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Cal -EPA DEPARTMENT OF TOXIC SUF`- TANCES CONTROL SAN JOAQUIN COUNTY UNIFIED PROGRAM AGENCY ENVIRONMENTAL HEALTH DEPARTMENT 600 E MAIN ST. STOCKTON, CA 95202-3029 Edmund G. Brown, Jr., Governor CHECKLIST AND INITIAL VERIFICATION INSPECTION REPORT FOR Permit by Rule, Conditionally Authorized, and Conditionally Exempt Notifiers NOTE SHEET c . This sheet includes inspector observations and expands upon the violations identified on the checklist (by number). In some cases, it indicates how the facility should correct the violations. It also includes the names of any others participating in this inspection. NOTICE OF VIOLATIONS: 4. (22 CCR 66265.192(h) as referenced by CA HSC 25200.3) The tank assessment for the waste water treatment units is incomplete. The certification was conducted by a chemical engineer instead of a civil, structural, or geotechnical engineer. The assessment does not include the thickness of the tanks or the condition of the interior surface of the tanks. Leak testing has not been conducted. Seismic load calculations were not included. The hazardous waste tank assessment should assess all five tanks in the system, including the sodium hydroxide tank, since it has previously had a leak. A hazardous waste generator shall obtain and keep on site a written assessment for each hazardous waste tank at the facility. This assessment shall be reviewed and certified by an independent, qualified (civil, structural, or geotechnical), professional engineer, registered in California, and shall attest to the tank system's integrity. The assessment shall determine that the tank system is adequately designed and has sufficient structural strength and compatibility with the waste stored, shall be written in accordance with Title 22 regulations, and shall include all relevant calculations and test results. Immediately update the current tank assessment or obtain a new written tank assessment for the waste water treatment units at this facility in accordance with Title 22 regulations, maintain a copy on site at the facility, and submit a copy of the certified assessment to the EHD. 10. (CA HSC 25202.9 as referenced by CA HSC 25200.3(c)(2)) A waste minimization certification has not been submitted to the EHD. A generator shall annually certify that: a) a program has been established to reduce the volume or quantity and toxicity of the hazardous waste, to the degree, determined by the generator to be economically practicable, and b) the proposed method of treatment, storage, or disposal is that practicable method currently available to the generator which minimizes the present and future threat to human health and the environment. Immediately complete a waste minimization certification and submit a copy to the EHD by May 27, 2011. 33. (22 CCR 67450.13) Annual financial assurance has not been submitted to the EHD. The most recent Certification of Financial Assurance on file with the EHD is dated July 18, 2007. The owner or operator shall submit a Certification of Financial Assurance for each Conditionally Authorized facility, documenting compliance with closure cost assurance requirements. The owner or operator shall prepare a written estimate of the cost of closing each unit. The estimate shall equal the actual cost or the costs estimated that would be incurred for closing a treatment unit when using the generator's own staff and/or personal equipment. This estimate shall be submitted as an attachment to the Certification of Financial Assurance form. The closure cost estimate shall be adjusted for inflation by March 1 of each year, and shall be revised whenever a change in the closure plan increases the cost of closure. A copy of the estimate shall be maintained at the facility. If the cost of closure is determined to by $10,000 or more, a mechanism of financial assurance must be submitted with the Certification of Financial Assurance. Immediately complete the Certification of Financial Assurance, with a current closure estimate and a financial assurance mechanism, if required, maintain a copy on site, and submit a copy to the EHD by May 27, 2011. Complete and submit a copy of the Tiered Permitting Certification of Return to Compliance to the EHD by May 27, 2011 along with a statement documenting the corrective actions that have been or will be taken for each violation and any supporting paperwork. SUMMARY OF VIOLAT S: Class II — 4, 10, 33 Onsite Che�E Pae 5 of 5 Rev 01/24/2011