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RCRA Hazardous Waste Generator Program Inspection Report Date: May 20, 2025 Facility Address: 700 DARCY PKWY, LathropTESLA - MEGAFACTORY Facility Name: Environmental Health DepartmentAMENDED 6/23/2025 SUMMARY OF VIOLATIONS (CLASS I, CLASS II, or MINOR - Notice to Comply) Item #Remarks 5 CA Code of Regulations 66265.16 3120001 - Trained facility personnel annually and maintained required documentation until closure OBSERVATION: The following was observed during the inspection: 1) One 5 gallon can holding dark stained rags, gloves, and other debris, and one 55 gallon drum containing cutting fluid waste was observed in the maintenance area. A hazardous waste determination had not been observed during the inspection. Per Senior Environmental Engineer Anali Gonzalez, maintenance staff are supposed to notify the hazmat team to make a hazardous waste determination and have the waste properly disposed of. Per the conversation with the maintenance shop worker on site at the time of inspection, they appeared unfamiliar with the hazardous waste determination requirements for the observed waste streams. 2) Near the wash area, one JB Weld Epoxy syringe was observed inside a red container for storage of aerosol cans as universal waste. Per Anali Gonzalez, the tube should not have been thrown away into that container. Per Anali, the tube was empty. REGULATION GUIDANCE: New employees shall be trained within 180 days of hire and annually thereafter as specified in Title 22 California Code of Regulations section 66265.16. The owner or operator shall maintain training records on current personnel until closure of the facility and training records on former employees for at least three years from the date the employee last worked at the facility. CORRECTIVE ACTION: Immediately train all employees who work with hazardous waste in compliance within the time frames and training materials required by this section. Ensure training covers Tesla's hazardous waste determination procedures and proper hazardous waste handling and disposal. Provide training documentation to the San Joaquin County Environmental Health Department (EHD) within 30 days. This is a (Class 2) Violation. 14 CA Code of Regulations 66262.11 3130001 - Determined if waste generated is hazardous waste OBSERVATIONS: The facility was not able to provide evidence showing a hazardous waste determination had been made for the following wastes: In the maintenance shop: 1) One white 55 gallon poly drum containing cutting fluid was observed in a container. Per the maintenance worker, the cutting fluid was non-reusable and a waste. 2) Dark stained rags, gloves, and other debris were observed inside a metal 5 gallon bucket. Near the wash area: 3) An unknown fluid was observed inside a secondary containment pallet. 4) One empty JB Weld Epoxy syringe was observed inside a red container for storage of aerosol cans as universal waste. REGULATION GUIDANCE: Any person who generates a waste shall determine if the waste is a hazardous waste as specified in Title 22 California Code of Regulations (CCR). CORRECTIVE ACTION: Immediately make a hazardous waste determination for each waste, and manage it according to Title 22 CCR. Use Safety Data Sheets (SDS), waste sampling and test results or other knowledge to support your hazardous waste determination. Waste testing must be done using methods specified in Title 22 CCR including sections 66261.20-24. Submit a statement and supporting documentation with your hazardous waste determination. Demonstrate current storage and labeling for wastes determined to be hazardous wastes. This is a (Class 2) Violation. 1868 E. Hazelton Avenue | Stockton, California 95205 | T 209 468-3420 | F 209 464-0138 | www.sjgov.org/EHD Page 5 of 6EHD - CUPA Inspection Report IS02 6/23/2025FA0012394 PR2500478 4518101