COMPLIANCE INFO_PRE 2019 - Laserfiche WebLink

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0 0 It was noted on the inspection form that CVWS failed to contact the transporter/destination facility within 35 days after the facility did not receive a copy of the signed manifest. CVWS contacted each destination facility for the above mentioned manifests and did receive a copy of each signed manifest. Copies of the signed manifests are located in Attachment 1. In the future, if CVWS does not receive a copy of the manifest from the destination facility within 35 days from the date the waste was accepted by the initial transporter, CVWS will contact the transporter/destination facility to determine the status of the waste. Violation code: 124 — Failed to file an exception report when copy of manifest signed by destination facility not received within 45 days. It was noted on the inspection form that CVWS failed to file an Exemption Report to the Department of Toxic Substances Control within 45 days of the date that the waste was accepted by the initial transporter. CVWS received a signed copy of the above mentioned manifests; therefore, it was not necessary to file an Exception Report with the Department of Toxic Substances Control. Copies of the signed manifests are located in Attachment 1. As a preventive measure, if CVWS does not receive a copy of the manifest from the destination facility within 45 days from the date the waste was accepted by the initial transporter, CVWS will file an Exemption Report, including a legible copy of the missing manifest, a cover letter signed by the generator explaining the efforts to located the hazardous waste and the results of those efforts, to the Department of Toxic Substances Control. This process will be managed by the fleet manager and the operations specialist. Violation code: 132 — Failed to maintain a log for the daily tank inspections and Violation code: 503 — Failed to conduct daily inspections of HW tank. It was noted on the inspection form that hazardous waste tank inspections were not documented for June, July, and October 2011. As explained during the inspection, CVWS underwent a management change in July 2011, therefore, daily tank inspections were conducted during June and July; however, they were not documented. New personnel have been trained to conduct the daily tank inspections, October, November, and December 2011 daily tank inspections have been completed and are enclosed in Attachment 2. Violation code: 133 — Failed to comply with new HW tank assessment requirements. It was noted on the inspection form that the facility Hazardous Waste Tank Assessment for the used oil tanks were incomplete. CVWS hired a third party contractor, NES, to complete a tank assessment in 2009. This plan was reviewed by the County and determined incomplete. On December 9, 2011 CVWS contacted John Boll of NES to discuss the County's findings. Based on conversations between CVWS, NES and San Joaquin County on January 5, 2012, it is the understanding of CVWS that San Joaquin County agrees with NES's assessment that the process of correcting this finding will take more than 30 days to complete. CVWS requests for a 90 day extension of this finding to in order to complete the Tanks Assessments required by CCR 66265.192. CVWS will work diligently with NES, and with the comments and support of San