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AT&T Services,Inc <br /> Environment, Health&Safety <br /> 2600 Camino Ramon,Room 3E000 <br /> San Ramon,CA 94583 <br /> March 26,2010 <br /> Fax: (209)468-3433 <br /> SENT VIA CERTIFIED MAIL <br /> #70081830 0003 2652 9835 <br /> Mr.Garrett Backus,Inspector <br /> San Joaquin County <br /> Environmental Health Department(CUPA) <br /> 600 E.Main Street, <br /> Stockton CA 95202-3029 <br /> RE: Your Inspection on 2-26-10 at AT&T Facility 2300 E.EIGHT MILE RD.,STOCKTON, <br /> CA 95210(UE17L)ITS#107629 <br /> Dear Mr. Backus: <br /> This letter is to acknov ledge the violation for which you cited us in your report for the inspection above. Specifically, <br /> you reference CCR 66 62.11 Failed to determine if a waste is a hazardous waste. Your note reads in salient part: <br /> "Notice of Viola 'on, Class IL #7 Failed to determine if a waste is a hazardous waste. Facility <br /> generates metal havings from brake rotor lathe operations. Metal waste that is>I00 microns in <br /> size can be sent i 9 a metal recycler. Title 22 listed metal waste that is<I00 microns in size must be <br /> handled and dis iosed of as hazardous waste. Facility could not provide hazardous waste manifests <br /> for metal dust les than 100 microns in size(Title 22 listed metals). <br /> "Make a hazard us waste determination on the brake rotor lathe shavings as specified in Title 22 <br /> California code f Regulations or handle as hazardous waste. Correct by 3-26-10. Send copies of <br /> scrap metal recycling receipts for the last two pick-ups of scrap metal to the environmental Health <br /> Department(ERD)by 3-26-10. <br /> "Summary of Violations-#7 Class H <br /> "Notes: #1) Fill out and return the following by 3-26-10: <br /> > Return to Compliance Certification Form <br /> > A corrective action statement for each violation <br /> > Supporting documentation <br /> #2) Facility generated 5.7 tons of HW in 2008 and 8.5 tons HW in 2009" <br /> However,AT&T arse s that it has complied with that requirement because generator knowledge is sufficient to <br /> determine that the wasi a in question is not a hazardous waste.The waste in question consists of metal shavings <br /> from vehicle brake m ntenance work.Most of these shavings are scrap metal,which is conditionally excluded <br /> from the definition of hazardous waste(see 22 Calif.Code of Regulations Section 66260.10).Of the six <br /> exclusions from the de nition of"scrap metal,"only one is relevant here:the exclusion of"Sludge,fine <br /> powders,semi-solids d liquids that are hazardous wastes." <br /> "Fine powder"is defin d as"a metal in dry,solid form having a particle size smaller than 100 micrometers <br /> (0.004 inches)or microns in diameter".The brake shaving waste in question includes some particles of less than <br /> 100 microns(about 0.08%of the total waste,by weight;see Attachment 1).However,under California law,such <br /> particles are not autom itically hazardous waste. Rather,they are hazardous waste only if they are a listed <br /> hazardous waste metal which these are not,or if they exhibit a hazardous waste characteristic. <br />