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S A N J 0 A Q I I I Irl Environmental Health Department <br /> C C U N T AMENDED <br /> 4/17/2020 <br /> RCRA Large Quantity Hazardous Waste Generator Inspection Report <br /> Facility Name: Facility Address: Date: <br /> APPLIED AEROSPACE STRUCTURES CORP 3437 S AIRPORT WAY, STOCKTON January 22, 2020 <br /> SUMMARY OF VIOLATIONS <br /> (CLASS I,CLASS II,or MINOR-Notice to Comply) <br /> Item# Remarks <br /> 204 HSC 25201(a)Failed to obtain a permit to treat hazardous waste. <br /> OBSERVATION: Waste wipes generated from wiping down parts at the facility are placed in containers labeled as <br /> hazardous waste. Periodically the containers are taken to centralized locations where the waste is consolidated and <br /> then compacted using a RAM FLAT COMPACTOR machine to reduce the waste volume. The compacted wipes <br /> are then disposed of as a RCRA hazardous waste for being flammable and toxic(RCRA waste codes: D001, D007, <br /> D035, F003, F005 and California Waste Code 352). Two compaction systems were observed during the inspection. <br /> US EPA guidance from RCRA Online document 11609 indicates that this operation is exempt from a treatment <br /> permit with US EPA. However, in California, a hazardous waste treatment permit is required for this activity from <br /> the California Department of Toxic Substances Control. A permit to operate this hazardous waste treatment <br /> process has not been issued by the San Joaquin County Environmental Health Department(EHD)or other <br /> regulatory agency. <br /> REGULATION GUIDANCE: <br /> California Health&Safety Code section 25201(a) <br /> No owner or operator of a storage facility or treatment facility shall treat, store, or dispose of a hazardous waste at <br /> the facility, unless the owner or operator holds a hazardous waste facilities permit or other grant of authorization <br /> from the department to use and operate the facility, or the owner or operator is operating under a permit-by-rule <br /> pursuant to the department's regulations, or a grant of conditional authorization or conditional exemption pursuant to <br /> this chapter. <br /> Title 22 California Code of Regulations section 66260.10 <br /> "Treatment"means any method,technique, or process which changes or is designed to change the physical, <br /> chemical, or biological character or composition of any hazardous waste or any material contained therein, or <br /> removes or reduces its harmful properties or characteristics for any purpose including, but not limited to, energy <br /> recovery, material recovery or reduction in volume. <br /> CORRECTIVE ACTION: Immediately cease treatment of hazardous waste wipes until a permit is issued. A permit <br /> for the treatment of this RCRA hazardous waste cannot be issued by the San Joaquin County Environmental Health <br /> Department because it outside our authority as a Certified Unified Program Agency. Apply for a hazardous waste <br /> treatment permit with the California Department of Toxic Substances Control. Store and dispose of the hazardous <br /> waste as specified in Title 22 California Code of Regulations until the treatment permit is obtained. Provide a <br /> corrective action statement and supporting documentation to the EHD within 30 days. <br /> This is a repeat violation. <br /> This is a Class I violation. <br /> FA0007094 PR0505939 SCO01 01/22/2020 <br /> EHD 22-03 Rev.9/20/2019 Page 5 of 8 RCRA Large Quantity Hazardous Waste Generator OIR <br /> 1868 E. Hazelton Avenue I Stockton, California 95205 1 T 209 468-3420 1 F 209 464-0138 1 www.sjcehd.com <br />