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0 <br />SAN JOAQUIN <br />COUNTY <br />10 <br />Environmental Health Department <br />treat hazardous waste". This statement appears to be erroneous, since this facility is a tiered permit <br />facility that treats hazardous waste. Please revise your corrective action statement, as appropriate. <br />2) Violation #3030 — Unlisted Operations/Maintenance violation. HSC, section 25143.9 (a): <br />Labeling containers of "Excluded Recyclable Material": Several spent acetone containers were found to <br />not be labeled properly. The containers were missing the words "Excluded Recyclable Material" instead <br />of words "Hazardous Waste". <br />EHD's response: The corrective action statement received by the EHD on August 5, 2014 as well as <br />the attached pictures indicate that Excluded Recyclable Materials (ERM) were only labeled with <br />words "Excluded Recyclable Materials" and not with all the required information. These waste <br />containers shall be marked with the following information: <br />1. the words "Excluded Recyclable Materials" (instead of words "Hazardous Waste') <br />2. name and address of generator <br />3. hazardous properties <br />4. physical state <br />5. composition (contents) <br />6. accumulation start date <br />Immediately label these containers and ensure that all hazardous waste containers are marked with <br />all the required information and submit proof of correction to the EHD. <br />3) Violation #3030 — Unlisted Operations/Maintenance violation. HSC, section 25143.9 (a): The (6) <br />55 -gallon container of "Stripper Sludge to be Recycled" are being accumulated speculatively as a spent <br />material and can not be reclaimed since the spent material is stored in containers. Immediately <br />discontinue this practice and manage the (6) 55 -gallon containers of "Stripper Sludge to be Recycled" <br />as hazardous waste by contacting a properly licensed transporter and arrange to have the containers <br />disposed of properly. Provide a copy of the disposal receipt for the (6) 55 -gallon containers of "Stripper <br />Sludge to be Recycled". This is a Class II violation. <br />EHD's response: The corrective action statement, received by the EHD, indicated that a technology, <br />sold by Becca (Super Capacity Solvent Saver (17.5 -gallon) Recycler) exists on the market, and that <br />this technology will enable the recycling of the stripper sludge onsite. The facility did not own this <br />piece equipment at the time of inspection. <br />The facility indicated in their return to compliance that they "believe that this material is excluded <br />from classification as a waste under HSC section 25143.2(b) or 25143.2(d)". The following are the <br />excerpts from the cited code sections: <br />"25143.2(b) Except as otherwise provided in subdivisions (e), (t), and (g), recyclable material that is <br />managed in accordance with Section 25143.9 and is or will be recycled by any of the following <br />methods shall be excluded from classification as a waste: <br />2 of <br />