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Table 1. Response to San Joaquin County EHD Inspection Report <br /> =v Alco Iron & Metals Company <br /> E N G N r 5 R , N G 1815 Navy Drive, Stockton, California 95206 <br /> Item Citation / Required Corrective Action Remarks Corrective Action Statement <br /> (Taken or Planned) <br /> 102 CCR 66262.11. Failed to determine if a waste is a Alco reports that the red The area has been cleaned and Alco retrained staff on <br /> hazardous waste. material observed by San handling of maintenance fluids on July 8, 2020. See <br /> Immediately make a hazardous waste Joaquin Environmental Attachment 8. <br /> determination for each waste and manage it Health Department (EHD) <br /> according to Title 22 CCR. Use Safety Data Sheets was fuel that had been <br /> (SDS), waste sampling, and test results or other drained during repair of a <br /> knowledge to support your hazardous waste piece of equipment <br /> determination. Waste testing must be done using (grappler). The fuel was not <br /> methods specified in Title 22 CCR including section waste and will be consumed. <br /> 66261.20-24. <br /> 108 CCR 66262.23 (a). Failed to complete, sign, or Alco reports that facility staff Alco submitted manifest correction letters to DTSC on July 8, <br /> date manifest; or obtain dated signature of erroneously associated 2020. See Attachment 2. <br /> transporter. manifest 007313217SKS <br /> A manifest correction letter must be sent to the (10/21/19 shipment)with <br /> Department of Toxic Substances Control (DTSC) wastewater sludge. In fact, <br /> whenever hazardous waste manifests submissions both waste shipments under <br /> contain incorrect or incomplete information. manifests 00696009S1KS <br /> (6/3/19 shipment) and <br /> 007313217SKS (10/21/19 <br /> shipment)were waxy paper <br /> waste from the wire stripper <br /> operation. <br /> 112 CCR 66268.7 (a). Failed to make determination for None. Alco indicates they have ceased stripping of the lead- <br /> land disposal. insulated copper wire at the current time. Should Alco <br /> Provide a corrective action statement and resume generation of this material, Alco indicates that they <br /> supporting documentation within 30 days to the will perform analytical testing to characterize the waste, <br /> San Joaquin County Environmental Health develop a waste profile, complete land disposal <br /> Department. determination, and ship waste to a permitted treatment <br /> storage and disposal facility. <br /> Page 1 of 4 <br />