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ATTACHMENT 10: Corrective Action Response to Management of Empty Aerosol Cans During the 9/18/2019 Inspection, the SJCEHD Inspector was informed by Frank Stanich, Lead Mechanic for the WFS Stockton Station, that aerosol cans are managed on site by removing the actuators, then puncturing the disabled can. As a consequence of the information provided to the SJCHD Inspector, the following violations were issued: • Violation #710: HSC 25201.16(h)(4)- No written operating procedure for aerosol can processing; and • Violation #711: HSC 25201.16(j)- Failed to submit or amend notification for aerosol can processing The information provided to Mr. Alaniz at the time of the 9/18/2019 inspection was incorrect. Upon further review Mr. Stanich clarified that the only aerosol cans that he had punctured were empty aerosol cans. According to California's universal waste regulations, empty aerosol cans are not a regulated waste subject to California's universal waste requirements, including the requirement to develop a written operating procedure for processing of non-empty aerosol cans. Effective 2/15/2021 all aerosol cans will be managed as a regulated universal waste limited to the follows: • All aerosol cans will be assumed to be non-empty at the time of disposal; • The valve head shall be removed, and the valve stem cut back to below the top of the can's rim to prevent potential discharge during accumulation; and • Disabled aerosol cans will be segregated and accumulated based on the hazard classification of the can's content