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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 /> 6/10/2020 <br /> Small Quantity Hazardous Waste Generator Inspection Report <br /> Facility Name: Facility Address: Date: <br /> ALCO METALS 1 1815 NAVY DR, STOCKTON June 09, 2020 <br /> SUMMARY OF VIOLATIONS <br /> (CLASS I,CLASS II,or MINOR-Notice to Comply) <br /> Item# Remarks <br /> 108 CCR 66262.23(a) Failed to complete, sign or date manifest; or obtain dated signature of transporter. <br /> OBSERVATION 1: Uniform Hazardous Waste Manifest(manifest)number 006960091 SKS dated 6/3/2019, <br /> showed 1500 pounds of waste taken off site. The waste was labeled on the manifest as"NON RCRA <br /> HAZARDOSOU WASTE SOLIDS, (DEBRIS, PETROLEUM HYDROCARBONS)" using state waste code 223,for <br /> "unspecified, oil containing waste." During today's inspection, General Manager Jerry Lynch stated that this <br /> manifest was used to document the off-site transport of waxy paper waste from the wire stripper operation. Jerry <br /> stated that this manifest contains all waxy paper waste generated from the wire stripper operation between 1-22-19 <br /> to April 2019, including the waxy paper waste observed during the 1/22/2019 inspection. Jerry stated that the wire <br /> stripper operation continued until April 2019. <br /> Four samples of the waxy paper waste were taken on 1/22/2019 by the California Department of Toxic Substances <br /> Control (DTSC). The samples were labeled as ALCO-01 B,ALCO-02B,ALCO-03B, and ALCO-04B. Each sample <br /> was tested for the Toxicity Characteristic Leaching Procedure (TCLP),Total Threshold Limit Concentration (TTLC), <br /> and Soluble Threshold Limit Concentration (STLC). The results of the metals from the tests that exceeded the <br /> RCRA and non-RCRA hazardous waste thresholds are as follows: <br /> ALCO-01 B: TCLP: Lead, 95.6 mg/L <br /> TTLC: Lead, 3,850 mg/kg <br /> STLC: Lead, 248 mg/L <br /> ALCO-02B: TCLP: Lead, 18.1 mg/L <br /> TTLC: Lead, 1050 mg/kg <br /> STLC: Lead, 66.3 mg/L <br /> ALCO-03B: TCLP: Lead, 97 mg/L <br /> TTLC: Lead, 3,260 mg/kg <br /> STLC: Cadmium, 1.18 mg/L Lead, 148 mg/L <br /> ALCO-04B: TCLP: Lead,444 mg/L <br /> TTLC: Lead, 3,830 mg/kg <br /> STLC: Lead,407 mg/L <br /> The waste description and waste codes on manifest 006960091 SKS dated 6/3/2019 are not consistent with the <br /> DTSC analytical data for the waxy paper waste. <br /> OBSERVATION 2: Uniform Hazardous Waste Manifest(manifest)number 007313217SKS dated 10/21/2019, <br /> showed 1000 pounds of sludge taken off site. The sludge was generated from cleaning out the storm water <br /> treatment water system oil and solid traps.The system collects storm water from the outside operations filtering out <br /> solids and collecting oil. Sludge is waste generated by pollution control devices.The waste was labeled on the <br /> manifest as"NON RCRA HAZARDOSOU WASTE SOLIDS, (DEBRIS, PETROLEUM HYDROCARBONS)"using <br /> state waste code 223,for"unspecified, oil containing waste." Jerry Lynch explained that the waste generated from <br /> cleaning the system was a sludge. <br /> The manifest waste DOT description and the waste codes did not include any information indicating the waste was <br /> a sludge. <br /> REGULATION GUIDANCE: <br /> (a)The generator of any hazardous or extremely hazardous waste to be transported off-site or into California shall: <br /> FA0001889 PR0220065 SCO01 06/09/2020 <br /> EHD 22-01 Rev.9/20/2019 Page 5 of 15 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 />