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A N J O A Q U IN Environmental Health Department <br /> COUNTY— <br /> Large Quantity Hazardous Waste Generator Inspection Report <br /> Facility Name: Facility Address: Date: <br /> STOCKTON STEEL CO 3003 E HAMMER LN, STOCKTON March 11, 2020 <br /> SUMMARY OF VIOLATIONS <br /> (CLASS I,CLASS II,or MINOR-Notice to Comply) <br /> Item# Remarks <br /> 103 CCR 66262.40(c) Failed to retain hazardous waste determination including waste analysis on site for 3 years. <br /> OBSERVATION: Spent grit waste(project SFO-19-054)was sampled on 2-5-19 and had a chromium TTLC result of <br /> 1060 ppm and a STLC result of 18 ppm. The grit waste had a copper TTLC result of 893 ppm. No chromium TCLP <br /> or copper STLC test results were available to demonstrate if the waste was RCRA hazardous waste, non-RCRA <br /> hazardous waste or non-hazardous waste. The spent grit waste is being hauled offsite as Excluded Recyclable <br /> Material (ERM)for cement manufacturing. RCRA hazardous waste of this type does not qualify for ERM handling. <br /> The business operator does not have hazardous waste determination records that support the current handling and <br /> disposal of the waste. <br /> REGULATION GUIDANCE:A business operator shall keep records of any hazardous waste determinations made <br /> in accordance with Title 22 California Code of Regulations(CCR)section 66262.11 for at least three years from the <br /> date that the waste was last sent to an on-site or off-site treatment, storage, or disposal facility. The records may <br /> include Safety Data Sheets(SDS),waste test results or other hazardous waste determination documentation. <br /> CORRECTIVE ACTION: Provide the Chromium TCLP and Copper STLC data for the 2-5-19 spent grit waste <br /> sample, maintain on site and submit a copy to the San Joaquin County Environmental Health Department(EHD). <br /> If hazardous waste determination documentation is not available, immediately make a hazardous waste <br /> determination and begin managing the spent grit waste as specified in Title 22 CCR. Use Safety Data Sheets <br /> (SDS),waste sampling and test results or other knowledge to support your hazardous waste determination. Waste <br /> testing must be done using methods specified in Title 22 CCR including sections 66261.20-24. Submit a statement <br /> and supporting documentation with your hazardous waste determination. <br /> This is a Class II violation. <br /> FA0004400 PR0513715 SCO01 03/11/2020 <br /> EHD 22-02 Rev.9/20/2019 Page 6 of 13 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 />