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Backus, Garrett [EHD] From: Jason Boone <Jason.Boone@vrcmetalsystems.com> Sent: Wednesday, October 13, 2021 1:10 PM To: Backus, Garrett [EHD] Cc: Mike Belmont; Terree Matson; Henry, Michelle D [EHD]; Michelle Le Subject: RE: Emailing: RTC form for Stockton Propeller, dated 7-2-2021, RTC Evidence Attachments: J. Boone, 08-10-2021.pdf, IMG_7365.JPG; disposal record used oiljpg; Manifest Paint Waste 10-11-2021.PDF; Paint Waste.JPEG; Used Oil.JPEG CAUTION: This email is originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Violation 106 -training. The training document is not complete and a sign -off sheet was not provided. 1. It does not discuss non-RCRA hazardous waste determinations. 2. The satellite container information is not consistent with California regulation. 3. The document references RCRA empty containers. Empty containers at this facility must comply with California (non- RCRA) empty container rules. We have entered into NES partnership program which will provide required training to all necessary employees. Their first onsite visit was October 12, at which point we are scheduling training for November. My department offers free classes here in basic hazardous waste management: https://ehd- training.sjgov.org/app/TrainingClasses.aspx To date, we have 1 person that has completed basic hazardous waste management training. Cert attached. We have 2 more registered to attend on October 19. Violation 202 - I did not receive photos of the labeled and closed waste alodine containers. There were two containers of this waste observed during the inspection. Item 202 in the inspection report does not list a violation for the labeling of Alodine containers. Only one container is contained in photo log of a waste Alodine container (IMG_6029). We do have a photo of this container labeled (attached IMG _7365) that was included in the 'complete response'. There is no 2nd container of Alodine waste. If you are referencing the 2 containers in IMG -6025 of the photo log, these are not waste. Violation 605 - labeling 1. The "Paint Waste Accumulation" photo shows an accumulation start date of 2-11-20. Since this waste has been accumulated greater than 180 days, please dispose of this waste and provide a disposal record. See attached disposal record, "Manifest Paint Waste". 2. The "Warehouse, Used Oil " photo does not include the words "mineral spirits" in the composition section. Since this is a combination of used oil and mineral spirits include the words "mineral spirits" and "used oil" on the label. Mineral spirits is not the same as used oil due to a lower flash point. The label also shows an accumulation start date of 11-21-20. Since this waste has been accumulated greater than 180 days, please dispose of this waste and provide a disposal record. a. See attached disposal record, "Used Oil". b. See attached photo "IMG _0660". No accumulation had occurred at the time of the photo, so accumulation start date is intentionally left blank. The "Paint Waste Satellite" photo has an accumulation date of "satellite". Change to a specific date or use "daily" or "weekly" if the container is dumped into the larger paint accumulation container.