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Backus, Garrett From: Backus, Garrett Sent: Tuesday, October 22, 2019 4:34 PM To: 'Chris Young' Cc: Alaniz, John; 'Craig Walters' Subject: RE: RTC violations Hi Chris, I feel that you need more data to demonstrate that the ash waste is consistently non-hazardous waste. Each lot of ash waste should probably be tested to see if it's hazardous waste before disposal. The ash waste sample from 3-27-19 was 11,000 ppm barium and above the 10,000 ppm barium TTLC limit. The paint became waste when it was burned off the racks. At that point the barium may not be the barium sulfate compound due to decomposition in the burning process so the barium sulfate exclusion does not apply. Garrett Backus, Ld. Sr. REHS, CUPA programs San Joaquin County Environmental Health Department 1868 E Hazelton Ave, Stockton, CA 95205 (209)468-2986 gbackusC@sigov.org https://www.sogov.org/departmenVenvhealth/ From:Alaniz,John <jalanizl@sjgov.org> Sent:Tuesday, October 22, 2019 4:01 PM To: 'Chris Young' <chris@premierfinishing.com> Cc: Backus, Garrett<gbackus@sjgov.org> Subject: FW: RTC violations HI Chris, Thank you for the response. The Storm Drain Waste is OK. Although a TCLP was not needed on the second sample, a TCLP was needed for the first sample. We still have a concern, especially with the way the waste is generated (burned),that a TCLP could fail. There are three ways to get this resolved: 1) If barium sulfate does not degrade in the burning process (provide evidence), provide a statement from DTSC saying a TCLP would not be required. DTSC has a Regulatory Assistance Office that can be contacted at RAO@dtsc.ca.gov or 1-800-728-6942. 2) Run a TCLP analysis on the ash waste. 3) Provide a statement that the facility does not intend to do anything else. Thank You, John Alaniz From: Chris Young [mailto:chris@premierfinishing.com] Sent:Tuesday, October 22, 2019 2:38 PM To:Alaniz,John <ialanizl@slgov.org> Subject: RE: RTC violations 1