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SAN JOAO IN cijulvIY �Jt� �o/airy Environmental Health Department Small Quantity Hazardous Waste Generator Inspection Report Facility Name: Facility Address: Date: OLD CASTLE INFRASTRUCTURE 10304 W LINNE RD, TRACY September 12, 2019 SUMMARY OF VIOLATIONS (CLASS I, CLASS II, or MINOR - Notice to Comply) Item # Remarks disposal records and supporting documentation to the San Joaquin County Environmental Health Department (EHD) within 30 days. This is a minor violation. 704 CCR 66273.33(b) UW handler failed to properly manage universal waste lamps. OBSERVATION: The facility is managing universal waste (UW) lamps in a way that does not prevent a release of waste to the environment. The UW lamps are being stored - One metal blue container with approximately 20 fluorescent lamps observed not contained in a manner that prevents release. REGULATION GUIDANCE: (b) Lamps (including M003 wastes that contain lamps). A universal waste handler shall manage lamps in a way that prevents releases of any universal waste or component of a universal waste to the environment, as follows: (1) A universal waste handler shall contain any lamp in a container or package that is structurally sound, adequate to prevent breakage, and compatible with the contents of the lamp. Such a container or package shall remain closed and shall lack evidence of leakage, spillage or damage that could cause leakage under reasonably foreseeable conditions. (2) A universal waste handler shall immediately clean up and place in a container any lamp that is broken and shall place in a container any lamp that shows evidence of leakage or damage that could cause the release of mercury or other hazardous constituents to the environment. Containers shall be closed, structurally sound, compatible with the contents of the lamps and shall lack evidence of leakage, spillage, or damage that could cause leakage or releases of mercury or other hazardous constituents to the environment under reasonably foreseeable conditions. (3) A universal waste handler may remove a lamp from a product or structure, provided the universal waste handler removes the lamp in a manner designed to prevent breakage. CORRECTIVE ACTION: Immediately place all UW lamps into closed, structurally sound containers with labeling: "universal waste - lamps". Provide a corrective action statement and supporting documentation to the San Joaquin County Environmental Health Department (EHD) within 30 days. This is a minor violation. 712 CCR 66273.34 UW handler (UWH) failed to label universal waste to identify type of universal waste. OBSERVATION: The following were observed in the scrap metal collection area: - One metal blue container with approximately 20 fluorescent lamps observed with no universal waste label. REGULATION GUIDANCE: Universal waste shall be marked with the words "Universal Waste" and the type of waste (batteries, mercury containing equipment, lamps, electronic devices, CRTs, CRT glass). CORRECTIVE ACTION: Immediately label these wastes and ensure that all universal wastes are labeled with the required information. Submit any statement/ documentation to Environmental Health Department. This is a minor violation. FA0010036 PR0539719 SC001 09/12/2019 EHD 22-01 Rev. 9/20/2019 Page 9 of 11 Small Quantity Hazardous Waste Generator OIR 1868 E. Hazelton Avenue � Stockton, California 95205 � T 209 468-3420 � F 209 464-0138 � www.sjcehd.com