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M Inspection Report s. Other: El IV. NARRATIVE OF OBSERVATIONSMISCUSS ION WITH OPERATOR On March 21, 2001, at approximately 0900 hours, Michael Kith of San Joaquin County Environmental Health, Steven Binning, and I representing DISC arrived at the Simsmetal recycling center. We were met by the Secretary. I asked to speak to the Operations Manager of the facility. The Secretary told us that the Manager just ran an errand and he would be back in about 112 an hour. At approximately 0930 hours, Mr. Armando Salgado, Assistant Operations Manager, arrived at the facility. We proceeded to introduce ourselves and explain the nature of our visit. Implied consent was given by Mr. Salgado, when he asked if it would be o.k. if we could wait for Mr. David Rogers, Division Manager, to accompany us on the inspection. We said that would be fine. About 15 minutes later, Mr. Rogers arrived and we began our inspection. We sat down in the office and I explained that the inspection would be conducted in two parts: (1) a facility walk through,. and (2) a document review. Simsmetal is a metal, glass, and plastic recycling yard. They take in scrap metal (i.e. tin, iron, aluminum, automobiles, appliances). Simsmetal does not take in items that contain hazardous materials (See Attachment A for Simsmetal's scrap acceptance policy). All trucks corning into the yard go through load checking and radiation detectors. Simsmetal keeps a rpjatian load. log. The working area of the facility is paved with cement. All storm water runs to a collection area where an in ground clarifier separates the water and sludges. Hazardous waste that Simsmetal typically generates are used oil, oil/water, separator sludges, spent absorbent, and lead/acid batteries. We were given a site map and we began our walk through inspection. We started at the maintenance shop where I observed a 300 gallon tank of used oil located in a secondary containment area under a protective cover to minimize rain fall into the secondary containment. Proper hazardous waste labeling was observed. The used oil tank was open; however, Mr. Salgado stated that the heavy equipment was being drained of oil and was going to be put into the tank. The secondary containment area had a standing mixture of oil and water. I informed Mr. Rogers that when they do their inspections and they notice liquids in the secondary containment, they need to remove the accumulated liquids. Next to the used oil storage I observed an open container that held absorbent that was partially used. Mr. Rogers stated that the absorbent was still being used as a useable product. We proceeded to the maintenance shop where I observed a container that held absorbent waste. Proper hazardous waste labeling was observed. Inside the maintenance building I observed a power wash system that removes the dirt and oils from the water for reuse. The sludge is picked up by a registered hauler, ECI. The used oil is picked up about every 90 days. Ashberry is the company that picks up the used oil on a modified manifest. We proceeded out to the yard and observed a number of bins that hold engine parts. I observed what appeared to be used oil mixed with water in the bins. Mr. Rogers stated that they periodically have a hazardous waste hauler come and pump out the oil and water and have it shipped off as hazardous waste. Mr. Rogers stated that they cover the bins when it is raining. Simsmetal should ensure that the containment bins used to hold engine parts and compressors are free of oils and prevent rain waters from entering the bins. Simsmetal should clean up all noticeable used oil accumulation in the containment bins. We proceeded to the automobile compactor where I observed one satellite accumulation container for waste absorbent. Proper hazardous waste labeling was observed. I observed another properly labeled satellite accumulation waste absorbent container in the scrap yard. In the truck loading area I observed a pallet of lead/acid batteries. I did not observe any batteries missing their caps or broken. A record review showed that lead/acid batteries were being picked up approximately every two months. This concluded our facility walk through. We proceeded with the record review. Observations with the record review can be found in Section III, Documents Reviewed. V. VIOLATIONS Yes No Summary of Violations attached? X Minor violation was corrected at the time of the inspection. VI. CONCLUSIONS DTsc (3/95) Page 3 of 2-'