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0 0 Return to Compliance Comments 7910 S LONGEST, STOCKTON, CA 95206; CERS ID: 10184277 Recyclable Materials" and not with all the required information. These waste containers shall be marked with the following information: 1. the words "Excluded Recyclable Materials" (instead of words "Hazardous Waste") 2. name and address of generator 3. hazardous properties 4. physical state 5. composition (contents) 6. accumulation start date Immediately label these containers and ensure that all hazardous waste containers are marked with all the required information and submit proof of correction to the EHD. 3) Violation #3030 — Unlisted Operations/Maintenance violation. HSC, section 25143.9 (a): The (6) 55 -gallon container of "Stripper Sludge to be Recycled" are being accumulated speculatively as a spent material and can not 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 II violation. EM: The corrective action statement, received by the EHD, indicated that a technology, sold by Becca (Super Capacity Solvent Saver (17.5 -gallon) Recycler) exists on the market and that this technology will enable the recycling of the stripper sludge onsite. The facility did not own this piece equipment at the time of inspection. The facility indicated in their return to compliance that they 'believe that this material is excluded from classification as a waste under HSC section 25143.2(b) or 25143.2(d)". The following are the excerpts from the cited code sections: "25143.2(b) Except as otherwise provided in subdivisions (e), (t), and (g), recyclable material that is managed in accordance with Section 25143.9 and is or will be recycled by any of the following methods shall be excluded from classification as a waste: (1) Used or reused as an ingredient in an industrial process to make a product if the material is not being reclaimed. (2) Used or reused as a safe and effective substitute for commercial products if the material is not being reclaimed. (3) Returned to the original process from which the material was generated, without first being reclaimed, if the material is returned as a substitute for raw material feedstock, and the process uses raw materials as principal feedstocks." Note: Please note, none of the above appear to describe the process of distilling and reclaiming the stripper sludge to be recycled, as proposed by the facility. "HSC section 25143.2 (d) Except as otherwiserop vided in subdivisions _�ej (f), (g), and (h), recyclable material that meets the definition of a non-RCRA hazardous waste in Section 25117.9, is managed in accordance with Section 25143.9, and meets or will meet any of the following requirements is excluded from classification as a waste: (1) The material can be shown to be recycled and used at the site where the material was generated. (2) The material qualifies as one or more of the following: (A) The material is a product that has been processed from a hazardous waste, or has been handled, at a facility authorized by the department pursuant to the facility permit requirements of Article 9 (commencing with Section 25200) (...) (B) The material is a petroleum refinery waste containing oil that is converted into petroleum coke at the same facility at which the waste was generated, unless the resulting coke product would be identified as a hazardous waste under this chapter. (C) The material is oily waste, used oil, or spent non -halogenated solvent (...)