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S A N J D AR I N Environmental Health Department Small Quantity Hazardous Waste Generator Inspection Report Facility Name: Facility Address: Date: BRACKETTS BY TINO 21 N STOCKTON ST, LODI December 16, 2019 SUMMARY OF VIOLATIONS (CLASS I,CLASS II,or MINOR-Notice to Comply) Item# Remarks 608 CCR 66266.130 Failed to properly manage used oil and fuel filters. OBSERVATION: This facility generates drained used metal oil filters. A complete three year bill of lading record for used oil filter recycling was not observed during the inspection. Bills of lading were not observed for the following date range: 12/16/19- 12/16/19. REGULATION GUIDANCE: Persons generating,transporting, or receiving used metal oil filters shall use a bill of lading to record the transfer of used oil filters. Bills of lading must indicate generator,transporter, and receiving company names, addresses, telephone numbers,the quantity and size of used oil filter containers transferred, and the date of transfer.A copy of each bill of lading must be kept on the premises of the generator,transporter, and receiving facility where the used oil filters were handled. Copies of bills of lading shall be kept for a period of three years. CORRECTIVE ACTION: Immediately obtain all missing bill of lading recycling records that can be found. Used metal oil filters not stored, handled and disposed of according to this section are regulated as hazardous waste. Provide a corrective action statement, bill of lading recycling records and supporting documentation to the San Joaquin County Environmental Health Department(EHD)within 30 days. ------------------------------------------------------------------------------------------------------------------------------- OBSERVATION: Containers of used metal oil filters out of compliance with the storage rules were observed on-site. The following used metal oil filter containers were on-site: -One 55 gallon drum of drained used oil filters were lacking accumulation start date. -One approximately 10 gallon drum contained used metal oil filters. -This container was not labeled. -The lid on this container had holes for holding funnels for draining. REGULATION GUIDANCE: (b) "used oil filters"are defined as filters which contain a residue of used oil and which are exempt from regulation as a hazardous waste under the scrap metal provision found in federal law. (c)Used oil filters that meet the conditions of subsection (b)of this section and are managed and recycled in compliance with the following requirements shall not be regulated as hazardous waste. (1)The filters are drained of free-flowing used oil. For the purposes of this subsection,free-flowing is defined as a continuous stream of oil exiting the filter when the filter is inverted. Oil exiting drop by drop is not considered to be free-flowing. However, if the filter is equipped with a device(such as a rubber flap located just inside the filter opening)which impedes the drainage of used oil from the filter,that device shall be manipulated to allow the oil to exit the filter freely, or the filter punctured, crushed, opened, drained, or otherwise handled in a manner that will allow the used oil to exit the filter. (2)The drained used oil filters are transported for purposes of metal reclamation to any of the following: (A)A smelter or other scrap metal processor where they are recycled or; (B)A storage facility or consolidation facility that subsequently transfers the filters to a facility described in paragraph (A)or(C)of this subsection or; (C)A municipal solid waste incinerator for energy recovery, if the residual casings are subsequently transferred to a facility described in paragraph (A)of this subsection,or to a storage or consolidation facility that subsequently transfers the residual casings to a facility described in paragraph (A)of this subsection. (3)The drained used oil filters are accumulated, stored, and transferred in a closed, rainproof container that is capable of containing any used oil that may separate from the filters placed inside. Drums of used oil filters shall be FA0013620 PR0517908 SCO01 12/16/2019 EHD 22-01 Rev.9/20/2019 Page 7 of 10 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