County of San Diego HazMat Inspection Report

Title Page

Conducted on
Prepared by
Location

Hazardous Materials Requirements

Failed to establish and implement a HMBP. HSC 25505(a) and 25507(a)
HMBP not submitted to the CUPA in CERS. HSC 25508(a)(1)(A); 27 CCR 15188(a),(b),(d)
Business Activities &/or Business Owner/Operator page not completed in CERS. 19 CCR 2652(a)(1); SDCC 68.904(b); HSC 25508(a)(1)(A)
Chemical inventory incomplete or not submitted in CERS. HSC 25505(a)(1); 25507(a); 25508.1(a-b); 19 CCR 2654 (a) or (d)
Site map not submitted in CERS or not sufficient. HSC 25505(a)(2); 25508.1(f); 19 CCR 2652(a)(3)
Failed to update HMBP in CERS within 30 days of a substantial change to any portion of the HMBP, including inventory changes or facility information. HSC 25508.1(a-f); 19 CCR 2654(d); SDCC 68.904(c)(6)
HMBP not certified annually as complete and accurate in CERS. HSC 25508(a)(1)(A), 25508.2, 19 CCR 2654(b)
Emergency response plan and procedures to mitigate a release or threatened release not adequate, not established or not submitted in CERS. HSC 25505(a)(3), 25508(a)(1)(A); 19 CCR 2658
Failure to notify property owner in writing that the business is subject to the HMBP program. HSC 25505.1
Failure to provide a copy of HMBP to the property owner within five working days upon request from property owner. HSC 25505.1
Failure to submit emergency response plan in CERS, when not meeting agricultural handler exemption. HSC 25507.1(a) and 25508(a)(1){A); 19 CCR 2670, 2671
Failure to submit employee training plan in CERS, when not meeting agricultural handler exemption. HSC 25507.1(a) and 25508(a)(1)(A)
HMBP not established or submitted in CERS, when not meeting the remote site exemption. HSC 25507.2 and 25508(a)(1)(A)
Employee training and/or plan for safety procedures in the event of a release or threatened release of a hazardous material not adequate, not established or not submitted in CERS. HSC 25505(a)(4) and 25508(a)(1)(A); 19 CCR 2659(a)
Initial &/or annual employee training not conducted in safety procedures for a hazardous material release or threatened release &/or employee training records not available or not maintained for 3 years. HSC 25505(a)(4); 19 CCR 2659(b)
Hazardous materials release or threatened release not immediately reported to the CUPA and OES upon discovery. HSC 25510(a); 19 CCR 2631(a)
Unified Program Facility permit not obtained for hazardous materials. SDCC 68.905; 68.906, 68.907
Emergency contact not provided or current in CERS. HSC 25508.1(f); SDCC 68.904(b)
Highly toxic gas (TLV<10 ppm) not disclosed in CERS. SDCC 68.1113(a)
Annual carcinogen/reproductive toxin list not submitted in CERS. SDCC 68.1113(b)
HMBP not readily available to facility personnel or the CUP A. HSC 25505(c)

Generator Information

Determination of Generator Classes

In one month did the site generate less than 100 kilograms (220 pounds)
In one month did the site generate LESS than 1,000 kilograms (2,200 pounds)
In one month did the site generate MORE than 1,000 kilograms (2,200 pounds)
Proceed to Section: Hazardous Waste Requirements for LQGS Only
Proceed to Section: Hazardous Waste Requirements for SQGS Only

HAZARDOUS WASTE REQUIREMENTS FOR SQGS ONLY

Did not accumulate waste in a container or tank. 22 CCR 66262.34(d)(2); 40 CFR 262.34(d)(2)
Failed to properly label/date hazardous waste container &/or tank. 22 CCR 66262.34(f)
Accumulated waste too long (>180 or 270 days) or (>90 days). HSC 25201(a), 25123.3(h)(1); 22 CCR 66262.34(d); 40 CFR 262.34(e) and/or (f)
Failed to accumulate hazardous waste in a container that is in good condition. 22 CCR 66262.34(d)(2); 40 CFR 262.34(d)(2), 265.171
Failed to accumulate or store hazardous waste in a lined &/or compatible container. 22 CCR 66262.34(d)(2); 40 CFR 262.34(d)(2), 265.172
Failed to properly close hazardous waste container(s). 22 CCR 66262.34(d)(2); 40 CFR 262.34(d)(2), 265.173
Failed to inspect hazardous waste storage area at least weekly. 22 CCR 66262.34(d)(2); 40 CFR 262.34{d)(2), 265.174
Failed to properly separate incompatible waste. 22 CCR 66262.34(d)(2); 40 CFR 262.34(d)(2), 265.177
Failed to maintain &/or operate facility to minimize the possibility of a fire, explosion, or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents. 22 CCR 66262.34(d)(2); 40 CFR 262.34(d)(4), 265.31
Failed to maintain adequate aisle space. 22 CCR 66262.34(d)(2); 40 CFR 262.34(d)(4), 265.35
Failed to post, next to the telephone, emergency information containing the location of emergency equipment, contact names and phone numbers. 22 CCR 66262.34(d)(2); 40 CFR 262.34(d)(S)(ii)
Failure to ensure employees are thoroughly familiar with proper waste handling and emergency procedures during normal facility operations and emergencies. 22 CCR 66262.34(d)(2); 40 CFR 262.34(d)(5)(iii)
Failed to maintain the following emergency response equipment or equivalent: 1) An internal communication or alarm system; 2) A communication device, such as a telephone; 3) Portable fire extinguishers, fire/spill control equipment and decontamination equipment; and 4) Water at adequate volume and pressure. 22 CCR 66262.34(d)(2); 40 CFR 262.34(d)(4), 265.32
Failed to have an emergency coordinator on the premises or on call, and available during an emergency. 22 CCR 66262.34(d)(2); 40 CFR 262.34(d)(5)(i)
Failed to implement and/or coordinate emergency response measures during an emergency, spill/release. 22 CCR 66262.34(d)(2); 40 CFR 262.34(d)(5)(iv)

HAZARDOUS WASTE REQUIREMENTS FOR SQGS AND LQGS

RECORD KEEPING/OPERATIONAL REQUIREMENTS

Unified Program Facility Permit not obtained &/or maintained for the generation of hazardous waste. SDCC 68.905
Failed to submit complete and accurate Facility Information in CERS. 27 CCR 15188(b-c); SDCC 68.904(b)
Failed to maintain waste analysis records, analytical records &/or waste determination results for at least 3 years. 22 CCR 66262.40(c)
Failed to obtain &/or maintain an active EPA ID Number. 22 CCR 66262.12(a)
Failed to properly complete a uniform hazardous waste manifest. 22 CCR 66262.23(a)
Failed to submit an Exception Report to DTSC for hazardous waste manifest. HSC 25123.3(h)(2); 22 CCR 66262.42(b), (c), &/or (d)
Failed to maintain copies of Uniform Hazardous Waste Manifest, consolidated manifest, or Bills of lading for 3 years. HSC 25160.2(b)(3), 25185(a)(4); 22 CCR 66262.40(a), 66262.23(a)(3)
Failed to send copy of the uniform hazardous waste manifest to DTSC within 30 days of shipment. 22 CCR 66262.23(a)(4)
Failed to meet the consolidated manifesting requirements for waste shipment. HSC 25160.2(b){3) &/or (c)
Failed to retain at the generator's place of business disposal records of spent lead-acid batteries for at least 3 years. 22 CCR 66266.81(a)(4)(A) &/or (B)
Failed to determine if a hazardous waste is restricted or prohibited from land disposal and has to be treated. 22 CCR 66268.7(a)(1)
Failure of recycler who recycles more than 100 kilograms per month of a recyclable material to submit the biennial Recyclable Materials Report (RMR) in CERS when claiming exclusion or exemption. HSC 25143.10(a), (c) &/or (d)
Failed to keep disposal receipts for drained used oil filters and/or drained fuel filters for 3 years. HSC 25250.22; 22 CCR 66266.130(c)(5)
Failed to report &/or update the required inventory information for hazardous waste(s) generated at the facility in CERS. SDCC 68.904(a)(2)
Failed to have land Disposal Restriction documentation onsite for 3 years. 22 CCR 66268.7(a)(8)
Failed to obtain a Treatment, Storage and Disposal Facility (TSDF) permit or authorization to store/treat/dispose of hazardous waste. HSC 25201(a)
Failed to have adequate records demonstrating claim of exemption or exclusion for recyclable materials. HSC 25143.2(f)
Failed to notify the CUPA in CERS for onsite hazardous waste treatment/tiered permitting. HSC 25201(a)
Manifest signed by the TSDF not available for inspection. 22 CCR 66262.40(a); HSC 25185(a)(4)

DISPOSAL AND TRANSPORTATION

Failed to prepare a hazardous waste manifest for the transport of a waste for off-site transfer, treatment, storage, or disposal. HSC 25160(b)(1) or (2), 25160.2(b)(9); 22 CCR 66262.20(a)
Failed to make a proper waste determination. 22 CCR 66262.11, 66262.40(c)
Failed to use a DTSC registered hazardous waste transporter to transport hazardous waste. HSC 25163(a)
Failed to properly dispose of hazardous waste at an authorized facility. HSC 25189.5(a)
Impermissible dilution of hazardous waste. 22 CCR 66268.3(a)
Disposed of used oil illegally. HSC 25250.5(a), 25189.5(a)
Failed to properly dispose of oil-based paint &/or hazardous waste latex paint liquid. HSC 25217.1, 25189.5(a)

STORAGE AND HANDLING

Failed to meet the management requirements when handling or storing spent lead-acid batteries. 22 CCR 66266.81{a)
Failed to properly manage 'damaged' spent lead acid batteries so as to minimize the release of acid and lead and to protect the handlers and the environment 22 CCR 66266.81(b)
Failed to properly manage, store, label &/or recycle used oil filters &/or used fuel filters. HSC 25250.22; 22 CCR 66266.130
Generator intentionally contaminated used oil with another hazardous waste other than minimal amounts of fuel. HSC 25250.7(a), (c)
Failed to properly label Excluded Recyclable Materials (ERM) accumulated in a container or tank. HSC 25143.9(a)
Failed to label hazardous material container within 10 days after the container was discovered to be mislabeled or inadequately labeled. HSC 25124(b)(3)(A); 22 CCR 66262.34(f)
Failed to repackage and properly label damaged/deteriorated hazardous material container within 96 hours. HSC 25124(b)(3)(B); 22 CCR 66262.34(f)
Failed to properly segregate used oil &/or fuel drained from filters. HSC 25250.22(b)(4); 22 CCR 66266.130(c)(6)
Failed to comply with hazardous waste satellite container regulation. 22 CCR 66262.34(e)
Failed to properly empty container, failed to manage non-empty container, or inner liner removed from a container. 22 CCR 66261.7(b), (d), (e) &/or (r)
Failed to mark date on empty container larger than 5 gallons &/or manage it within one year. 22 CCR 66261.7(f)
Failure of the owner or operator managing laboratory hazardous waste in a laboratory accumulation area to comply with the quantity limitations, management, training, or documentation requirements. HSC 25200.3.1(b)

UNIVERSAL WASTE HANDLER REQUIREMENTS

Failed to obtain a California ID Number from DTSC or federaiiD Number from US EPA prior to accumulating 5,000 kgs or more of Universal Waste. 22 CCR 66273.32(a-b)
Failed to maintain universal waste handler training records for 3 years. 22 CCR 66273.36(c),(d)
Failed to properly train handlers of universal waste in universal waste management and response procedures. 22 CCR 66273.36(a),(b)
Failed to properly label or mark Universal Waste container, package, or pallet (excluding CESQUWG) 22 CCR 66273.34
Failed to properly dispose of Universal Waste within one year. 22 CCR 66273.35(a) &/or (b)
Failed to keep records of offsite Universal Waste shlpment(s) available for inspection for 3 years. 22 CCR 66273.39(c),(d)(2)
Failed to meet accumulation, labeling, marking, &/or containment standards for Universal Waste aerosol containers. HSC 25201.16(f)
Failed to manage universal waste in a manner to prevent release(s) to the environment. 22 CCR 66273.33; 66273.33.5
Disposal of universal waste (UW) to an unauthorized point. HSC 25189.5(a); 22 CCR 66273.31(a), 66273.8(b)
Failure of a universal handler of electronic devices or CRTs from an offsite source to notify DTSC 30 days prior to acceptance. 22 CCR 66273.32(c)
Failure of certified appliance recycler (CAR) to properly remove and dispose of all materials that require special handling (MRSH). HSC 25211.3, 25212, 25212(c)

HAZARDOUS WASTE REQUIREMENTS FOR LQGS ONLY

RECORDKEEPING/OPERATIONAL REQUIREMENTS

Failed to prepare every four years a source reduction evaluation review and plan. 22 CCR 67100.4(a), HSC 25244.19(a)
Failed to prepare a summary progress report every four years. 22 CCR 67100.9(a)
Failed to complete a hazwaste management performance report and/or maintain for review. HSC 25244.20(a), 25244.21(a); 22 CCR 67100.3(a)
(RCRA LQG) Failed to complete the Biennial Report by March 1st on even numbered year and maintain a copy for 3 years. 22 CCR 66262.40(b), 66262.41(b)

TRAINING, CONTINGENCY PLAN & ER PROCEDURES

Failed to have a written Contingency Plan which is designed to minimize hazards to human health or the environment from fires, explosions, or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents to air, soil, or surface water. 22 CCR 66265.51(a)
Failed to maintain onsite a copy of the Contingency Plan and all its revisions and submit a copy to the local emergency agencies that may be called upon to provide emergency services. 22 CCR 66265:53
Failed to maintain training documents and records at the facility. 22 CCR 66265.16(d) & (e)
Failed to test and maintain all communications or alarm systems, fire protection equipment, spill control equipment, and decontamination equipment to assure its proper operation in time of emergency. 22 CCR 66265.33
Failed to maintain aisle space to allow the unobstructed movement of personnel, fire protection, spill-control equipment, etc. to any area of facility operation in an emergency. 22 CCR 66265.35
Failed to take precautions to prevent accidental ignition or reaction of ignitable or reactive waste, including the posting of a "No Smoking" sign(s), & separate and protect from sources of ignition or reaction. 22 CCR 66265.17(a)
Failed to immediately implement the Contingency Plan during an emergency and whenever there is a fire, explosion, or release of hazardous waste or hazardous waste constituents which could threaten human health or the environment. 22 CCR 66265.51(b)
Employee training program not adequate. 22 CCR 66265.16(a) and/or (b)
Contingency plan content is missing information and/or listing of required actions or descriptions. 22 CCR 66265.52
Failed to train employees at least annually. 22 CCR 66265.16(c)
Failed to equip facility with required emergency equipment, water at adequate pressure and volume, internal communication system, &/or spill response equipment. 22 CCR 66265.32
Failed to have an emergency coordinator on the premises or on call, and available to respond during an emergency and when a release occurs. 22 CCR 66265.55

STORAGE AND HANDLING

Failed to properly label/date hazardous waste container or portable tank. 22 CCR 66262.34(f), 66262.34(a)(2), 66262.34(a)(3)
Accumulated hazardous waste more than 90 days without a DTSC storage permit. HSC 25201(a); 22 CCR 66262.34(a) and (c)
Failed to transfer waste from a container that is in poor condition to another container that is in a good condition. 22 CCR 66265.171
Failed to accumulate hazardous waste in a lined or compatible container. 22 CCR 66265.172
Failed to keep a hazardous waste container or portable tank closed. 22 CCR 66265.173(a)
Failed to inspect hazardous waste storage area(s) at least weekly. 22 CCR 66265.174
Failed to keep reactive and/or ignitable waste at least 50 ft. from the property line. 22 CCR 66265.176
Failed to properly separate incompatible waste. 22 CCR 66265.17(b), 66265.177
Facility failed to maintain and/or operate to minimize the possibility of a fire, explosion, or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents to air, soil, or surface water which could threaten human health or the environment. 22 CCR 66265.31
Generator did not accumulate hazardous waste in a container or tank. 22 CCR 66262.34(a)(1)(A)