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A N J O A Q U IN Environmental Health Department COUNTY— Large Quantity Hazardous Waste Generator Inspection Report Facility Name: Facility Address: Date: STOCKTON STEEL CO 3003 E HAMMER LN, STOCKTON March 11, 2020 SUMMARY OF VIOLATIONS (CLASS I,CLASS II,or MINOR-Notice to Comply) Item# Remarks 609 HSC 25143.2,25143.9 Failed to meet requirements for claimed excluded recyclable materials. OBSERVATIONS:The facility generates"spent grit"which consists of sand blast dust, bag house dust and welding slag. The"spent grit' is periodically transported from the site to Kleen Industrial Services on a bill of lading as an excluded recyclable material (ERM)for cement manufacturing. The facility did not provide documentation supporting the ERM status of the spent grit that is used in cement manufacturing. ERM used in this manner are recyclable materials that are placed on land since concrete is commonly used on land. The facility must demonstrate that the ERM meets the requirements in Title 22 CCR section 66266.21. LAW and REGULATION sections: California Health and Safety Code(HSC)sections 25143.2 and 25143.9 Title 22 California Code of Regulation (CCR)section 66266.21 CORRECTIVE ACTIONS: Immediately begin managing this material as hazardous waste or demonstrate to the San Joaquin County Environmental Health Department(EHD)that the material meets the excluded recyclable material (ERM) requirements. Provide the following to satisfy the ERM requirements: 1. Show compliance with HSC 25143.2(f)(1)(A)by providing the name, street and mailing address, and telephone number of the owner or operator of the receiving facility that manages the ERM. 2. Show compliance with HSC 25143.2(f)(2)by providing documents that demonstrate a known market or disposition for the ERM and resulting cement product made from the ERM. 3. Show compliance with HSC 25143.9 by labeling all containers of the ERM with the words"Excluded Recyclable Material',your business name, address, composition of the ERM, physical state, hazardous properties and the accumulation start date. 4. Show compliance with Title 22 California Code of Regulations(CCR)section 66266.21 including 66266.21(b) (5). Demonstrate that the hazardous constituents in the recyclable material are bound in the product so that they would not exceed the applicable Soluble Threshold Limit Concentrations (STI-Cs)set forth in T22 CCR section 66261.24(a)(2)(A). Provide analytical results for the product made from this ERM in compliance with this section. 5. Show compliance with Title 22 CCR 66266.21(b)(6): Provide evidence that the final product does not contain constituents at concentrations that cause the product to exhibit hazardous waste other than those constituents that are also found in the same or greater concentrations in a comparable commercial product. 6. Show compliance with Title 22 CCR 66266.21(b)(7): Provide a written certification from a qualified independent engineer or engineering geologist, registered in the state of California,that the recyclable material and the product containing that material meet the applicable standards or specifications for the intended use of the recyclable material and product of the American Society for Testing and Materials(ASTM),the American Association of State Highway and Transportation Officials(AASHTO),the American National Standards Institute(ANSI),the Uniform Building Code(UBC), or the standards of a government agency having jurisdiction over the applications of that recyclable material or product. This is a Class II violation. FA0004400 PR0513715 SCO01 03/11/2020 EHD 22-02 Rev.9/20/2019 Page 12 of 13 Large Quantity Hazardous Waste Generator OIR 1868 E. Hazelton Avenue I Stockton, California 95205 1 T 209 468-3420 1 F 209 464-0138 1 www.sjcehd.com