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ATTACHMENT 1: Corrective Action Response Regarding Used Oil Containing Material During the 9/18/2019 Hazardous Waste Generator inspection, the EJCEHD Inspector observed a 30-gallon drum and a 5-gallon cardboard box containing oily debris. In response to this observation, the following hazardous waste management violations were issued: • Violation #402: The facility has hazardous waste stored in a container that is not compatible with the waste; • Violation #403: Failed to keep hazardous waste containers closed except when adding or removing hazardous waste; • Violation #601: Stored hazardous waste onsite greater than 180 days: and • Violation #605: Failed to completely label containers or portable tanks of hazardous waste However, based on the following regulatory language and/or DTCS guidance, material that do not contain free-flowing used oil do not meet the definition of 'used oil'. Consequently, unless the material contaminated with residual used oil exhibit a characteristic of a hazardous waste, or is burned for energy recovering, the material containing non-free flowing used oil is considered non-hazardous and not subject to California's hazardous waste control laws: • Heath & safety Code Div 20, Chapter 6.5, Sections 25250.1 and 25250.4 • DTSC Guidance Document: Managing Textile Materials Soiled with Hazardous Waste (refer to Attachment 2) • 22 CCR 6626.130(c)(1) The oily debris observed during the 9/18/2019 inspection contained residual used oil (i.e., non-free-flowing) generated from the daily cleanup of incidental spills/leaks of motor oils from GSE when is use. Additionally, based on generator knowledge, the oily debris is not expected to exhibit any characteristic of a hazardous waste. Nor is the oily debris burned for energy recovery. The WFS-Stockton Station has identified and profiled all regulated wastes routinely generated at the site. Refer to the attached Regulated Waste Management Matrix for waste-specific management requirements (refer to Attachment 2). Effective 2/5/2021 all oily debris will be managed either as Oily Solids (CWC 223) for dry used absorbents; or as Oily Sludge (CWC 222) for wet/saturated used absorbents.