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RCRA Hazardous Waste Generator Program Inspection Report <br />Date: <br />May 20, 2025 <br />Facility Address: <br />700 DARCY PKWY, LathropTESLA - MEGAFACTORY <br />Facility Name: <br />Environmental Health DepartmentAMENDED <br />9/3/2025 <br />SUMMARY OF VIOLATIONS <br />(CLASS I, CLASS II, or MINOR - Notice to Comply) <br />Item #Remarks <br />5 CA Code of Regulations 66262.17(a)(7) 3120001 - Trained facility personnel annually and maintained required <br />documentation until closure <br />OBSERVATION: The following was observed during the inspection: <br />1) One open 5 gallon bucket holding dark stained rags, gloves, and other debris, and one 55 gallon drum containing <br />cutting fluid waste was observed in the maintenance area. A hazardous waste determination had not been observed <br />during the inspection. Per Senior Environmental Engineer Anali Gonzalez, maintenance staff are supposed to notify the <br />hazmat team to make a hazardous waste determination and have the waste properly disposed of. Per the conversation <br />with the maintenance shop worker on site at the time of inspection, they appeared unfamiliar with the hazardous waste <br />determination requirements for the observed waste streams. <br />Hazardous waste (HW) training documentation was provided at the time of inspection demonstrating that the employees <br />had received hazardous waste training per Tesla’s training plan. Although this documentation was provided, at the time <br />of inspection the maintenance shop worker was unfamiliar with the HW determination requirements for waste streams <br />being generated by the maintenance shop. The generator failed to ensure that the training given was completed <br />successfully and teaches facility personnel to perform their duties in a way that ensures the facility's compliance with the <br />requirements of this chapter and section 5192, subsection (p), of Title 8, California Code of Regulations.. <br />2) Near the wash area, one JB Weld Epoxy syringe was observed inside a red container for storage of aerosol cans as <br />universal waste. Per Anali Gonzalez, the tube should not have been thrown away into that container. Per Anali, the tube <br />was empty. <br />The facility provided documentation on July 23, 2025, demonstrating that the chemical was disposed of as hazardous <br />waste. This portion of the violation was corrected. <br />Please see the overall inspection comment section of the report for the rest of the violation language. <br />This is a (Class 2) Violation. <br />14 CA Code of Regulations 66262.11 3130001 - Determined if waste generated is hazardous waste <br />OBSERVATIONS: The facility was not able to provide evidence showing a hazardous waste determination had been <br />made for the following wastes: <br />In the maintenance shop: <br />1) One white 55 gallon poly drum containing cutting fluid was observed in a container. Per the maintenance worker, the <br />cutting fluid was non-reusable and a waste. <br />2) Dark stained rags, gloves, and other debris were observed inside a metal 5 gallon bucket. <br />Near the wash area: <br />3) An unknown fluid was observed inside a secondary containment pallet. <br />4) One empty JB Weld Epoxy syringe was observed inside a red container for storage of aerosol cans as universal <br />waste. <br />REGULATION GUIDANCE: Any person who generates a waste shall determine if the waste is a hazardous waste as <br />specified in Title 22 California Code of Regulations (CCR). <br />CORRECTIVE ACTION: Immediately make a hazardous waste determination for each waste, and manage it according <br />to Title 22 CCR. Use Safety Data Sheets (SDS), waste sampling and test results or other knowledge to support your <br />hazardous waste determination. Waste testing must be done using methods specified in Title 22 CCR including sections <br />66261.20-24. Submit a statement and supporting documentation with your hazardous waste determination. <br />Demonstrate current storage and labeling for wastes determined to be hazardous wastes. <br />This is a (Class 2) Violation. <br />1868 E. Hazelton Avenue | Stockton, California 95205 | T 209 468-3420 | F 209 464-0138 | www.sjgov.org/EHD <br />Page 5 of 7EHD - CUPA Inspection Report IS02 9/3/2025FA0012394 PR2500478 4518101