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• • 0 <br /> VII. VIOLATIONS• <br /> E.R. Carpenter has failed to submit copies of their Hazardous Waste <br /> Manifests to DHS as required by the California Health and Safety <br /> Code Section 25160. Waste oil removed from site was not documented <br /> as per Title 22 , California Code of Regulations, Section 66480, <br /> et.seq. <br /> VIII.OBSERVATIONS: <br /> Elizabeth Ambacher (DHS) , Jaime Favila, Senior R.E.H.S. , and I <br /> arrived at the site at approximately 0930 hours. We met with Gary <br /> Shortridge, Engineering Station Manager, and were led to the S/W <br /> corner of the facility. A review was made of facility records for <br /> management of hazardous waste on-site, employee training, <br /> contingency planning and emergency procedures. A list of chemicals <br /> used in the production process was provided. (see attached) . <br /> The manifests for hazardous waste generation were reviewed and <br /> found to be in order. Both of the required copies of manifests <br /> were found to be stapled together. It was noted that a copy <br /> designated for DHS had not been forwarded. <br /> Mr. Shortridge was asked about hazardous materials training for <br /> employees at the facility. Although no written records were <br /> provided, their Hazardous Materials Management Plan required by San <br /> Joaquin County Office of Emergency Services was present and <br /> indicated hazardous material training and planning for the facility <br /> had taken place. <br /> We then proceeded to the truck maintenance area and waste oil drum <br /> storage area located at the N/E corner of the property. Six drums <br /> with varying amounts of waste oil were noted. Next we visited the <br /> new truck maintenance shop and observed the new oil/sand separator <br /> and the 2 , 000 gallon aboveground waste oil. <br /> We then proceeded into the main manufacturing building and arrived <br /> at the maintenance shop. Mr. Ware identified their waste oil <br /> hauler as Refinery Services, but was unable to provide any records <br /> or documentation of waste oil removal. <br /> We then progressed to the production area at the S/W corner of the <br /> main building and observed the hazardous waste drum storage area. <br /> The drums were found to be properly labeled and dated. <br /> Lastly, we arrived at the production line area. Visual inspection <br /> revealed no obvious floor drains or conduits where chemicals could <br /> drain to an uncontrolled area. In addition, no chemical spills <br /> were observed on the floor surface. <br />