COMPLIANCE INFO - Laserfiche WebLink

Home Browse Search

• • RECEIVE® JI 1.1 9, 6 2017 #118. Failed to complete training on hazardous waste management and emergency response procedures. ENV4GNMENTAL HEALTH DEPARTMENT CORRECTIVE ACTION An employee, Bob Kennedy, was observed during the inspection handling an acidic material, for which the inspector questioned the PPE that was being used by the employee. The employee was not performing the activity related to hazardous waste, but rather hazardous chemicals (addition of phosphoric acid to the tank), and therefore did utilize the appropriate PPE based on company policy and in accordance with applicable OSHA regulations. The job activity being performed and the reference to selection and use of PPE, is outside the scope of training requirements for LQGs as referenced in 22 CCR §66365.16(a-c). Training for employees who generate and/or manage hazardous waste will be provided on July 19`h, 2017. The training program will be consistent with the updated Contingency Plan and will cover the following topics: Hazardous waste identification and management, container management standards, central and satellite accumulation limits, use, inspection, and maintenance of emergency and response equipment, automatic waste feed cut-off systems, alarm systems, responses to fires or explosions, responses to unplanned releases and potential groundwater contamination, shutdown operations, evacuation procedures. Employees who have additional hazardous waste responsibilities will receive training by NES prior to September 1, 2017, and annually, thereafter. #119. Failed to maintain complete personnel training records. CORRECTIVE ACTION A training matrix is being developed and will be implemented to identify employees by name, job title,job duties, and type and amount of training. The training matrix will be used for the hazardous waste training conducted by NES on July 19, 2017 and annually, thereafter. #123. Failed to provide information for>100 kg/mo recyclable material to claim the exclusion or exemption. CORRECTIVE ACTION On average, only 10 gallons(approximately 70 lbs.) per month of MEK and MEK/SBA are recycled on-site between two distillation units. The maximum amount of MEK and MEK/SBA recycled would never exceed 20 gallons (approximately 140 pounds)per month, which is not subject to the bi-annual notification. The CERS submittal that identified that more than 100 kg per month of excluded recyclable materials was being recycled on-site was an error. The MEK and MEK/SBA recycled on-site is handled, managed, and recycled in accordance with HSC §25143.2 & 25143.9. If the amount exceeds 100 kg per month, notification will be made on CERS.