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A J OA U I Environmental Health Department COUNTY Small Quantity Hazardous Waste Generator Inspection Report Facility Name: Facility Address: Date: Pershing Holdings, Inc. DBA Esclon Arco 1329 Esc Ave, Escalon February 19, 2020 SUMMARY OF VIOLATIONS (CLASS I,CLASS II,or MINOR-Notice to Comply) Item# Remarks 601 CCR 66262.34(d) Stored hazardous waste onsite greater than 180 days. OBSERVATION: The following hazardous waste containers were found on-site with an accumulation start date of greater than 180 days or no accumulation start date: A 55 gallon blue steel drum of petroleum mix with water was observed in the dumpster area with no start date. REGULATION GUIDANCE: (a) Except as provided in subsections (c) and (d) of this section and section 66262.35, a generator may accumulate hazardous waste on-site for 90 days or less without a permit or grant of interim status, provided that: (b)The beginning of the 90 day period specified in subsections (a) and (c) of this section is determined as follows: (1) if the generator does not generate more than 100 kilograms of hazardous waste or one kilogram of acutely hazardous waste (listed in section 66261.33(e))or one kilogram of extremely hazardous waste during any calendar month, the 90 day period begins on the date the generator has accumulated 100 kilograms of hazardous waste or one kilogram of acutely hazardous waste or one kilogram of extremely hazardous waste; (2) if the generator generates more than 100 kilograms of hazardous waste or one kilogram of acutely hazardous waste or one kilogram of extremely hazardous waste during any calendar month, the 90-day period begins on the first date on which any amount of hazardous waste begins to accumulate during that month. (d) Notwithstanding subsections (a)and (c)of this section and section 66262.35, a generator of less than 1,000 kilograms of hazardous waste in any calendar month who accumulates hazardous waste onsite for 180 days or less, or 270 days or less if the generator transports the generator's own waste, or offers the generator's waste for transportation, over a distance of 200 miles or more, for offsite treatment, storage, or disposal, is not a storage facility if all of the following apply: (1)The quantity of hazardous waste accumulated onsite never exceeds 6,000 kilograms. (2)The generator complies with the requirements of 40 Code of Federal Regulations section 262.34(d), (e) and (f). (3)The generator does not hold acutely hazardous waste or extremely hazardous waste in an amount greater than one kilogram for more than 90 days. CORRECTIVE ACTION: Immediately dispose of the hazardous waste stored on site greater than 180 days in compliance with Title 22 California Code of Regulations. Provide a corrective action statement and a copy of the disposal records to the San Joaquin County Environmental Health Department(EHD)within 30 days. This is a Class II violation. FA0000293 PR0542875 SCO01 02/19/2020 EHD 22-01 Rev.9/20/2019 Page 5 of 7 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