COMPLIANCE INFO PRE 2019 - Laserfiche WebLink

Home Browse Search

San Joaquin County Environmental Health Department 1868 East Hazelton Avenue, Stockton, California 95205-6232 Telephone: (209)468-3420 Fax:(209)468-3433 Web:www.sjgov.or.lq ehd Large Quantity Hazardous Waste Generator Inspection Report Facility Name: Facility Address: Date: PACTIV LLC 1110 PERFORMANCE DR STOCKTON June 05 2015 SUMMARY OF VIOLATIONS (CLASS I,CLASS II,or MINOR-Notice to Comply) Item# Remarks 105 CCR 66262.11, 66262.40(c) Failed to determine if a waste is a hazardous waste or retain waste analysis on site for 3 years. 1. Metal fines, generated from metal grinding and metal cutting equipment, are being recycled as scrap metal without first determining particle size or hazardous properties. Any person who generates a waste shall determine if the waste is a hazardous waste. Immediately stop recycling metal fines, make a hazardous waste determination for the metal fines, and manage it according to Title 22 hazardous waste regulations. Particles 100 microns or smaller must be handled as hazardous waste if the metal is determined to be a hazardous waste. No sample was collected for analysis at the time of inspection due to insufficient material quantities. Submit a statement and supporting documentation explaining how this waste was managed. 2_ '"Vacuum/oil, water, sludge" has been disposed of on two occasions (May 22, 2014 and July 15, 2014) as a non-hazardous waste; several hazardous waste manifests were also present for the disposal of oily water and sludge in 2014 and 2015. Several containers and totes were observed onsite with varying contents("mop water" in particular) with"non-hazardous waste" labels. Any person who generates a waste shall determine if the waste is a hazardous waste. Immediately stop disposing these wastes as non-hazardous, make a hazardous waste determination, and manage them according the Title 22 hazardous waste regulations. Make a hazardous waste determination for all waste streams ( for example "mop water", "ink and water" (wash water), and "vac-oil, water, sludge"), at the point of generation (prior to any mixing or dilution) and keep a record of any test results, waste analyses, or other determinations made in accordance with hazardous waste regulations. Submit a statement and supporting documentation explaining how these wastes will be managed. 3. Incomplete waste analysis records were available for the"ink and water"waste, no waste analysis records were available for the oily water mixture—"mop water' and for the "vac-oil, water, sludge", which are being generated at this facility; no fish bioassay was available for any of the above waste streams. Furthermore, the quality control for the reviewed"ink wash water" laboratory analytical result indicated abnormal QC indicators; no explanation was found indicating if these results were acceptable. The aforementioned wastes are being disposed of intermittently as hazardous and as non-hazardous wastes. According to Mr. Mark Ross, this facility changed their ink formulation and conducted a waste profiling to enable them to dispose of some generated wastes as non-hazardous. A generator shall make a hazardous waste determination for each waste stream ("mop water", "ink and water" (wash water), and "vac-oil, water, sludge", at the point of generation (prior to any mixing takes place) and keep a record of any test results, waste analyses, or other determinations made in accordance with hazardous waste regulations for at least three years from the date that the waste was last disposed of. Immediately conduct an adequate 'hazardous waste determination for all waste streams, and begin managing them under Title 22 hazardous waste regulations, and submit copies of laboratory analytical along with a statement to the EHD on how these wastes will be managed. 4. Several plastic lined drip pans with some residual paint were set out to dry in the"cup" manufacturing area. Mr. David Bauer stated that they are placed into their solid waste once they are dry. Mr. Mark Ross indicated that all their paint solids are being handled as hazardous waste. Disposal records for the disposal of hazardous waste paint solids were available at the time of inspection. Any person who generates a waste shall determine if the waste is a hazardous waste. Since it's unclear how this particular waste stream is being handled, immediately make a hazardous waste determination for the waste paint left out to dry, and manage it according the Title 22 hazardous waste regulations. Ensure that all hazardous waste is containerized immediately, labeled and managed in the appropriate time frame. Submit a statement and supporting documentation explaining how this waste was managed. Received by Inspector: Phone: Date: (initial): R,yt arch l ELENA MANZO, REHS (209) 953-7699 06/05/2015 Page 4 of 9