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Table 1. Response to San Joaquin County EHD Inspection Report =v Alco Iron & Metals Company E N G N r 5 R , N G 1815 Navy Drive, Stockton, California 95206 Item Citation / Required Corrective Action Remarks Corrective Action Statement (Taken or Planned) 115 CCR 66266.81 (a) (4) (B). Failed to retain copy of None. See Attachment 3 for bills of lading for the past three years manifest or bill of lading for spent lead acid provided by Alco. Included are: batteries for 3 years. Attachment 3.1 - Report for all loads shipped as Immediately correct the bills of lading used to batteries from Stockton from July 1, 2017-July 1, transport the lead acid batteries. Submit a 2020. Weight Tag, Bill of Lading, and packing slip corrected form to the EHD once it has been from all of those loads. Alco notes that the first 13 completed. Provide copies of battery core bill of loads went directly to buyer, while the last 5 went to lading records from the last three years for the San Leandro and then to the buyer. transport of lead acid batteries from the facility Attachment 3.2 -Additional loads sent from Stockton directly to the recycler and from the Alco San to San Leandro which had batteries as part of the Leandro location directly to the recycler. In addition, load. These were partial loads. provide a corrective action statement to the San Attachment 3.3 - Summary of all San Leandro Joaquin County Environmental Health Department shipments for batteries from July 1, 2017 -July 1, (EHD)within 30 days. 2020 along with representative examples. Alco can provide additional shipment documentation upon request. Batteries transported between the Alco Stockton and San Leandro facilities shall comply with requirements for Offsite Shipments and Universal Waste Transporters. On July 8, 2020, Alco retrained employees on Alco's Universal Waste management requirements for lead acid batteries. Alco reports that it also working to update its bill of lading procedures to ensure that the bill of lading packages clearly state the origination, destination, and quantity of batteries. 303 CCR 66262.34 (d) (2). Failed to maintain all None. Alco serviced the extinguisher and uncovered the eye wash communication or alarm systems, spill control, or station and prepared each for emergency use on June 12, decontamination equipment. 2020. See Attachment 4 for service documentation. Bring the fire extinguisher and the emergency eyewash station into proper working order by repair, replacement, or testing. Provide a corrective action statement to the San Joaquin County EHD within 30 days. Page 2 of 4