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Stacy Rivera [EH] • From: Matt Zeiter [Matt.Zeiter@simsmm.com] Sent: Thursday, March 29, 2012 3:20 PM To: Stacy Rivera [EH] Cc: Matt Zeiter Subject: Updates for SMM Stockton • Page 1 of 2 Attachments: Exhibit 31 -Used Oil Bill of Lading NO. N718462.pdf; Exhibit 32-Stockto InHouse UWaste Generation.pdf; Exhibit 33 -Emergency Notifications Stockton.pdf; Exhibit 34 -Incident Comm. Plan Stockton.pdf; Exhibit 35 - Used Oil Bill of Lading 8-11-11.pdf; Exhibit 36- Used Oil Bill of Lading 12-28-11.pdf; Exhibit 37 -Car Crusher Clean.jpg Stacy Below are descriptions of the corrective actions taken from the last inspection. Attached are supporting material for the records. Included in the attachments is a revised copy of the IN -House Universal Waste Generation based upon your last comments. The remaining training material will be sent in a follow up email due to its large size. 1. Operations: (7) CCR 66262.11 Failed to determine if a waste is a hazardous waste Following this observation, a small amount of metal fines were generated as a result of the grinder and were swept from the ground and accumulated into a jar. Given the volume of the fines collected, there was not sufficient material for a waste determination. Since the observation, a vacuum device has been installed to the grinder to remedy any airborne debris from its operations. Once enough volume is accumulated, a sample will be submitted to a certified laboratory. Grinding operations are minimal, and thus may take additional time to collect a sufficient sample. The collection container for the metal fines is labelled "Metal Fines — Pending Analysis 8-17-2011" Please see Exhibit 29 -Collection Jar for Metal Fines. The spillage observed in the secondary containment of the diesel tank was immediately cleaned with adsorbent. The area was swept clean and SMM properly disposed of the waste in the nearest hazardous waste drum. The secondary containment for the diesel is now clear of any waste on the ground, surrounding concrete and secondary containment. PCB Ballasts observed to have been incorrectly labeled have been reclassified with the proper labelling. An accumulation start date has been noted on the hazardous waste label. 2. Preparedness: (11) CCR 66265.31 Facility not maintained to minimize the release of a hazardous waste Immediately following the inspection, the car crusher was cleaned of debris; Adsorbent material was spread in the car crusher's secondary containment, and concrete surface. Any oils absorbed in the area were swept clean and properly disposed of into the nearest hazardous waste drum. The Car Crusher is now clear of any waste on the ground, surrounding concrete, and secondary containment. Please see new Exhibit 37. The facility will monitor the car crusher for any further evidence of leaks. If a leak is observed, a work order will be issued to remedy this problem immediately. Please see Exhibits 1, 2, 3 Car Crusher (photos). 3. Storage: (18) HSC 25201(a) Stored hazardous waste on site longer than 90 days without permit or authorization At the time of inspection, the two 5 gallon buckets containing solid debris and soil were immediately placed into the proper Hazardous Waste drum. Appropriate labelling and signage were confirmed to be accurate for the drum used which is located at the accumulation site. As noted it was corrected onsite. During the inspection, it was noted that there were two black steel drums with Hazardous Waste labels dated April 29, 2011 and May 17, 2011; However, these drums were determined to be Re -Usable Adsorbent and not a waste. Refresher training with facility personnel has been completed to ensure compliance. The facility manager corrected this 4/3/2012