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SANJ O A Q U I N Environmental Health Department Small Quantity Hazardous Waste Generator Inspection Report Facility Name: Facility Address: Date: SGS Stockton - Carpenter Road 4863 CARPENTER RD, Stockton February 26, 2016 Universal Waste 708 HSC 25201.16(f) Failed to properly manage containers of waste aerosol cans ❑ V ❑ R ❑ COS 709 HSC 25201.16(g) Failed to store used aerosol cans in an accumulation container ❑ V ❑ R ❑ COS 710 HSC 25201.16(h)(4) No written operating procedure for aerosol can processing ❑ V ❑ R ❑ COS 711 HSC 25201.160) Failed to submit or amend notification for aerosol can processing ❑ V ❑ R ❑ COS 712 CCR 66273.34 UW handler (UWH) failed to label universal waste to identify type of universal waste ❑ V ❑ R ❑ COS 713 CCR 66273.35 UWH stored UW onsite greater than one year or was unable to demonstrate storage time ❑ V ❑ R ❑ COS 714 CCR 66273.36 UWH failed to train employees and maintain records on UW handling and emergency procedures ❑ V ❑ R ❑ COS 715 CCR 66273.39 UWH failed to keep complete records of each shipment of universal waste for three years ❑ V ❑ R ❑ COS Other Violations 3010 See below Unlisted Administration/Documentation violation ❑ V ❑ R ❑ COS 3020 See below Unlisted Training violation ❑ V ❑ R ❑ COS 3030 See below Unlisted Operations/Maintenance violation ❑ V ❑ R ❑ COS 3040 See below Unlisted Release/Leaks/Spills violation ❑ V ❑ R ❑ COS 3050 See below Unlisted Abandonment/I[legal Disposal/Unauthorized Treatment violation ❑ V ❑ R ❑ COS SUMMARY OF VIOLATIONS (CLASS I, CLASS II, or MINOR - Notice to Comply) Item # Remarks 102 CCR 66262.11 Failed to determine if a waste is a hazardous waste or retain waste analysis on site for 3 years. Two types of rinsate are being generated at this facility. The first type of rinsate consists of "diluted fertilizer", and is being generated at the fertilizer tank farm via four underground storage tanks (USTs) connected to an above ground storage tank located at the fertilizer tank farm. The second type of rinsate consists of various herbicides (industrial strength Roundup, etc.) and a carrier oil, and is being generated at the chemical tank farm via four USTs connected to an above ground storage tank located at the chemical tank farm. Facility representatives, present at the time of inspection, provided disposal records for the generated rinsate indicating that it's being sold to Van Exel Dairy located at 20002 N. Thornton Rd., Lodi, CA for $1 "which gets credited back to them on the way out". According to the onsite records the "rinsate" is being analyzed for NPK (nitrogen, phosphorus, potassium) via analytical method 200.7 (3010) and the analytical result reviewed at the time of inspection had the following detections: potassium 92 mg/L, nitrogen 720 mg/L, Nitrate 205 mg/L, and phosphorous at 60 mg/L. Although the rinsate is being analyzed, according to facility representatives present at the time of ispection, all rinsate is being relinquished to the outside company as "diluted fertilizer" with "no analysis, no guarantee", according to the facility representatives, no sample analysis is being provided to the user of the onsite rinsate. At the time of inspection the following transaction records were reviewed for the "diluted fertilizer" relinquished to Van Exel Diary: 1-26-16 (12.34 tons), 1-26-16 (12.74 tons), 1-27-16 (12.06 tons), 2-05-16 (4.5 tons), 2017016 (6.7 tons), 2-25-16 (11.38 tons), 2-26-16 (11.9 tons). Also, Daniel Perez indicated that this rinsate is being reported in CERS as hazardous material. Any person who generates a waste shall determine if the waste is a hazardous waste. Immediately stop managing this rinsate and make a hazardous waste determination for the "diluted rinsate", and manage it according the Title 22 hazardous waste regulations. Submit a statement and supporting documentation explaining how this rinsate is being managed. This is a minor violation. FA0005712 PR0539280 SCO01 02/26/2016 EHD 22-01 Rev. 09/27/2018 Page 3 of 6 Small Quantity Hazardous Waste Generator OIR 1868 E. Hazelton Avenue I Stockton, California 95205 1 T 209 468-3420 1 F 209 464-0138 1 www.sjcehd.com