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San Joaquin County Envir ntal Health Dept. <br /> February 25,2011 <br /> Page 4 <br /> Revised HMMPs for each store located in San Joaquin County have been prioritized and will be <br /> submitted electronically as soon as possible. <br /> Item#49. Personnel Training Records Incomplete. Provide this office with a copy of the roster and <br /> the syllabus which meet the requirements of 66265.16 CCR. <br /> Every AutoZoner in CA is required to complete online Annual CA Environmental training. This <br /> mandatory training is conducted and documented electronically. The attached compliance reports for <br /> stores #3315 and #5684 confirm that all but 1 employee at store #3315 have completed environmental <br /> training. A printed transcript of the online training module is also attached for your review. <br /> Additionally, every store AutoZoner is required to complete 2011 Emergency Action Plan training <br /> (attached). This training is manually documented by a signed EAP acknowledgement form which is <br /> posted on the overhead shelf door in the Store Manager's office. <br /> AutoZone stores are Small Quantity Generators (SQGs) of hazardous waste. Regulation 66265.16 as <br /> referenced in the Inspection Report appears to apply only to Large Quantity Generators (LQGs). <br /> Please refer to AutoZone's response to Item#20 above. <br /> AutoZone believes its training program satisfactorily addresses proper waste handling and emergency <br /> procedures, relevant to each store employee's responsibilities during normal facility operations, as <br /> well as emergencies, and provides all of the required training elements as described in 8 CCR 5194(h) <br /> and 40CFR 262.34(d)(5)(iii). <br /> Item#50. Stored Hazardous Waste on site greater than 180 days(store#5862) <br /> The Inspection Report noted a 55-gal. drum of waste absorbent missing a start accumulation date and <br /> a 5-gal. bucket (with an accumulation start date of November 2010) containing a green-colored liquid <br /> identified by the Store Manager as "Slime Tire Sealant." <br /> The 55-gal. drum of waste absorbent had not been on site for more than 180 days. Although the <br /> accumulation start date was not identified on the drum label, a manifest dated 10-28-10 (attached) <br /> documents that Safety-Kleen picked up a 55-gal. drum of used absorbent waste from this location on <br /> October 28, 2010. Store personnel have subsequently noted the accumulation start date as 10-28-10 to <br /> properly complete the drum label. Safety-Kleen is scheduled to pick up this waste drum no later than <br /> March 25, 2011. <br /> Regarding the 5-gal. bucket containing a green-colored liquid, please refer to Item #52 response. <br /> Item #52. Failed to comply with CFR 262.34 (d),(e), and (11), (emergency coordinator, modified <br /> contingency plan,train employees on waste handling and emergency procedures, and respond to <br /> a fire spill or other release). <br /> The Inspection Report stated that at the time of inspection, it could not be demonstrated that <br /> employees who handle hazardous waste were properly trained. The inspector did observe a poster <br /> directly above the California Retail Chemical Waste storage area which included the phrases, <br /> "Important, never pour liquid chemicals directly into a waste container" and "If you are not sure in <br /> which container to place chemical waste, don't guess, call PSC." However, the inspector further <br /> observed free chemical liquids in two of the waste buckets. When questioned, the Store Manager <br />