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Environmental Health Department <br />CP22 - Tiered Permitting PBR Inspection Report <br />Date: <br />February 18, 2025 <br /> Facility Address: <br /> 3437 S AIRPORT WAY, STOCKTON <br /> Facility Name: <br /> APPLIED AEROSPACE STRUCTURES CORP <br />SUMMARY OF VIOLATIONS <br />(CLASS I, CLASS II, or MINOR - Notice to Comply) <br />RemarksItem # <br />CA Code of Regulations 67450.2(b)(3) 3210044 - Generator and treatment unit information, and unit location map <br />submitted in CERS. <br />OBSERVATION: The facility operator has not submitted complete and correct information in the California <br />Environmental Reporting System. The following items were not submitted for 2025: <br />-Most recent Local Agency notification <br />-Property Owner Notification <br />-Tank and Container Certification <br />REGULATION GUIDANCE: See California Health & Safety Code section 67450.2(b)(3) for details. <br />CORRECTIVE ACTION: Update and submit the hazardous waste treatment information in CERS. Provide a corrective <br />action statement and supporting documentation to the San Joaquin County Environmental Health Department within <br />30 days. <br />This is (Minor) Violation. <br /> 4 <br />CA Code of Regulations 67450.13(a)(1), b 3210026 - Completed and submitted a Cert of Financial Assurance , Closure <br />Cost Estimate, & Fin Assurance Mech. <br />OBSERVATION: This facility is treating hazardous waste but has not submitted a complete written estimate of the <br />cost of closing each fixed treatment unit (FTU) and financial assurance certification to the California Environmental <br />Reporting System (CERS). <br />-Multiple discrepancies were observed in the financial test letter uploaded in 2025. Dates from different years were <br />cited as the source of the numbers used for the financial test. <br />-Current corporate credit rating is missing. <br />-The number of drums required for closure decreased from 22 drums in the 2023 submittal to 17 drums in the 2024 and <br />2025 submittals. No changes were noted in the operation of the tank during this timeframe. <br />-The cost of closure estimate includes four UN17-H 55-gallon drums but the cost of disposal of these drums is not <br />included. <br />-The estimate of closure cost states that Applied Aerospace would use their own engineer for review and closure <br />certification. A third party engineer is required to review and certify closure . <br />REGULATION GUIDANCE: The owner or operator of a fixed treatment unit (FTU) shall prepare a written estimate of the <br />cost of closing each unit. The estimate shall equal the actual cost or the costs estimated by an owner or operator or a <br />generator that would be incurred for closing a treatment unit when using the owner or operator or generator's own staff <br />and/or personal equipment. The closure cost estimate may take into account any salvage value that may be realized <br />from the sale of wastes, facility structure or equipment, land or other facility assets. <br />CORRECTIVE ACTION: Immediately submit the required closure cost estimate for each FTU and financial assurance <br />certification to CERS for review by the San Joaquin County Environmental Health Department (EHD). Provide a <br />corrective action statement and supporting documentation to the EHD within 30 days. <br />This is (Class 2) Violation. <br /> 6 <br />CA Code of Regulations 66265.191(k) 3210015 - Existing HW tank system assessment is complete. <br />OBSERVATION: This facility has existing hazardous waste treatment tank systems with incomplete tank <br />assessments. The following discrepancies were observed within the tank system assessment: <br /> 16 <br />FA0007094 PR0507000 SC001 02/18/2025 <br />EHD Rev. 12/06/2021 CP22 - Tiered Permitting PBR OIRPage 3 of 5 <br />1868 E. Hazelton Avenue | Stockton, California 95205 | T 209 468-3420 | F 209 464-0138 | www.sjgov.org/EHD