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S A N J 0 A Q I I I Irl Environmental Health Department <br /> C o u N T AMENDED <br /> 7/s/2020 <br /> Small Quantity Hazardous Waste Generator Inspection Report <br /> Facility Name: Facility Address: Date: <br /> SIMS METAL 1000 S AURORA ST, STOCKTON July 06, 2020 <br /> SUMMARY OF VIOLATIONS <br /> (CLASS I,CLASS II,or MINOR-Notice to Comply) <br /> Item# Remarks <br /> 102 CCR 66262.11 Failed to determine if a waste is a hazardous waste. <br /> OBSERVATION 1: The facility has a closed down aluminum compactor on the ferrous side of the yard. The base <br /> of the machine had several piles of aluminum saturated with used oil. Next to the base of the compactor was more <br /> unused equipment placed in a secondary containment. The secondary containment had metal shavings, absorbent <br /> pads, and other debris that were saturated with used oil. In addition, one 3 gallon metal pan containing a dark liquid <br /> was holding metal shavings. Operations Manager Alex Thomas did not know the contents in the pan. <br /> OBSERVATION 2: Piles of brown dirt containing metal shavings were observed throughout the ferrous side of the <br /> yard. Alex Thomas stated that dirt is brought in when customers drop off scrap metal. The dirt will often contain <br /> metal pieces that are not sent to recycling. It was then explained that the facility does not segregate small metal <br /> pieces or metal fines from the dirt. Alex said the dirt would be put into drums for proper disposal. He was not sure if <br /> the waste would be"hazardous waste." <br /> OBSERVATION 3: The facility has a scrap drop off area on the ferrous side of the yard. Alex Thomas stated that <br /> load checks are done at the front gate. However, due to staffing shortages, items not normally accepted by the <br /> facility can be missed when a customer is emptying the load. If an item is missed in this area, and the customer <br /> cannot be identified,then the facility will take responsibility for any hazardous materials received. While inspecting <br /> the drop off area, one 2oz container(3/4 full)labeled "Rx-acid Scavenger"was observed in a pile of trash. <br /> OBSERVATION 4:According to Alex Thomas, hazardous materials are picked out of the pile before the metal is <br /> bundled and taken to another Sims recycling facility. Once a pile of hazardous materials has been formed, a <br /> representative from Sims will go to the facility and verify that the pile does not contain any product. A third party <br /> company will then come to the facility and pick up the hazardous materials. Alex did not know who the third party <br /> company was and could not provide any disposal records or bills of lading for chemicals found. <br /> OBSERVATION 5: On the non-ferrous side of the facility, one 1 pint can (1/2 full)labeled"Meth-IA5"was on the <br /> ground. Alex Thomas was not sure what the can contained. <br /> OBSERVATION 6: The storm drains at the facility have"witch hats"which are strainer like objects that catch metal <br /> debris. The storm drain on the non-ferrous side of the yard had a torn"witch hat." Metal shavings and brown dirt <br /> were observed at the bottom of the storm drain. <br /> OBSERVATION 7: No storm drains are located on the ferrous side of the facility. According to Alex Thomas, rain <br /> water on the ferrous side of the yard flows to a sump near the Aurora St facility entrance. The drain is then pumped <br /> out approximately one time a year. Alex could not provide any information regarding who picks up the waste water <br /> and how it is disposed of as. He could not also provide any information on if a sludge is generated from the dirt <br /> washed away by the rain. <br /> REGULATION GUIDANCE: Any person who generates a waste shall determine if the waste is a hazardous waste <br /> as specified in Title 22 California Code of Regulations(CCR). There are wastes that are listed as hazardous <br /> wastes. There are wastes that exhibit one or more of the hazardous waste characteristics:toxic, corrosive, reactive <br /> or ignitable. <br /> CORRECTIVE ACTION: Immediately make a hazardous waste determination for each waste, and manage it <br /> according to Title 22 CCR. Use Safety Data Sheets(SDS),waste sampling and test results or other knowledge to <br /> support your hazardous waste determination. Waste testing must be done using methods specified in Title 22 CCR <br /> including sections 66261.20-24. <br /> FA0010274 PR0514266 SCO01 07/06/2020 <br /> EHD 22-01 Rev.9/20/2019 Page 5 of 13 Small Quantity Hazardous Waste Generator OIR <br /> 1868 E. Hazelton Avenue I Stockton, California 95205 1 T 209 468-3420 1 F 209 464-0138 1 www.sjcehd.com <br />