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Notice of Violation <br /> Violation 102 — Failed to Determine if a Waste is a Hazardous Waste Class 2 violation <br /> OBSERVATIONS : <br /> 1 . White tank in the wastewater treatment area contained several inches deep of oily liquid . <br /> 2 . 55 gallon drum partially full of discolored soil next to the white tank . <br /> 3 . One drum of sodium hydroxide next to the water treatment pit was measured as pH 12 . 0 with pH paper . <br /> The liquid was pH 12 . The drum also contained solid sodium hydroxide according to Albert Mora . <br /> 4 . Five drums of solid sodium hydroxide in the water treatment secondary containment was pH 13 with <br /> wetted pH paper . <br /> REGULATION GUIDANCE : Any person who generates a waste shall determine if the waste is a hazardous <br /> waste as specified in Title 22 California Code of Regulations ( CCR ) . There are wastes that are listed as <br /> hazardous wastes . There are wastes that exhibit one or more of the hazardous waste characteristics : toxic, <br /> corrosive, reactive or ignitable . <br /> Title 22 CCR section 66261 . 2 — Definition of Waste <br /> Title 22 CCR section 66261 . 3 — Definition of Hazardous Waste <br /> A business operator shall keep records of any hazardous waste determinations made in accordance with Title <br /> 22 California Code of Regulations ( CCR ) section 66262 . 11 for at least three years from the date that the waste <br /> was last sent to an on-site or off-site treatment, storage, or disposal facility . The records may include Safety <br /> Data Sheets ( SDS ), waste test results or other hazardous waste determination documentation . <br /> CORRECTIVE ACTION : Immediately make a hazardous waste determination for each waste , and manage it <br /> according to Title 22 CCR . Use Safety Data Sheets (SDS ), waste sampling and test results or other knowledge to <br /> support your hazardous waste determination . Waste testing must be done using methods specified in Title 22 <br /> CCR including sections 66261 . 20-24 . <br /> Submit a statement and supporting documentation with your hazardous waste determination . Demonstrate <br /> current storage and labeling for wastes determined to be hazardous wastes . Provide disposal records for <br /> wastes determined to be hazardous wastes and stored longer than the number of days specified in Title 22 <br /> CCR for your hazardous waste generator status . <br /> Note : One half-full black 55 -gallon drum containing used oil was observed without a hazardous waste label . All <br /> hazardous waste containers shall be marked with the following information : the words " Hazardous Waste" , name <br /> and address of generator, hazardous properties, physical state, composition ( contents), and accumulation start <br /> date . The container was labeled during the inspection . <br /> Note : Howard Chan , President was informed by EHD that if the PH level of the wastewater before pH adjustment is <br /> less than 2 . 0 or greater than 12 . 5 a treatment permit is required from the San Joaquin County Environmental <br /> Health Department . According to Howard Chan and Albert Mora, Maintenance Supervisor, the wastewater before <br /> treatment is pH range 4 — 8 . <br /> Complete and submit a copy of the return to Compliance Certification form to the EHD with a statement <br /> documenting the corrective actions that have been or will be taken for each violation , and any supporting <br /> paperwork, by 2/9/2023 . Waste streams found : used oil <br />