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S 11�1 N J OAQ I I N Environmental Health Department COUNTY— AMENDED 1/29/2020 Permit By Rule Treatment Facility Inspection Report Facility Name: Facility Address: Date: APPLIED AEROSPACE STRUCTURES CORP 3437 S AIRPORT WAY, STOCKTON January 22, 2020 SUMMARY OF VIOLATIONS (CLASS I,CLASS II,or MINOR-Notice to Comply) Item# Remarks 214 CCR 67450.3(c)(8-9)Failed to prepare and implement a waste analysis plan and retain analytical results. OBSERVATION:This hazardous waste treatment facility does not have a complete and correct waste analysis plan. -The waste analysis plan does not discuss the procedure the facility has after the waste has been treated to ensure that no hazardous waste constituents remain. -The facility has an internal lab that runs samples of the treated waste to ensure that chromium levels are at an acceptable range before discharge. According to Lon Kitagawa, Environmental Coordinator, no post treatment samples have been run under the test methods described in the waste analysis plan. The plan requires the samples to be run under EPA test method 200.7 by a certified lab. REGULATION GUIDANCE: (a)(1) Before an owner or operator transfers,treats, stores, or disposes of any hazardous waste, or non-hazardous waste if applicable under section 66265.113(d),the owner or operator shall obtain a detailed chemical and physical analysis of a representative sample of the waste.At a minimum,this analysis shall contain all the information which must be known to transfer,treat, store, or dispose of the waste in accordance with the requirements of this chapter and chapter 18 of this division. (2)The analysis may include data developed under chapter 11 of this division, and existing published or documented data on the hazardous waste or on hazardous waste generated from similar processes. (A)The facility's record of analyses performed on the waste before the effective date of these regulations, or studies conducted on hazardous waste generated from processes similar to that which generated the waste to be managed at the facility, may be included in the data base required to comply with subsection (a)(1)of this section. (B)The owner or operator of an off-site facility may arrange for the generator of the hazardous waste to supply part or all of the information required by subsection (a)(1)of this section, except as otherwise specified in section 66268.7(b)and (c). (3) If the generator does not supply the information as specified in subsection (a)(2)(B)of this section, and the owner or operator chooses to accept a hazardous waste,the owner or operator shall obtain the information required to comply with this section. (4)The analysis shall be repeated as necessary to ensure that it is accurate and up to date.At a minimum,the analysis shall be repeated: (A)when the owner or operator is notified, or has reason to believe, that the process or operation generating the hazardous waste,or non-hazardous waste, if applicable under section 66265.113(d), has changed; and (B)for off-site facilities,when the results of the inspection required in subsection (a)(5)of this section indicate that the hazardous waste received at the facility does not match the waste designated on the accompanying manifest or shipping paper. (5)The owner or operator of an off-site facility shall inspect and, if necessary, analyze each hazardous waste movement received at the facility to determine whether it matches the identity of the waste specified on the accompanying manifest or shipping paper. (b)The owner or operator shall develop and follow a written waste analysis plan which describes the procedures which the owner or operator will carry out to comply with subsection (a)of this section.The owner or operator shall keep this plan at the facility.At a minimum,the plan shall specify: (1)the parameters for which each hazardous waste, or non-hazardous waste if applicable under section 66265.113(d),will be analyzed and the rationale for the selection of these parameters(i.e., how analysis for these parameters will provide sufficient information on the waste's properties to comply with subsection (a)of this section); (2)the test methods which will be used to test for these parameters; (3)the sampling and sampling management methods which will be used to obtain a representative sample of the waste to be analyzed.The sampling, planning methodology, equipment, sample processing, documentation and custody procedures shall be in accordance with either: (A)one of the sampling methods described in Appendix I of chapter 11 of this division; or FA0007094 PR0507000 SCO01 01/22/2020 EHD 22-04 Rev.9/20/2019 Page 4 of 6 Permit By Rule Treatment Facility OIR 1868 E. Hazelton Avenue I Stockton, California 95205 1 T 209 468-3420 1 F 209 464-0138 1 www.sjcehd.com