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The following is an itemized list of hazardous waste violations that have not been addressed for QUEST INDUSTRIES LLC as of January 11, 2021. Open violations from November 04, 2020 inspection Violation#204-Failed to obtain a permit to treat hazardous waste. OBSERVATIONS: The facility is treating paint waste. Used paint water is put into a system that concentrates the liquid to a solid. Post-treatment paint waste solids were observed near the treatment unit and outside east of the compressor room. Nasrat Fazli,quality manager,stated that the solids near the treatment unit was post-treatment paint waste. Joel McDonald, plant manager,stated that the solids east of the compressor room was post-treatment paint waste. A sample of each solid was taken on 11/4/2020 by the San Joaquin County Environmental Health Department(EHD). The samples were labeled as SAMPLE 6 and SAMPLE 7. They were tested for the Total Threshold Limit Concentration(TTLC)of inorganic toxic substances. The samples exceeded the non-RCRA hazardous waste threshold as follows: SAMPLE 6-Zinc: 120,000 mg/kg SAMPLE 7-Zinc: 51,000 mg/kg A permit to operate the hazardous waste treatment system has not been issued by the San Joaquin County Environmental Health Department(EHD)or other regulatory agency. REGULATION GUIDANCE: California Health&Safety Code(HSC)section 25201(a) No owner or operator of a storage facility or treatment facility shall treat, store, or dispose of a hazardous waste at the facility, unless the owner or operator holds a hazardous waste facilities permit or other grant of authorization from the department to use and operate the facility, or the owner or operator is operating under a permit-by-rule pursuant to the department's regulations, or a grant of conditional authorization or conditional exemption pursuant to this chapter. Title 22 California Code of Regulations section 66260.10 "Treatment"means any method,technique, or process which changes or is designed to change the physical, chemical,or biological character or composition of any hazardous waste or any material contained therein,or removes or reduces its harmful properties or characteristics for any purpose including, but not limited to,energy recovery, material recovery or reduction in volume. California Health&Safety Code(HSC)section 25123.5 (a) Except as provided in subdivisions(b)and(c),"treatment"means any method,technique, or process which is not otherwise excluded from the definition of treatment by this chapter and which is designed to change the physical,chemical, or biological character or composition of any hazardous waste or any material contained therein, or which removes or reduces its harmful properties or characteristics for any purpose. (b) (1) "Treatment"does not include any of the activities listed in paragraph(2), if one of the following requirements is met: (A) The activity is conducted onsite in accordance with the requirements of this chapter and the department's regulations adopted pursuant to this chapter governing the generation and accumulation of hazardous waste. (B) The activity is conducted in accordance with the conditions specified in a permit issued by the department for the storage of hazardous waste. (2) The activities subject to the exemption specified in paragraph(1)include all of the following: (A) Sieving or filtering liquid hazardous waste to remove solid fractions,without added heat, chemicals, or pressure, as the waste is added to or removed from a storage or accumulation tank or container. For purposes of this subparagraph, sieving or filtering does not include adsorption, reverse osmosis, or ultrafiltration. (B) Phase separation of hazardous waste during storage or accumulation in tanks or containers, if the separation is unaided by the addition of heat or chemicals. If the phase separation occurs at a commercial offsite permitted storage facility, all phases of the hazardous waste shall be managed as hazardous waste after separation. (C) Combining two or more waste streams that are not incompatible into a single tank or container if both of the following conditions apply: (i) The waste streams are being combined solely for the purpose of consolidated accumulation or storage or consolidated offsite shipment, and they are not being combined to meet a fuel specification or to otherwise be chemically or physically prepared to be treated,burned for energy value,or incinerated. (ii) The combined waste stream is managed in compliance with the most stringent of the regulatory requirements Page 9 of 22 i