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ATTACHMENT 2: Corrective Action Response to Violation #102- Failed to determine if a waste is a hazardous <br /> waste <br /> At the time of the 9/18/2019 inspection, the SJCEHD Inspector, Mr. John Alaniz, was informed that the WFS- <br /> Stockton (WFS-SCK) Station's Lead Mechanic takes the oily rags and washes them at a laundromat. This <br /> violation presumes that the oily rags generated at the facility are a hazardous waste. They are not. <br /> According to DTSC's guidance regarding the Managing Textile Materials Soiled with Hazardous Waste (see <br /> attached) oily rags that do not contain free-flowing used oil do not meet the definition of 'used oil' . <br /> Consequently, unless the oily rags exhibit a characteristic of a hazardous waste, dry soiled oily rags are <br /> considered non-hazardous and not subject to California's hazardous waste control laws, including the <br /> exemption in HSC Section 25144.6. <br /> According to Mr. Frank Stanich, WFS-SCK Lead Mechanic, the oily rags were typically generated from cleaning <br /> the mechanics' hands of oils, greases during maintenance and repair of the Station's Ground Service <br /> Equipment (GSE). The mechanics use a waterless hand cleaner/degreaser to clean their hands.The oily rags <br /> are generated from wiping the hand cleaner off their hands after application/use. <br /> WFS-SCK has identified and profiled all regulated wastes routinely generated at the site. Refer to the attached <br /> Regulated Waste Management Matrix for waste-specific management requirements. Effective 2/5/2021 all <br /> used oily rags will be managed either as Oily Solids (CWC 223) for dry soiled oily rags; or as Oily Sludge (CWC <br /> 222) for wet/saturated soiled oily rags. <br />