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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.ora/ehd Small Quantity Hazardous Waste Generator Inspection Report Facility Name: Facility Address: TDate: ALCO METALS 1815 NAVY DR, STOCKTON September 03 2015 Universal Waste 706 CCR 66273.33.5 Failed to properly manage universal waste electronic devices,CRTs or CRT glass ❑V ❑R ❑COS 707 HSC 25201.16(e) Failed to manage aerosol cans in a manner that prevents the unauthorized release of waste ❑V ❑R ❑COS 708 HSC 25201.16(f) Failed to properly manage containers of waste aerosol cans ❑V ❑R ❑COS 709 HSC 25201.16(g) Failed to store used aerosol cans in an accumulation container ❑V ❑R ❑COS 710 HSC 25201.16(h)(4) No written operating procedure for aerosol can processing ❑V ❑R ❑COS 711 HSC 25201.160) Failed to submit or amend notification for aerosol can processing ❑V ❑R ❑COS 712 CCR 66273.34 Failed to label universal waste to identify type of universal waste ❑V ❑R ❑COS 713 CCR 66273.35 Stored UW onsite greater than one year or was unable to demonstrate the time UW has been stored ❑V ❑R ❑COS 714 CCR 66273.36 Failed to train employees and maintain records on UW handling and emergency procedures ❑V ❑R ❑COS 715 CCR 66273.39 Failed to keep complete records of each shipment of universal waste for three years ❑V ❑R ❑COS Other Violations 3010 See below Unlisted Administration/Documentation violation ❑V ❑R ❑COS 3020 See below Unlisted Training violation ❑V ❑R ❑COS 3030 See below Unlisted Operations/Maintenance violation ❑V ❑R ❑COS 3040 See below Unlisted Release/Leaks/Spills violation ❑V ❑R ❑COS 3050 See below Unlisted Abandonment/Illegal Disposal/Unauthorized Treatment violation ❑V ❑R ❑COS SUMMARY OF VIOLATIONS (CLASS I,CLASS II,or MINOR-Notice to Comply) Item# Remarks 102 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. A 55 gallon drum of copper turnings and smaller particles was observed in the storage building or metal recycling without first determining particle size or hazardous properties. Dark solids were observed accumulated on and around a copper wire processing machine inside the storage building. According to Mr. Rose and Mr. Lynch, the machine strips the insulation from the copper and the accumulation could be from the copper wiring or part of the sealant for the insulation. The floor around the machine was covered in oily staining. 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 copper turnings waste and the waste around the processing machine, and manage them according to Title 22 hazardous waste regulations. Metal particles 100 microns or smaller must be handled as hazardous waste if the metal is determined to be a hazardous waste. Submit a statement and supporting documentation explaining how these wastes were managed. A sample of the copper turning waste was taken by the EHD at the time of inspection. This is a minor violation. Received by Inspector: Phone: Date: (initial): STACY RIVERA, Senior REHS U7,-, (209)468-3440 09/03/2015 Page 3 of 6