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j 1141 Sibley Street,Folsom,CA 95630 <br /> (916)353-2360 I(800)NES-ADVISE/Fax(9I6)353-2375 <br /> www.nesglobal.net <br /> Return to Compliance Statement <br /> November 26, 2019 <br /> Prepared on behalf of: <br /> Cozad Trailer Sales, LLC <br /> 4907 E Waterloo Rd <br /> Stockton, CA 952I5 <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 stated <br /> hazardous waste determinations must be made for metal fines within the grinding shop and <br /> machine shop as well as sanding dust from the primer operations in the paint shop and plasma <br /> cutter slag wastes. <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. In 22 CCR 66260.1 0(a)(2), scrap metal is defined as <br /> "metal workings...grindings, shavings and sandings," while 22 CCR 66260.10(b)(6) defines <br /> materials that are excluded from the definition of scrap metal as "sludges, fine powders...". <br /> Conclusion <br /> On November 26, 2019, samples were collected by Natasha McClurg of NES, Inc. (NES) for the <br /> primer sanding operations and the sand blast media dusts, and these samples were submitted to <br /> California Laboratory Services in Rancho Cordova,CA for CAM 17 analysis. Initial TTLC results <br /> will be received by end of business day on November 27, 2019; at that time, a determination will <br /> be made for further testing (STLC and TCLP) or to manage the waste streams as non-hazardous. <br /> The plasma cutting sludge waste and associated filters will be managed as a hazardous waste per <br /> generator knowledge of the metal content that would accumulate in the sludge and filters during <br /> operations. Additionally, the metal particles generated from the grinding and machine shops have <br /> Return to Compliance Statement NES,Inc. <br /> Cozad Trailer Sales,.LLC 1 Project Number: 114 7.EC4676 00 <br /> 4907 E Waterloo Rd, Stockton, CA 95215 November 2019 <br />