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Alaniz, John From: Chris Young <chris@premierfinishing.com> Sent: Wednesday, September 11, 2019 2:36 PM To: Alaniz, John Subject: RE: RTC Hazardous Waste Attachments: 22 CCR 66261.24.pdf; cardinal letters.pdf; e300-bkl 1 sds.pdf; h304-gr312 sds.pdf Good afternoon John, 1) Waste Powder Coating: For us to accept the results of Cardinal,we need to receive more information showing the powder coatings that were tested are one of the products that the facility uses. This can be provided to us via statements and SDS sheets. 4) 1 did not see a TCLP test done on barium for the burned off ash. Was TCLP testing done on the waste? 5) See 4. In regards to violation 102,#1,#4 and #5, regarding Barium TCLP results for the waste streams associated with these open violations,TCLP was not performed because these waste contain Barium sulfate as opposed to barium (Cardinal confirmed that all of their products contain barium sulfate not barium). Per 22 CCR 66261.24(a)(1) Barium (CAS number 7440-39-3) has a TCLP limit, however Barium Sulfate (CAS number 7727-43-7) is not listed nor does it have a TCLP limit. Also, 22 CCR 66261.24(a)(2), refer to footnote c (see attached), specifically excludes Barium sulfate. Since Barium sulfate is not regulated the TCLP for these waste streams was not performed. If you have any question please contact me. From:Alaniz,John <jalanizl@sjgov.org> Sent:Wednesday, September 11, 2019 9:35 AM To: Chris Young<chris@premierfinishing.com> Cc: Craig Walters<craig@premierfinishing.com>; Backus, Garrett<gbackus@sjgov.org> Subject: RE: RTC Hazarodus Waste Hi Chirs, It is fine if you want to take the more stringent route and dispose of wastes as RCRA. If the wastes in question (with no TCLP) are being hauled off as RCRA hazardous waste,you would not need to get them retested. However, if you want to dispose of the waste as non-RCRA, then you would need to prove to us it is not a RCRA regulated waste. If you have any more questions on this please let me know. Thank You, John Alaniz From:Alaniz,John Sent:Wednesday, September 11, 2019 9:06 AM To: 'Chris Young' <chris@premierfinishine.com> Cc: 'Craig Walters' <craig@premierfinishing.com>; Backus, Garrett<gbackus@sigov.org> Subject: RE: RTC Hazarodus Waste Hi Chris, Here is an UPDATE. Violation 602/603: Although the bucket is emptied daily, the EHD needs to receive the disposal record for the treatment waste that was in the buckets. Please send in the manifest that the waste would have gone out on. 1