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l.�al•�ii'�li."C�ifICES CARDIMALi---"� ir�rnAfrc .IDC,i Ili I t urinllie, "'17;1J,USA PI idle:626-:, 927,i Fax:62G-,; k4; 03fi www.cardinalpaini.com Preu7ien•Finishing 7910 South Longe Street Stockton, CA 95206 Attn: Craig Walters July 29,2019 To Whom It May Concern: Capri-1-lI P',:li;I! J,r i�_ ill 11 ! h �, -11 1, 1 .. I'1tCi�ti, 113: ;li?IL.'c pi_I..t'Ias C�i r.Cilel' IIhi'ci c nil_' '.l']i:�h ,�'ul-I'.�I11 Ii��l�i lilci' 1:.L':,1 I have included a copy of the pertinent language of this regulation] for your review, The question as to wilether a waste is hazardous involves several issues. First is it a list waste? Federal and State authorities have designated certain materials as hazardous waste per se. If the waste is not listed,then you have to ask if it dernon.strates the characteristic of a waste. These would be reactive, corrosive, flarmnable, or toxic, Powder coatings are not reactive,corrosive or£lanunable. The State of California has developed a list of]petals which if present could render the waste hazardous,if not present the waste would not be considered toxic. I am forwarding copies of analysis performed on our powder coatings by an independent laboratory. If you compare the test result with the regulatory birrit established in 22 CCR 66261.24 you will find that there are no constituents present that exceed regulatory limits. In cases where a particular constituent shows a result considerably above non detect we have also performed the STLC(soluable threshold limit concentration)analysis, This test result appears at the bottom of the TTLC(total tlu•eshold limit concentration)testing. You may notice that barium sulfate has a higher result than other constituents. If you look at 22 CCR 66261.24 the footnote marked++you will see that barium sulfate is specifically excluded fi•om barium and or barium compounds. Despite this fact the STLC for barium has been performed and the result is listed at the bottom of the TTLC analysis. Barium sulfate has been delisted from the category"barium compounds"on the list of toxic chemicals for which reporting is required under sec. 313 of the Emergency Planning and Community RIGHT-TO-KNOW Act of 1986 (EPCRA)since June 28, 1996,40 CFR Part 372. In addition Cardinal has performed a Hazardous Waste Screen Bioassy(CAL)on each series of our powder products. In this analysis the product is fed to frsh at various concentrations for various lengths of time. The results of this analysis show that these coatings caused no death at any of the established intervals. These results show that these coatings are not harmful to aquatic life. The test data provided is from 2001. No changes have been made to these formulas since the analysis were conducted. I am iiwluding a cope elf L]recent lest pertorried on pov dL.-r cuatin"materials Contained in our dust CoIlectiorl .,vstem' -]-his %�ould Ill-an awgregafe of all ilie coatings tv�marlutaciur�. Tice results indicated no California mets present at or Ileal'the rec uLIWOry limit. We strongly recommend that you perform similar analysis on the material of which you plan to dispose in order to certify that your waste does not contain heavy metals above the limits established in 22 CCR 66261.24. If you have any further questions,piease call me at 626-937-6767. Sincerely b V f o Mike Shirey Laboratory Manager SOUTH EL MONTE,CA o CITY OF INDUSTRY, CA a SAN JOSE, CA a PHOENIX,AZ a DENVER,CO . NIGH POINT, HC a WOODINVILLE, UUA WARREN, PA o LAKEVILLE, IVIN o MARYLAND HEIGHTS,MO a DALLAS,TX o HONG KONG