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Environmental Health Department Small Quantity Hazardous Waste Generator Inspection Report Date: September 12, 2019 Facility Address: 10304 W LINNE RD, TRACY Facility Name: Oldcastle Infrastructure SUMMARY OF VIOLATIONS (CLASS I, CLASS II, or MINOR - Notice to Comply) RemarksItem # 608 CCR 66266.130 Failed to properly manage used oil and fuel filters. OBSERVATION: Containers of used metal oil filters out of compliance with the storage rules were observed on-site. The following used metal oil filter containers were on-site: - Used metal oil filters stored in large open approximately 20 yard metal storage bin found in the scrap metal recycling area. - One used metal oil filter observed next to parts washer machine. Note: Operator states that Oil filters are crushed in a oil filter crushing machine. Used oil is collected in a 55 gallon container below the the machine. He states the used metal oil filters are then transferred into one approximately 20 yard metal storage bin. The filters are then picked up with other scrap metal by A&S Metals Modesto. REGULATION GUIDANCE: (b) “used oil filters” are defined as filters which contain a residue of used oil and which are exempt from regulation as a hazardous waste under the scrap metal provision found in federal law. (c) Used oil filters that meet the conditions of subsection (b) of this section and are managed and recycled in compliance with the following requirements shall not be regulated as hazardous waste. (1) The filters are drained of free-flowing used oil. For the purposes of this subsection, free-flowing is defined as a continuous stream of oil exiting the filter when the filter is inverted. Oil exiting drop by drop is not considered to be free-flowing. However, if the filter is equipped with a device (such as a rubber flap located just inside the filter opening) which impedes the drainage of used oil from the filter, that device shall be manipulated to allow the oil to exit the filter freely, or the filter punctured, crushed, opened, drained, or otherwise handled in a manner that will allow the used oil to exit the filter. (2) The drained used oil filters are transported for purposes of metal reclamation to any of the following: (A) A smelter or other scrap metal processor where they are recycled or; (B) A storage facility or consolidation facility that subsequently transfers the filters to a facility described in paragraph (A) or (C) of this subsection or; (C) A municipal solid waste incinerator for energy recovery, if the residual casings are subsequently transferred to a facility described in paragraph (A) of this subsection, or to a storage or consolidation facility that subsequently transfers the residual casings to a facility described in paragraph (A) of this subsection. (3) The drained used oil filters are accumulated, stored, and transferred in a closed, rainproof container that is capable of containing any used oil that may separate from the filters placed inside. Drums of used oil filters shall be sealed during transfer so that used oil will not spill out when they are laid upon their sides. Drums shall be secured as a load to prevent movement or tipping during transfer. Containers shall be labelled as “drained used oil filters” (not as hazardous waste) and show initial date of accumulation or receipt on each container of filters. (4) Storage of less than one ton of used oil filters shall be limited to one year. Storage of one ton or more of used oil filters is limited to 180 days. (5) Persons generating, transporting, or receiving used oil filters shall use a bill of lading to record the transfer of used oil filters. Bills of lading must indicate generator, transporter, and receiving company names, addresses, telephone numbers, the quantity and size of used oil filter containers transferred, and the date of transfer. A copy of each bill of lading must be kept on the premises of the generator, transporter, and receiving facility where the used oil filters were handled. Copies of bills of lading shall be kept for a period of three years. CORRECTIVE ACTION: Immediately drain all metal oil filters of free-flowing oil, store them in closed, rainproof containers, label the container with the words “drained used oil filters,” and mark the container with an accumulation start date. Dispose of all used oil filters stored on-site greater than one year. Used oil filters not stored, handled and disposed of according to this section are regulated as hazardous waste. Provide a corrective action statement, FA0010036 PR0539719 SC001 09/12/2019 EHD 22-01 Rev. 8/22/2019 Small Quantity Hazardous Waste Generator OIRPage 7 of 9 1868 E. Hazelton Avenue | Stockton, California 95205 | T 209 468-3420 | F 209 464-0138 | www.sjcehd.com