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Backus, Garrett [EHD] From: Backus, Garrett [EHD] Sent: Monday, August 2, 2021 12:35 PM To: Jason Boone Cc: Mike Belmont; Terree Matson; Henry, Michelle D [EHD] Subject: RE: Emailing: RTC form for Stockton Propeller, dated 7-2-2021, RTC Evidence Hi Jason, Thank you for the return to compliance information provided 7-29-21. I'll need more details to close violations 106, 202 and 605. Several documents mention "submit a copy of the manifest to CERS within 30 days of shipment". Be aware that generator signed paper copies of manifests need to be mailed to DTSC, not CERS. Violation 102 - resolved. Violation 106 -training. The training document is not complete and a sign -off sheet was not provided. 1. It does not discuss non-RCRA hazardous waste determinations. 2. The satellite container information is not consistent with California regulation. The document references RCRA empty containers. Empty containers at this facility must comply with California (non- RCRA) empty container rules. Retrain on California hazardous waste regulations and provide documentation. My department offers free classes here in basic hazardous waste management: https://ehd- training.sjgov.org/app/TrainingClasses.aspx Hazardous waste determination guidance: https://dtsc.ca.gov/defining-hazardous-waste/ Accumulation including Satellite accumulation: https://dtsc.ca.gov/accumulating-hazardous-wastes-at-generator-sites/ Empty containers: https://dtsc.ca.gov/managing-empty-containers/ Violations 109, 110, 112, 113 - resolved. Violation 202 - I did not receive photos of the labeled and closed waste alodine containers. There were two containers of this waste observed during the inspection. Violation 403 - resolved. Violation 605 - labeling 1. The "Paint Waste Accumulation" photo shows an accumulation start date of 2-11-20. Since this waste has been accumulated greater than 180 days, please dispose of this waste and provide a disposal record. 2. The "Warehouse, Used Oil " photo does not include the words "mineral spirits" in the composition section. Since this is a combination of used oil and mineral spirits include the words "mineral spirits" and "used oil" on the label. Mineral spirits is not the same as used oil due to a lower flash point. The label also shows an accumulation start date of 11-21- 20. Since this waste has been accumulated greater than 180 days, please dispose of this waste and provide a disposal record.