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Complaint Investigation Re[ Tri -Valley Recycling description of the white Tri -Valley Recycling van that picked up a -waste and paint waste to employees of City of Folsom. The complaint was made to DTSC on November 16, 2010. On April 19, 2011 Mr. Fong and I arrived at Tri -Valley Recycling. I walked into the office and said to the lady at the front desk that I came from DTSC to inspect the facility. She telephoned Mr. Adams, and Mr. Adams came to the front desk and greeted us. I said came to inspect the facility, and my inspection will include walking through the facility, taking photographs and reviewing documents. Mr. Adams said "yes" at 9:40 AM. I informed him that DTSC had received complaints about the facility and I had come to investigate the complaints. I asked Mr. Adams to describe the a -waste operations in the facility and to show me the a -waste storage area. Mr. Adams then proceeded to explain the facility's operations. He said that the facility distributed flyers and cards to residents in a community, and later picked up e- waste from residents on a scheduled date. He gave me a flyer and the flyer instructed residents to place Tri -valley Recycling cards/flyers on the items that needed to be picked up. The flyer also stated that Tri - Valley Recycling picked up batteries from a resident's driveways. Later, I asked Tri - Valley Recycling to give me copies of few flyers and cards that were collected with the e -waste from driveways. The following statement was printed on a flyer collected on February 28th from a driveway of a resident living at Dublin; "Car & motorcycle batteries OK! No appliances, household batteries, (AA, AAA, etc), light bulbs, furniture, tires or others sorts of waste" The flyers and cards submitted by Tri -Valley Recycling substantiated the complaint that was recorded on the hot-line, in that the facility actively solicited and encouraged residents through advertisements to place motorcycle and car batteries on driveways of homes for pick up. Waste batteries are hazardous waste. Batteries contain sulfuric acid and lead that could be harmful for children and animals in the neighborhood when placed on driveways for indefinite time periods. Mr. Adams led us to the e -waste storage room. Inside the e -waste storage room, observed two large open Gaylord cardboard boxes on pallets containing batteries. One box was marked with the words "Batteries" and the other box did not have any markings. Both boxes were filled up to % of their capacity with lead acid and alkaline batteries. After the inspection, Tri -Valley Recycling submitted documentation to show that the facility stored 5,720 pounds of batteries in cardboard boxes. A facility generating over 1000 kg of hazardous waste in any one month is considered a large quantity generator. I said to Mr. Adams that lead acid batteries were hazardous waste and should not be stored in cardboard boxes that could be damaged if acid leaked from the batteries. California Code of Regulations, title 22, section 66265.172 requires operator to use a container made with materials which will not react with the hazardous waste to be transferred or stored, so that the ability of the container to contain the waste is not impaired. In another location in the same room, card board boxes of batteries were stacked to a height about 6 feet. Boxes on the top of the stack were open and I observed dry cell batteries inside the boxes. The stacked boxes did not have any markings. said the boxes that contained batteries must be marked with the date on which the 2 of 20