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San Joaquin County RM Environmental Health Department 1868 East Hazelton Avenue, Stockton, California 95205-6232 Telephone: (209) 468-3420 Fax: (209) 468-3433 Web: www.sjgov.org/ehd Small Quantity Hazardous Waste Generator Inspection Report Facility Name: TOYS R US Facility Address: 1 1624 ARMY CT, STOCKTON Date: October 09, 2015 SUMMARY OF VIOLATIONS (CLASS I, CLASS II, or MINOR - Notice to Comply) Item # Remarks 104 CCR 66262.34(d)(2) No modified contingency plan. An emergency coordinator and modified contingency plan information is lacking. There must be at least one emergency coordinator on site or on call to coordinate emergency response measures, and the following information must be posted by a phone: the name and phone number of the emergency coordinator; location of fire extinguishers, spill control equipment, and if present, fire alarm; and the phone number of the fire department, unless the facility has a direct alarm. Immediately appoint an emergency coordinator and post the required information by a phone. A form is provided that can be used for this purpose. This is a Class II violation. 106 CCR 66262.34(d)(2) Failed to train employees on waste handling and emergency procedures. At the time of inspection, it could not be demonstrated (not necessarily documented) that employees who handle hazardous waste were properly trained. According to Tony Evans, the employees have not yet received detailed training on reverse logistics hazardous waste handling, and he is currently the only person at the facility making hazardous waste determinations for the reverse logistics waste. He stated that the employees are to separate out the containers which appear to be leaking or are labeled as trash and place them aside for a determination by Mr. Evans. Leaking jugs of hazardous waste liquid laundry detergent were observed uncontainerized, unlabeled near the hazardous waste drums. Mr. Evans was unfamiliar with how long the containers had been there. The generator must ensure that all employees who handle hazardous waste are thoroughly familiar with proper waste handling and emergency procedures. Provide proof of training to the EHD for employees whose responsibilities include hazardous waste. This is a Class II violation. 107 CCR 66262.20 Failed to prepare manifests for transportation of hazardous waste. On September 23, 2014, it was found that PAC Trucking was receiving hazardous wastes, including damaged items, from Toys R Us. An invoice from ACT for waste pickup was observed at PAC Trucking identifying the "purchase order" as Toys R Us for "Nickel Cadmium batteries (Dry Cell)," dated April 1, 2014. Six 5 gallon buckets of hazardous waste batteries from Toys R Us were observed on site at PAC Trucking at that time. These wastes were transported without first preparing a uniform hazardous waste manifest. According to Mr. Tony Evans, this facility does not open the boxes that are returned to them from stores and transporters unless it is obviously damaged or labeled as trash. The containers are sorted and sent to one of two packing streams, with no uniform hazardous waste manifests provided for any of these shipments. A generator shall prepare a Uniform Hazardous Waste Manifest on EPA Form 8700-22 prior to the transport of a hazardous waste for off-site transfer, treatment, storage or disposal. Ensure that a manifest is prepared each time hazardous waste is transported for off site transfer, treatment, storage or disposal. This is a Class II violation. Page 4 of 9