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r] L <br />SAN JOAQUIN <br />COUNTY <br />(C) Sorting. <br />(D) Sieving. <br />0 <br />Environmental Health Department <br />(E) Grinding. <br />(F) Physical or gravity separation without the addition of external heat or any chemicals. <br />(G) pH adjustment. <br />(H) Viscosity adjustment. <br />(6) The material is used or reused as a safe and effective substitute for commercial products �...] <br />(7) The material is a chlorofluorocarbon or hydrochlorofluorocarbon compound (..4 <br />Per HSC section 25143.2 (e)(4) the accumulated recyclable material would not be excluded from <br />classification as a waste and are hazardous wastes if they are: (4) Materials accumulated <br />speculatively. Furthermore, since no process exists at this time at the subject facility to recycle the <br />stored stripper sludge (HSC section 25143.2 (d)) and the sludge is being accumulated speculatively, <br />it is not excluded from classification as a hazardous waste. <br />Please note, per HSC section 66260. 10, "Accumulated speculatively" means that a material is <br />accumulated before being recycled. A material is not accumulated speculatively, however, if the <br />person accumulating it can show that the material is potentially recyclable and has a feasible means <br />of being recycled and that during the calendar year (commencing on January 1) the amount of <br />material that is recycled or transferred to a different site for recycling equals at least 75 percent by <br />weight or volume of the amount of that material accumulated at the becimmng of the period. In <br />calculating the percentage of turnover, the 75 percent requirement is to be applied to each material <br />of the same type (e.g., slags from a single smelting process) that is recycled in the same way (i.e., <br />from which the same material is recovered or that is used in the same way). Materials accumulating <br />in units that would be exempt from regulation under section 66261.4(c) are not to be included in <br />making the calculation. (Materials that are already defined as wastes also are not to be included in <br />making the calculation.) Materials are no longer in this category once they are removed from <br />accumulation for recycling, however. <br />EHD's response: As such, the six 55 -gallon containers of "Stripper Sludge to be Recycled" observed <br />onsite are hazardous wastes, which were being accumulated speculatively as a spent material, and <br />can not be recycled onsite at this time (the technology which will allow such recycling was not present <br />onsite at the time of inspection). Furthermore, these materials have been stored onsite for several <br />years without being recycled. Immediately dispose of these wastes, as appropriate, and provide <br />disposal records to the EHD, or provide proof that the amount of material that is being recycled, or <br />transferred to a different site for recycling, equals at least 75 percent by weight or volume of the <br />amount of that material accumulated. Submit proof of correction. <br />4 of <br />