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• • • Environmental Health Inspection Program 2220, SM HW GEN <5 Tons/YR • Premier Finishing Violations, Corrections, & WIP 3030 HSC 25143.9(a) Class II Unlisted Operations/Maintenance violation. HSC, section 25143.9 (a): Labeling containers of Violation Details: Several spent acetone containers were found to not be labeled properly. The containers were missing the words "Excluded Recyclable Material" instead of the words "Hazardous Waste". According to the listed section: (a) If the material is held in a container or tank, the container or tank is labeled, marked, and placarded in accordance with the department's hazardous waste labeling, marking, and placarding requirements which are applicable to generators, except that the container or tank shall be labeled or marked clearly with the words "Excluded Recyclable Material " instead of the words "Hazardous Waste," and manifest document numbers are not applicable. If the material is used oil, the containers, aboveground tanks, and fill pipes used to transfer oil into underground storage tanks shall also be labeled or clearly marked with the words "Used Oil... Immediately label the spent acetone containers according to this section. This is a Class II violation. CCR, section 66261.4 (a)(5):Secondary Materials that are reclaimed. (6) 55 -gallon metal containers labeled as containing "Stripper Sludge to be Recycled" with an accumulation start date do not meet the exclusion as a hazardous waste under this section: (5) secondary materials that are reclaimed and returned to the original process or processes in which they were generated where they are reused in the production process provided: (A) only tank storage is involved, and the entire process through completion of reclamation is closed by being entirely connected with pipes or other comparable enclosed means of conveyance; (B) reclamation does not involve controlled flame combustion (such as occurs in boilers, industrial furnaces, or incinerators); (C) the materials are never accumulated in such tanks for over twelve months without being reclaimed; and (D) the reclaimed material is not used to produce a fuel, or used to produce products that are used in a manner constituting disposal. The "Stripper Sludge to be Recycled" is stored in containers and not in tanks with the entire process not being closed entirely. Under the HSC, section 25143.2 (e)(4): (e) Notwithstanding subdivisions (b), (c), and (d), all of the following recyclable materials are hazardous wastes and subject to full regulation under this chapter, even if the recycling involves use, reuse, or return to the original process as described in subdivision (b), and even if the recycling involves activities or materials described in subdivisions (c) and (d): (4) Materials accumulated speculatively. The (6) 55 -gallon containers of "Stripper Sludge to be Recycled" are being accumulated speculatively as a spent material and cannot be reclaimed since the spent material is stored in containers. Immediately discontinue this practice and manage the (6) 55 -gallon containers of "Stripper Sludge to be Recycled" as hazardous waste by contacting a properly licensed transporter and arrange to have the containers disposed of properly. Provide a copy of the disposal receipt for the (6) 55 -gallon containers of "Stripper Sludge to be Recycled". This is a Class lI violation AUG 0 5 2014 ENVIRONMENTAL HEALTH DEPARTMENT