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5 April 2019 <br />Mr. John Alaniz <br />San Joaquin County EHD <br />1868 Hazelton AV <br />Stockton, CA 95205-6232 <br />RE: Return to Compliance <br />Kustom Materials Laminators -Stockton <br />CERS ID —10184437 <br />Mr. Alaniz: <br />619 Gillis Avenue <br />Stockton, California 9e: 209.943.2912 <br />Fax: 209.943.6955 <br />Fh`JIR�hMENTAL HEALTH <br />P�R:�:lIYISERVI �FS <br />As is required, we are pleased to provide this response to the Small Quantity Hazardous Waste <br />Generator Inspection Report produced during your visit to the above -referenced facility on 7 <br />March 2019. Kustom Material Laminators (KML) will discuss the listed points of non- <br />compliance in the same order as your report. <br />Item 102: "...Failed to determine if a waste is a hazardous waste." <br />1. "Metal fines generated are thrown into the trash without first determining particle size <br />or hazardous properties..." <br />Response: KML has determined that metal fines generated from cutting operations are <br />hazardous waste as defined by California law. When generated, metal fines will be <br />placed into a properly labeled 55 -gallon steel drum located in an identified Satellite <br />Accumulation Point. Once filled, the drum will either be: 1) manifested, then <br />transported/recycled; or 2) manifested, then transported/disposed as a non-RCRA <br />hazardous waste. <br />2. "Oily absorbent is bagged and thrown away into the trash for disposal. Any person who <br />generates a waste shall determine if the waste is a hazardous waste." <br />Response: KML has determined that the oily absorbent materials generated during our <br />operations are hazardous waste as defined by California law. When generated, oily <br />absorbents will be placed into a properly labeled 55 -gallon steel drum. Once filled, the <br />drum will be manifested, then transported/disposed on a quarterly basis by an <br />appropriately licensed/registered contractor. A photograph of the current absorbent <br />waste drum is included in Attachment A. <br />Item 113: "...Failed to keep copies of consolidated manifesting receipts for three years." <br />Response: KML has obtained copies of all waste manifests for the previous three years <br />anA <br />they are available for inspection at this time. KML's procedures have been altered <br />KML Stockton CERS 10184437 Page 1 <br />