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S A N J D AR I N Environmental Health Department u j ;"� 1 Y AMENDED 10/21/2019 Small Quantity Hazardous Waste Generator Inspection Report Facility Name: Facility Address: Date: LODI USD-TOKAY HIGH SCHOOL 1 1111 CENTURY BLVD, LODI October 10, 2019 SUMMARY OF VIOLATIONS (CLASS I,CLASS II,or MINOR-Notice to Comply) Item# Remarks 102 CCR 66262.11 Failed to determine if a waste is a hazardous waste. OBSERVATIONS: In the ceramics classroom, clay powder waste is wiped and swept then thrown into the trash with no determination being made. In the photography classroom, three trays containing photo fixer chemicals were observed uncovered with no determination being made. REGULATION GUIDANCE: Any person who generates a waste shall determine if the waste is a hazardous waste as specified in Title 22 California Code of Regulations(CCR). There are wastes that are listed as hazardous wastes. There are wastes that exhibit one or more of the hazardous waste characteristics:toxic, corrosive, reactive or ignitable. CORRECTIVE ACTION: Immediately stop disposal of clay powder waste as trash and make a hazardous waste determination for the clay powder waste and the liquid in the photo fixer trays, and manage it according to Title 22 CCR. Use Safety Data Sheets(SDS),waste sampling and test results or other knowledge to support your hazardous waste determination. Waste testing must be done using methods specified in Title 22 CCR including sections 66261.20-24. Submit a statement and supporting documentation with your hazardous waste determination. Demonstrate current storage and labeling for wastes determined to be hazardous wastes. Provide disposal records for wastes determined to be hazardous wastes and stored longer than the number of days specified in Title 22 CCR for your hazardous waste generator status. This is a minor violation. 110 CCR 66262.40(a) Failed to keep signed copy of manifests from the designated facility for three years. OBSERVATION: Designated facility signed copy of Uniform Hazardous Waste Manifest(UHWM)number 017145641JJK ship date 03-14-18 was not found on-site. Uniform Hazardous Waste Manifest(UHWM)number 018146131JJK ship date 06-21-18 was found without a signed copy from the designated facility. REGULATION GUIDANCE: A hazardous waste generator shall keep a copy of each manifest signed in accordance with section 66262.23(a)for three years or until the generator receives a signed copy from the designated facility which received the waste. This signed copy shall be retained as a record for at least three years from the date the waste was accepted by the initial transporter. The hazardous waste generator must submit a copy of the manifest to the California Department of Toxic Substances Control (DTSC)within 60 days if the destination facility signed manifest copy is not received from the transporter or designated facility. CORRECTIVE ACTION: Locate a copy of the destination facility signed manifests and send a copy to the San Joaquin County Environmental Health Department(EHD). If the destination facility signed manifests cannot be found then send to DTSC a copy of each generator signed manifest and a statement that the designated facility signed copy was not received by the generator. DTSC address is DTSC Report Repository, Generator Information Services Section, PO Box 806, Sacramento, CA 95812-0806. Provide a corrective action statement to the EHD within 30 days. This is a repeat violation, Class II. FA0000196 PR0522660 SCO01 10/10/2019 EHD 22-01 Rev.9/20/2019 Page 4 of 5 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