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Pacific Southwest Irrig <br /> 8372 S. Jack Tone Ro* ROONSE TO: FINDING #102 <br /> Stockton, CA 95215 <br /> 209-460-0450 J CCEj V <br /> • ri <br /> San Joaquin County IV a <br /> ENVIRONMENTAL HEALTH DEPARTMENT FEB2 4 2015 <br /> 1868 East Hazelton Avenue <br /> Stockton, California 95205 ENVIRONMENTAL. <br /> Telephone 209-408-3420 <br /> Small Quantity Hazardous Waste Generator Inspection Sheet <br /> Record Keeping/Documentation v a o5 <br /> 102 COI 6626211, Fano to determine if a waste is a hazardous waste or retain waste analysis on site fora wars <br /> 66262.01z1 <br /> 102 CCR 66262.11, 56262.40(c) Failed to determine if a waste is a hazardous waste or retain waste analysis on site for 3 <br /> years. <br /> According to Mr. Carlos Abarca, metal fines generated from an onsite band saw and other metal cutting equipment, <br /> which is located inside the shop area, are being recycled as scrap metal without first determining particle size or <br /> hazardous properties, oily residue was noted on some accumulated metal fines Any person who generates a waste <br /> shall determine if the waste is a hazardous waste. Immediately stop recycling metal fines, make a hazardous waste <br /> determination for the metal fines, and manage them according to Title 22 hazardous waste regulations. Particles 100 <br /> microns or smaller must be handled as hazardous waste if the metal is determined to be a hazardous waste. A sample <br /> of the metal fines was collected by the EHD inspector at the time of inspection and submitted to the analytical <br /> laboratory for analysis. Submit a statement and supporting documentation explaining how this waste will be managed. <br /> This is a Class II violation. <br /> Response: <br /> Basically the intent of the rule is metal shavings must be tested and those found to be largerthan 100 mc.in size removed. <br /> • Anything smaller or not tested is considered to be toxic. Due to the small amount of metal grinding&shavings produced in <br /> the PSWI Machine&Welding shop it is both economical and smarter to collect the metal waste in a 5 gallon Metal container <br /> labeled Hazardous Waste"Non-RCRA Metal Grindings and Shavings'and have a waste Transporter transport the sealed and <br /> labeled DOT t1N1A2 metal container to an appropriate TSDF. It is cheaper and safer,due to cutting oils being present in the <br /> metal wastes,to send as Hazardous Waste,CA Waste Code 352(other organic solids),to the appropriate TSDF.See <br /> Attached! <br /> • <br />