/L,and the soluble chromium <br /> as determined by the Soluble Threshold Limit Concentration (STLC) is 560 mg/L, or more, then <br /> the waste would be considered a California(non-RCRA) hazardous waste. <br /> Conclusion <br /> On November 26, 2019, samples were collected by Natasha McClurg of NES, Inc. (NES) for the <br /> primer sanding operations dusts and the sand blast media dusts and submitted to California <br /> Laboratory Services in Rancho Cordova, CA for CAM 17 analysis. Initial Total Threshold Limit <br /> Concentration (TTLC — see Attachment 1) results determined that neither waste stream triggered <br /> a TCLP (see Attachment 2);however,both waste streams triggered STLC testing(see Attachment <br /> 3).In an effort of caution,both samples were additionally TCLP tested for chromium. STLC results <br /> determined that the sand blast media dusts are non-hazardous and shall be managed as solid waste. <br /> The STLC results for the primer sanding operations indicated that the primer sanding dusts have <br /> Technical Analysis Memo NES,Inc. <br /> Cozad Trailer Sales,LLC 1 Project Number:1147.EC4676.00 <br /> Kara Kardashian December 2019 <br />