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San Joaquin County E Environmental Health Department 5 /2A.)J 1868 East Hazelton Avenue, Stockton, California 95205-6232 Telephone: (209)468-3420 Fax:(209) 468-3433 Web:www.sjgov.org/ehd RCRA Large Quantity Hazardous Waste Generator Inspection Report Facility Name: Facility Address: Date: KAISER PERMANENTE 7373 WEST LN, STOCKTON June 13, 2017 SUMMARY OF VIOLATIONS (CLASS I,CLASS II,or MINOR-Notice to Comply) Item # Remarks 119 CCR 66265.16(d) Failed to maintain complete personnel training records. It was not clear at time of inspection what hazardous waste training was being provided to employees. Inspector was provided with different training modules for different time periods but employees were not able to identify who had received the training, and what trainings were applicable to their job functions. Lack of training was evident during the inspection when the same hazardous waste stream was identified differently on hazardous waste labels or not at all. At one point during the inspection when looking at an incomplete hazardous waste label, a comment was made by Darryl Gardner, "these guys don't really know what they're doing". Personnel who handle hazardous waste shall be trained within six months of assignment and take part in an annual review of the initial training received. At a minimum, the training program shall be designed to ensure that facility personnel are able to respond effectively to emergencies by familiarizing them with emergency procedures, emergency equipment, and emergency systems, including where applicable: 1. procedures for using, inspecting, repairing, and replacing facility emergency and monitoring equipment; 2. key parameters for automatic waste feed cut-off systems; 3. communications or alarm systems; 4. response to fires or explosions; 5. response to ground-water contamination incidents; and 6. shutdown of operations. Training records on current employees shall be kept until closure of the facility. Training records on former employees shall be kept for at least three years from the date the employee last worked at the facility. Immediately provide employees who need it with initial or refresher hazardous waste training. Submit a copy of the roster, the syllabus, and training program for employees to the EHD. This is a Class II violation. 203 HSC 25189.5(c) Transported or caused transportation of hazardous waste to an unauthorized point. RCRA expired pharmaceuticals are being sent back to a reverse distributor for credit without first preparing a uniform hazardous waste manifest. The pharmaceutical waste is being sent back on a monthly basis without a determination if it is a RCRA or non-RCRA(medical waste)waste prior to shipping. The reverse distributor, Inmar, in Texas is not a permitted TSDF. 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 hazardous waste is transported to a permitted treatment, storage and/or disposal facility. This is a Class II violation. 403 CCR 66265.173 Failed to keep hazardous waste containers closed except when adding or removing hazardous waste. Black hazardous waste container in Dermatology was seen open at the time of inspection (photo 16). All hazardous waste containers shall be closed at all times except when adding or removing waste. Immediately close these containers and ensure all hazardous waste containers are closed when not adding or removing waste. This is a Class II violation. FA0002602 PRO514210 SC001 06/13/2017 EHD 22-03 Rev.09/22/16 Page 6 of 12 RCRA Large Quantity Hazardous Waste Generator OIR