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December 15, 2014 0 40 San Joaquin County Environmental Health Department 1868 East Hazelton Avenue Stockton, California 95205-6232 Website: www.s/gov.org/ehd Phone: (209) 468-3420 Fax: (209) 464-0138 FILE COPY DIRECTOR Linda Turkatte, REHS PROGRAM COORDINATORS Robert McClellon, REHS Jeff Carruesco, REHS, RDI Kasey Foley, REHS Rodney Estrada, REHS Adrienne Ellsaesser, REHS CRAIG WALTERS PREMIER FINISHING 9171 9690 0935 0084 8370 32 7910 S LONGE ST - STOCKTON, CA 95206 RE: Return to Compliance Comments for 7910 S LONGE ST, STOCKTON, CA 95206; CERS ID: 10184277 On June 16, 2014, Raymond Von Flue of the San Joaquin County Environmental Health Department (EHD) performed a routine hazardous waste inspection at the above referenced site. An inspection report was issued identifying information to be submitted to bring this site into compliance. This information was required to be submitted 30 days after receiving the inspection report. A corrective action statement and some supporting documentation was received by the EHD on August 5, 2014, however, the received documentation was incomplete. Return to compliance deficiencies were discussed with Mr. David Dixon via phone conversation on November 6, 2014. The outstanding violations are itemized on the following pages. Submit a statement documenting the corrective actions that have been or will be taken for each violation, and any supporting paperwork. Note: All EHD staff time associated with failing to comply, including the issuance of this letter, is billed at the current hourly rate ($130). Failure to submit the completed information immediately may result in a re -inspection, additional violations, and/or further legal action. The required corrective actions include: 1) Violation #204 — Failed to obtain a permit to treat hazardous waste. Flammable paint waste is being treated by adding a hardener without a permit to treat hazardous waste. Flammable paint waste is not an eligible hazardous waste that can be treated under a tiered permit. A permit to treat flammable paint waste must be obtained from the DTSC in order to continue this process. Immediately cease treating the flammable paint waste until an approved permit to treat hazardous waste is issued by the DTSC. Provide a statement explaining how this violation will be corrected and how the flammable paint waste will be managed in the interim. This is a Class I violation. EM: The corrective action statement received by the EHD on August 5, 2014 indicated that paint hardening is part of the manufacturing process of paint application, which takes place at this facility. Please provide a statement indicating that a 5 -gallon paint container labeled 'paint to be hardened" (photograph taken at the time of inspection is attached hereto) was indeed set out to be used as part of the painting process and was not a waste to be hardened and disposed of. Furthermore, the provided corrective action statement indicated that "Premier Finishing does not treat hazardous waste". This statement appears to be erroneous, since this facility is a tiered permit facility that treats hazardous waste. Please revise your corrective action statement, as appropriate. 2) Violation #3030 — Unlisted Operations/Maintenance violation. HSC, section 25143.9 (a): Labeling containers of "Excluded Recyclable Material": Several spent acetone containers were found to not be labeled properly. The containers were missing the words "Excluded Recyclable Material" instead of words "Hazardous Waste". EM: The corrective action statement received by the EHD on August 5, 2014 as well as the attached pictures indicate that Excluded Recyclable Materials (ERM) were only labeled with words "Excluded