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SAN J O A Q U I N Environmental Health Department I YAMFiNDiiD 3/19/2020 Small Quantity Hazardous Waste Generator Inspection Report Facility Name: Facility Address: Date: UNIVERSAL SERVICE RECYCLING LLC 3200 S EL DORADO ST, STOCKTON March 12, 2020 SUMMARY OF VIOLATIONS (CLASS I,CLASS Il,or MINOR-Notice to Comply) Item# Remarks 609 HSC 25143.2, 25143.9 Failed to meet requirements for claimed excluded recyclable materials. OBSERVATION: Metal recyclables are received and processed at the facility. Recyclable items which contain materials that require special handling(MRSH)are not currently accepted by this facility. The facility has processed items with MRSH in the past under their Certified Appliance Recycler certificate. Shredder equipment is used to create smaller pieces of recyclable material and split the material streams into ferrous and nonferrous piles. Coarse shredded scrap metal(ferrous and non-ferrous)and fine soil-like material are three material streams produced by the shredding process. Copper containing scrap is picked out manually during the shredding process. The fine soil-like material is being stored on the site in piles under the shredding equipment and at the end of the non-ferrous shredding process. The piles are partially covered and stored on concrete and metal plating. Run-on protection from rain is incomplete. The pile stored on metal plating appears to have a two inch high metal curb but the pile is too large to be contained by the curb and overflowed onto the adjacent concrete pad. Liquid was puddling next to the pile. The piles under the shredding equipment are stored on concrete and have no curbing to prevent run-on of rain water and run-off of leachate from the pile during rain. A few open top metal containers were observed storing some fine soil-like material and the containers were not labeled. Water runoff from the Concrete pad under the shredding equipment goes through a clarifier and ends up at an on-site pond. The fine soil-like material is not reported on the California Environmental Reporting System(CERS)in the hazardous materials inventory. Prior to 1-1-20 the fine soil-like material was being shipped off-site in railcars as"non-RCRA shredder residue"with hazardous waste manifests. After 1-1-20 the fine soil-like material is being shipped off site in trucks as"metal shredder aggregate—excluded recyclable material'on excluded recyclable material(ERM)manifests. The fine soil-like material being hauled off the site as ERM does not currently meet the storage and labeling requirements or business plan requirements of California Health and Safety code section 25143.9 and Title 22 California Code of Regulations sections 66265.170-178(containers), 66265.190-202(tanks),66265.250-260(waste piles)for ERM. The facility personnel could not provide details that demonstrate that the ERM is a non-RCRA hazardous waste as required by HSC 25143.2(d). RCRA hazardous waste does not qualify for the HSC 25143.2(d)exclusion. The facility personnel could not provide details that demonstrate that the ERM is being recycled at its destination in Carson City, Nevada which is required by HSC 25143.2(d)(3). REGULATION GUIDANCE: See California Health&Safety Code section 25143.2 and 25143.9 for the complete statute. See Title 22 California Code of Regulations for hazardous waste regulation. Some parts are included here: HSC 25143.2. (d) Except as otherwise provided in subdivisions(e), (0, (g), and(h), recyclable material that meets the definition of a non-RCRA hazardous waste in Section 25117.9, is managed in accordance with Section 25143.9, and meets or will meet any of the following requirements is excluded from classification as a waste: (3) The material is transported between locations operated by the same person who generated the material, if the material is recycled at the last location operated by that person and all of the conditions of clauses(i)to(vi), inclusive, of subparagraph(A)of paragraph(4)are met. If requested by the department or by any official authorized to enforce this section pursuant to subdivision(a)of Section 25180, a person handling material subject to this paragraph,within 15 days from the date of receipt of the request, shall supply documentation to show that the requirements of this paragraph have been satisfied. HSC 25143.9. A recyclable material shall not be excluded from classification as a waste pursuant to subdivision(b) FA0011200 PRO521451 SCO01 03/12/2020 EHD 22-01 Rev.9/20/2019 Page 15 of 17 Small 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