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S A N J D AR I N Environmental Health Department <br />L)U ;" 1 Y <br />Small Quantity Hazardous Waste Generator Inspection Report <br />Facility Name: Facility Address: Date: <br />MADRUGA IRON WORKS INC 305 GANDY DANCER DR, TRACY September 25, 2020 <br />SUMMARY OF VIOLATIONS <br />CLASS I,CLASS II,or MINOR-Notice to Comply) <br />Item# Remarks <br />102 CCR 66262.11 Failed to determine if a waste is a hazardous waste. <br />OBSERVATIONS: The following was observed adjacent to the west building (345 formally 305B): <br />One 55-gallon container with waste laser filters from the laser cutting machines. Operator stated that laser filters <br />are disposed of in the garbage. <br />Metal dust from laser cutting machines observed on the ground and inside scrap metal recycling bins. Operator <br />stated metal dust are recycled by a scrap metal recycler. <br />Note: Operator stated metal dust comes from Carbon Steel Mebac and Aluminum Alloy metals. Safety Data Sheet <br />for aluminum alloy stated "in the form of particulates may be reactive and its hazardous characteristics should be <br />determined prior to disposal." <br />REGULATION GUIDANCE: Any person who generates a waste shall determine if the waste is a hazardous waste <br />as specified in Title 22 California Code of Regulations(CCR). There are wastes that are listed as hazardous <br />wastes. There are wastes that exhibit one or more of the hazardous waste characteristics:toxic, corrosive, reactive <br />or ignitable. Metal particles 100 microns or smaller in size must be handled and disposed of as hazardous waste if <br />the metal is determined to be a hazardous waste. Metal particles larger than 100 microns in size can be recycled as <br />scrap metal. <br />CORRECTIVE ACTION: Immediately stop recycling metal dust as scrap metal and disposal of laser filters in the <br />garbage, make a hazardous waste determination for each waste , and manage it according to Title 22 CCR. Use <br />Safety Data Sheets (SDS),waste sampling and test results or other knowledge to make your hazardous waste <br />determination. Waste testing must be done using methods specified in Title 22 CCR including Title 22 CCR <br />sections 66261.20-24. <br />Submit a statement and supporting documentation with your hazardous waste determination. Demonstrate current <br />storage and labeling for wastes determined to be hazardous wastes. Provide disposal records for wastes <br />determined to be hazardous wastes and stored longer than the number of days specified in Title 22 CCR for your <br />hazardous waste generator status. <br />This is a minor violation. <br />FA0010031 PR0514135 SCO01 09/25/2020 <br />EHD 22-01 Rev.9/16/2020 Page 4 of 6 Small Quantity Hazardous Waste Generator OIR <br />1868 E. Hazelton Avenue I Stockton, California 95205 1 T 209 468-3420 1 F 209 464-0138 1 www.sjgov.org/EHD