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1 Baker, Lydia From:Mark Granados <mgranados@surtecsystem.com> Sent:Monday, April 29, 2019 11:33 AM To:Baker, Lydia Subject:RE: Return to Compliance Hello Lydia, It appears that option 1 is the most viable. We have already stopped the process of drying and will drum up the material, have it profiled and disposed of by our waste hauler. The amount to be disposed of should be less than 55 gallons in volume. In the future, any waste of this type will collected and disposed of in its original liquid form. Regards, Mark E. Granados Surtec, Inc. 209-820-3700 x233 www.surtecsystem.com From: Baker, Lydia [mailto:lbaker@sjgov.org] Sent: Wednesday, April 24, 2019 9:48 AM To: Mark Granados Subject: RE: Return to Compliance Hello Mark, I’ve reviewed the SDS that you sent over. All four are not hazardous for ignitability, corrosivity and reactivity. The toxicity for each is still unclear. The two acrylic emulsion polymers do not have any data (96 hour fish bioassay) for toxicity. The two products only have the 96 hour fish bioassay for the components. The hazardous waste determination for those four chemicals is incomplete. Here are the options that I see right now: 1. Decide to handle those four chemicals as hazardous waste and stop drying them. 2. Provide complete toxicity data (96 hour fish bioassay) for the four chemicals (sample results or if you have additional information to show that these chemicals are not toxic) 3. I can come sample the four chemicals and send them in for toxicity analysis. (You will get a copy of the results.) If the results come back as non-hazardous for toxicity for all four chemicals then I will amend the report to remove the treatment violation. If any of them come back as hazardous for toxicity then the violation for treatment would stand and you would either need to stop drying the chemicals that came back as hazardous waste or get a hazardous waste treatment permit. If you have any questions please let me know. Best Regards,