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S A N J 0 A Q I I I Irl Environmental Health Department C o u N T AMENDED 6/10/2020 Small Quantity Hazardous Waste Generator Inspection Report Facility Name: Facility Address: Date: ALCO METALS 1 1815 NAVY DR, STOCKTON June 09, 2020 SUMMARY OF VIOLATIONS (CLASS I,CLASS II,or MINOR-Notice to Comply) Item# Remarks 112 CCR 66268.7(a)Failed to make determination for land disposal. OBSERVATION: Uniform Hazardous Waste Manifest(UHWM)006960091 SKS(6/3/2019)was found on-site showing disposal of hazardous wastes without making a determination if the waste has to be treated before it can be disposed of to land. Manifest 006960091 SKS (6/3/2019),showed 1500 pounds of waxy paper waste from a wire stripper operation taken off site. The waste was labeled on the manifest as"NON RCRA HAZARDOSOU WASTE SOLIDS, (DEBRIS, PETROLEUM HYDROCARBONS)" using state waste code 223,for"unspecified, oil containing waste." Four samples of the waxy paper waste were taken on 1/22/2019 by the Department of Toxic Substances Control (DTSC). The samples were labeled as ALCO-01 B,ALCO-0213,ALCO-03B, and ALCO-04B. The Toxicity Characteristic Leaching Procedure(TCLP), Total Threshold Limit Concentration (TTLC), and Soluble Threshold Limit Concentration (STLC)tests were done on each sample. The results of the metals from the tests that exceeded the threshold are as follows: ALCO-01 B: TCLP: Lead, 95.6 mg/L TTLC: Lead, 3,850 mg/kg STLC: Lead, 248 mg/L ALCO-02B: TCLP: Lead, 18.1 mg/L TTLC: Lead, 1050 mg/kg STLC: Lead, 66.3 mg/L ALCO-03B: TCLP: Lead, 97 mg/L TTLC: Lead, 3,260 mg/kg STLC: Cadmium, 1.18 mg/L Lead, 148 mg/L ALCO-04B: TCLP: Lead,444 mg/L TTLC: Lead, 3,830 mg/kg STLC: Lead,407 mg/L The results indicate that the waste was a RCRA hazardous waste. REGULATION GUIDANCE: Per Title 22 California Code of Regulations 66268.7 (a)Requirements for generators: (1)A generator of hazardous waste shall determine if the waste has to be treated before it can be land disposed. This is done by determining if the hazardous waste meets the treatment standards in article 4 or article 11 of this chapter.This determination can be made concurrently with the hazardous waste determination required in section 66262.11 of this division, in either of two ways: testing the waste or using knowledge of the waste. If the generator tests the waste, testing would normally determine the total concentration of hazardous constituents, or the concentration of hazardous constituents in an extract of the waste obtained using test method 1311 in"Test Methods of Evaluating Solid Waste, Physical/Chemical Methods,""USEPA Publication SW-846, as referenced in section 66260.11 of this division, depending on whether the treatment standard for the waste is expressed as a total concentration or concentration of hazardous constituent in the waste's extract.Alternatively,the generator may send the waste directly to a hazardous waste treatment facility,where the hazardous waste treatment facility shall comply with all requirements of section 66264.13 of this division and paragraph (b)of this section. In addition, some hazardous wastes shall be treated by particular treatment methods before they can be land disposed and some FA0001889 PR0220065 SCO01 06/09/2020 EHD 22-01 Rev.9/20/2019 Page 7 of 15 Small Quantity Hazardous Waste Generator OIR 1868 E. Hazelton Avenue I Stockton, California 95205 1 T 209 468-3420 1 F 209 464-0138 1 www.sjcehd.com