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4 <br />From: Alaniz, John [EHD] <jalaniz1@sjgov.org> <br />Sent: Monday, March 22, 2021 4:58 PM <br />To: Miguel Ruvalcaba Sandoval <mruvalcaba@ufpi.com> <br />Cc: Christopher Killeen <Christopher.Killeen@ufpi.com>; Daniel Shipman <dshipman@ufpi.com>; Michael Lewis <br /><Michael.Lewis@ufpi.com>; Rob Dickens <rdickens@ufpi.com>; Francisco Ortiz <Francisco.Ortiz@ufpi.com>; Backus, <br />Garrett [EHD] <gbackus@sjgov.org> <br />Subject: RE: UFP <br /> <br />Hi Miguel, <br /> <br />Thank you for the quick reply. <br /> <br />To answer your question, California has additional hazardous waste testing requirements making it more stringent than <br />the EPA. California requires a complete hazardous waste determination to be made that includes the generator <br />addressing the aquatic toxicity. <br /> <br />Based off of the safety data sheet, chlorothalonil has an aquatic toxicity LC50 of 17.1 micrograms/l. If the acute aquatic <br />96-hour LC 50 is less than 500 milligrams per liter then the waste is determined to be hazardous and should be <br />managed according to all applicable hazardous waste requirements. Even though the chlorothalonil is <1 percent, there <br />is enough concern that the whole waste could fail the test as the LC 50 is so low. <br /> <br />If the paint is hazardous waste, the dried version cannot be thrown away into the trash-even if the final destination is <br />not a river. You can compare it to lead paint-you still would not put it in the general trash. <br /> <br />The generator has to prove the waste is not hazardous waste for fish toxicity. If the facility has test results from the <br />EPA/DTSC/Manufacturer for the California Fish Toxicity test, then they can submit that as documentation. <br /> <br />It might be easier to talk about it over a phone call? <br /> <br />Thank You, <br />John Alaniz <br /> <br />From: Miguel Ruvalcaba Sandoval [mailto:mruvalcaba@ufpi.com] <br />Sent: Monday, March 22, 2021 1:14 PM <br />To: Alaniz, John [EHD] <jalaniz1@sjgov.org> <br />Cc: Christopher Killeen <Christopher.Killeen@ufpi.com>; Daniel Shipman <dshipman@ufpi.com>; Michael Lewis <br /><Michael.Lewis@ufpi.com>; Rob Dickens <rdickens@ufpi.com>; Francisco Ortiz <Francisco.Ortiz@ufpi.com> <br />Subject: RE: UFP <br /> <br />CAUTION: This email is originated from outside of the organization. Do not click links or open attachments unless you recognize the <br />sender and know the content is safe. <br /> <br />Hi John, <br /> After our conversation, I have a question, “If the EPA considered the aquatic toxicity of the moldicide <br />and found it acceptable prior to approving its use in paint as a pesticide”? <br />Why do we have re-test when it has already been done in the EPA labs. <br /> This message was sent from outside the company. Please consider this when <br />clicking any links or sharing information!