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The following is an itemized list of hazardous waste violations that have not been addressed for PANELLA TRUCKING LLC as of December18, 2019. Open violations from October 29, 2019 inspection Violation #102 -Failed to determine if a waste is a hazardous waste. OBSERVATIONS Metal fines are generated from grinding equipment in the main shop and welding shop. Currently metal fines are being recycled before making a hazardous waste determination. REGULATION GUIDANCE: Any person who generates a waste shall determine if the waste is a hazardous waste as specified in Title 22 California Code of Regulations (CCR). There are wastes that are listed as hazardous wastes. There are wastes that exhibit one or more of the hazardous waste characteristics: toxic, corrosive, reactive or ignitable. Metal particles 100 microns or smaller in size must be handled and disposed of as hazardous waste if the metal is determined to be a hazardous waste. Metal particles larger than 100 microns in size can be recycled as scrap metal. CORRECTIVE ACTION: Immediately stop recycling metal fines and make a hazardous waste determination for each waste and manage it according to Title 22 CCR. Use Safety Data Sheets (SDS), waste sampling and test results or other knowledge to make your hazardous waste determination. Waste testing must be done using methods specified in Title 22 CCR including Title 22 CCR sections 66261.20-24. Submit a statement and supporting documentation with your hazardous waste determination. Demonstrate current storage and labeling for wastes determined to be hazardous wastes. Provide disposal records for wastes determined to be hazardous wastes and stored longer than the number of days specified in Title 22 CCR for your hazardous waste generator status. ❑ This violation was corrected ❑ This violation will be corrected by (date): ❑ Supporting documents included Describe actions taken or will be taken to correct violation: Violation #114-Failed to keep signed copy of manifests from the designated facility for three years. OBSERVATION: The following designated facility signed copies of Uniform Hazardous Waste Manifest(UHWM) numbers were not found on-site: -011209218FLE (2/14/2018) -012800765FLE (3/10/2019) -012794927FLE (6/23/2019) REGULATION GUIDANCE: A hazardous waste generator shall keep a copy of each manifest signed in accordance with section 66262.23(a) for three years or until the generator receives a signed copy from the designated facility which received the waste. This signed copy shall be retained as a record for at least three years from the date the waste was accepted by the initial transporter. The hazardous waste generator must submit a copy of the manifest to the California Department of Toxic Substances Control(DTSC)within 60 days if the destination facility signed manifest copy is not received from the transporter or designated facility. CORRECTIVE ACTION: Locate a copy of the destination facility signed manifests and send a copy to the San Joaquin County Environmental Health Department(EHD). If the destination facility signed manifests cannot be found then send to DTSC a copy of each generator signed manifest and a statement that the designated facility signed copy was not received by the generator. DTSC address is DTSC Report Repository, Generator Information Services Section, PO Box 806, Sacramento, CA 95812-0806. Provide a corrective action statement to the EHD within 30 days. Page 1 of 4