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ATTACHMENT A—EXAMPLES <br /> Violation Classification Examples <br /> The UPAs should go through all classification steps to properly classify violations, including <br /> considering all factors presented in this document. Below are some GENERAL violations that <br /> may be minor, Class II, or Class I. This provides common program violations and potential minor, <br /> Class II, or Class I situations. <br /> These lists are NOT intended to be exhaustive lists of violations with classifications. <br /> Potential Minor Violations <br /> Hazardous Materials Business Plan Program <br /> • Failure to submit annual/triennial certification when there is no change in chemical <br /> inventory. (Subject to local ordinance requirements) <br /> • Failure to electronically submit the HMBP to CERS when a plan is in place and it is a low <br /> hazard facility such as an Auto Body shop(not a plating shop). <br /> • Failure to specify the location of a low hazard chemical on the facility site map. <br /> • Annual refresher training was not conducted, but employees were previously trained in a <br /> low risk facility(Dry Cleaner/Auto Shop). <br /> Underground Storage Tank(UST) Program <br /> • Failure to update or submit complete tank and facility information in CERS. <br /> • Missing maintenance and monitoring records onsite(Unless offsite storage allowed by the <br /> UPA). <br /> • Records for employee training conducted by the DO were not onsite, but training was <br /> complete. <br /> • Occasional missing monthly inspection report and no alarms were noted. <br /> California Accidental Release Prevention Program (CalARP) <br /> • A required data element is missing from the submitted Registration Information. <br /> • A stationary source reported gallons instead of pounds for a regulated substance in the <br /> initial RMP. <br /> • Review of documentation required for a RMP is incomplete for a single element. <br /> Hazardous Waste Program <br /> • Incomplete or missing label on a container of minimal-hazard waste. <br /> Violation Classification Guidance for UPAs Page 9 <br />