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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#102-Failed to determine if a waste is a hazardous waste. OBSERVATIONS: Rack 3, along the east wall of the main building, contained paint waste on the top shelf,25 feet above the floor. Six one-cubic yard cardboard boxes and one pallet of six 55-gallon buckets were observed from the floor. According to Nasrat Fazli,quality manager,these paint waste solids were treated in the paint waste treatment system. The waste is being stored until it can be hauled off site by their waste hauler. One box had a yellow label but the details could not be read from 25 feet away. Twelve 5-gallon buckets of paint waste solids,treated in the paint treatment system,were observed in the fabrication room. An old paint water treatment system, no longer being used,was observed in the compressor room. The treatment system contained partially treated paint waste(approximately 100 gallons in two 55 gallon drums). More than forty 5-gallon buckets full of paint waste were observed in the compressor room near the paint treatment system. Seven unlabeled, 55-gallon containers with unknown contents were observed in the boneyard.The drums were not able to be fully inspected as there was not enough aisle space. Three unlabeled, 55-gallon containers of various wastes including filters,gloves and paint solids were observed east of the compressor room. One 275-gallon unlabeled tote of liquid paint waste was observed east of the compressor room stacked with other totes labeled"hazardous waste". A conex box(40 feet length x 8.5 feet high x 8 feet wide),west of the boneyard and east of the compressor room, was filled with 5-gallon buckets of old or recycled paint. According to Nasrat Fazli,quality manager,this paint can be reused in the manufacturing process. It was not clear how long the paint has been on-site. REGULATION GUIDANCE:Any person who generates a waste shall determine if the waste is a hazardous waste as specified in Title 22 CCR.There are wastes that are listed as hazardous wastes.There are wastes that exhibit one or more of the hazardous waste characteristics:toxic, corrosive, reactive or ignitable. Title 22 CCR section 66261.2—Definition of Waste Title 22 CCR section 66261.3—Definition of Hazardous Waste Title 22 California Code of Regulations(CCR section 66260.10 has this definition: "Accumulated speculatively' means that a material is accumulated before being recycled.A material is not accumulated speculatively, however, if the person accumulating it can show that the material is potentially recyclable and has a feasible means of being recycled; and that,during the calendar year(commencing on January 1),the amount of material that is recycled, or transferred to a different site for recycling,equals at least 75 percent by weight or volume of the amount of that material accumulated at the beginning of the period. In calculating the percentage of turnover,the 75 percent requirement is to be applied to each material of the same type(e.g., slags from a single smelting process)that is recycled in the same way(i.e., from which the same material is recovered or that is used in the same way). Materials accumulating in units that would be exempt from regulation under section 66261.4(c)are not to be included in making the calculation. (Materials that are already defined as wastes also are not to be included in making the calculation.)Materials are no longer in this category once they are removed from accumulation for recycling, however. CORRECTIVE ACTION: Immediately make hazardous waste determinations for the wastes listed above and manage it according to Title 22 CCR. Use Safety Data Sheets(SDS),waste sampling and test results or other knowledge to support your hazardous waste determination.Waste testing must be done using methods specified in Title 22 CCR including sections 66261.20-24. Page 2 of 22