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SAN ,dDAQ U I N Environmental Health Department C01-1 N T Large Quantity Hazardous Waste Generator Inspection Report Facility Name: Facility Address: Date: OLIN CHLOR ALKALI PRODUCTS WTR SYS 26700 S BANTA RD,TRACY December 04, 2019 Universal Waste 720 CCR 66273.31(a) UW handler caused improper disposal of UW ❑V ❑R ❑COS 721 CCR 66273.8(b) Conditionally exempt small quantity UW generator caused improper disposal of UW ❑V ❑R ❑COS Appliance Recycler 801 HSC 25211.4 Failure to obtain Certified Appliance Recycler certification(CAR) ❑V ❑R ❑COS 802 HSC 25211.2,25211.3 Failure of a CAR to provide docs that materials that require special handling have been removed ❑V ❑R ❑COS 803 HSC 25212 Failure of a CAR to properly remove and dispose of all materials that require special handling ❑V ❑R ❑COS Other Violations 3010 See below Unlisted Administration/Documentation violation ❑V ❑R ❑COS 3020 See below Unlisted Training violation ❑V ❑R ❑COS 3030 See below Unlisted Operations/Maintenance violation ❑V ❑R ❑COS 3040 See below Unlisted Release/Leaks/Spills violation ❑V ❑R ❑COS 3050 See below Unlisted Abandon ment/lIlegal Disposal/Unauthorized Treatment violation ❑V ❑R ❑COS 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: The following were observed on-site in tote storage/warehouse area: -Three 55 gallon drums labeled as non-hazardous oily debris. Operator states that the oily debris originated from an oil spill from a truck.Approximately 6 gallons of oil were released on to the asphalt ground due to a faulty seal on an oil filter. Operator contacted NRC to clean up the spill. Operator states that NRC determined the oily debris (absorbent)to be non-hazardous. Spill occurred on 11/27/19. 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 make a hazardous waste determination for oily debris, 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. Overall Inspection Comments: Complete and submit a copy of the Return to Compliance Certification form to the EHD with a statement FA0004478 PR0535813 SCO01 12/04/2019 EHD 22-02 Rev.9/20/2019 Page 4 of 5 Large 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