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SAN JOAQUIN COUNTY <br /> ENVIRONMENTAL HEALTH DEPARTMENT <br /> 1868 East Hazelton Avenue, Stockton, California 95205-6232 <br /> Telephone:(209)468-3420 Fax: (209) 468-3433 Web:www.s'gov.org/ehd <br /> CONTINUATION FORM Page: 5 of 6 <br /> OFFICIAL INSPECTION REPORT Date: 10/15/13 <br /> Facility Address: Union Pacific-Intermodal Facility 1000 East Roth Rd, FrenchCamp Program: HW <br /> SUMMARY OF VIOLATIONS <br /> CLASS I, CLASS II,or MINOR-Notice to Comply) <br /> 108. Metal fines generated from metal cuttings, grinding machinery located at the Pro Trailer Repairs Inc <br /> shop located on the west side of the railroad tracks are being recycled as scrap metal without first <br /> determining particle size or hazardous properties. Metal fine powders can be found on the work table <br /> and on the asphalt ground behind the work table. Metal fines are also generated from the operations of <br /> bench grinders in the drayage tractor maintenance shop. Per Mgr Environmental Field Ops, metal <br /> powder fines and metal scraps are collected at the end of the day and placed into the metal scrap <br /> recycling bin. Any person who generates a waste shall determine if the waste is a hazardous waste. <br /> According to California's definition of"scrap metal", Title 22, CCR 66260.10, means (1) manufactured, <br /> solid metal objects, products, (2) metal workings, cuttings, trimming, stampings, grindings, shaving, <br /> sanding, (3) solids metal residues of metal production (4) printed circuit boards <br /> but excludes <br /> (1) lead-acid batteries, waste mercury, water-reactive metals (sodium, potassium, lithium) (2) <br /> magnesium borings, trimmings, grindings, shavings, sanding (3) beryllium borings, trimmings, grindings, <br /> shavings, sandings, (4) metal contaminated with haz waste (5) metal contaminated with oil & free- <br /> flowing (6) sludges, fine powders, semi-solids & liquids solution that are hazardous waste (7) printed <br /> circuit boards <br /> According to California's definition of"fine powder", Title 22, CCR 66260.10, means metal in dry, solid <br /> form having particle size smaller than 100 micrometers/microns in diameter. Some metal waste (eg. <br /> "fine powders") that meet definition of'scrap metal' under federal law are exempted when it is recycled <br /> under federal regulations. Unfortunately, fine powder does not meet the definition of'scrap metal' under <br /> California regulations, thus must be managed as hazardous waste under State law. <br /> Per Mgr Environmental Field Ops, a size analysis was performed and the 86% of the samples were <br /> found to be larger than 100 microns and the other 14% smaller than 100 microns. Particles 100 microns <br /> or smaller must be handled as hazardous waste if the metal is determined to be a hazardous waste. <br /> Immediately stop recycling metal fines, make a hazardous waste determination for the metal fine <br /> powder, and manage it according the Title 22 hazardous waste regulations. <br /> Submit a statement and supporting documentation explaining how this waste was managed. <br /> ALL EHD STAFF TIME ASSOCIATED WITH FAILING TO COMPLY BY THE ABOVE NOTED DATES WILL BE BILLED AT THE CURRENT HOURLY RATE. <br /> THIS FACILITY IS SUBJECT TO REINSPECTION AT ANY TIME AT EHD'S CURRENT HOURLY RATE. <br /> EHD Inspector: Received By: Title: <br /> Thuy Tran (209) 468-8257 <br /> EHD 23-02-003 Rev 04/19/12 CONTINUATION FORM <br />