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signage were confirmed to be accurate for the drum used which is located at the
<br />accumulation site. As noted it was corrected onsite.
<br />During the inspection, it was noted that there were two black steel drums with Hazardous
<br />Waste labels dated April 29, 2011 and May 17, 2011; However, these drums were
<br />determined to be Re -Usable Adsorbent and not a waste. Refresher training with facility
<br />personnel has been completed to ensure compliance. The facility manager corrected this
<br />observation by removing the HW label.
<br />During the facility inspection, it was observed that one steel drum containing PCB ballasts
<br />had expired the accumulation date. The steel drum of PCB ballasts were transported by
<br />Veolia ES Technical Solutions on 910112011. Please see Exhibit 4 -PCB Manifest tracking
<br />number 000511944VES.
<br />4. Storage: (22) CCR 66266.81(b) Damaged lead acid batteries not property managed and
<br />labelled
<br />During the inspection, the labels were applied to both the over -sized battery, and the 55
<br />gallon black poly drum which contained damaged lead acid batteries. Due to the size of the
<br />over -sized battery, arrangements were made with the local battery recycier to pick up the
<br />battery. Before any transportation was made, a call was made to you to confirm method of
<br />disposal was compliant. Please see Exhibit 5 - Removal of Broken Steel Case Battery for &
<br />Shipment AMP Power Construction; Exhibit 6 -Properly labelled Broken Battery Drum.
<br />5. Containers: (27) CCR 66265.173(a) Failed to keep containers of HW closed except
<br />when adding or removing HW
<br />At the time of inspection, the two 5 gallon buckets containing solid debris and soil were
<br />immediately placed into the proper Hazardous Waste drum. Appropriate labelling and
<br />signage were confirmed to be accurate for the drum used which is located at the
<br />accumulation site. As noted it was corrected onsite.
<br />Two oil drain pans which are strictly used for draining sealed units, and gear reservoirs from
<br />appliances during operating hours were labelled as "Drained Daily". The accumulated
<br />contents were moved into the proper drums following daily operation. Exhibit 7 —drip pan
<br />stencil
<br />6. Containers: (30) CCR 66261.7(t) An empty HW or Haz Mat container (larger than 5
<br />gallons) was not marked with the date it was emptied and/or not managed within one
<br />year of being emptied.
<br />An empty 55 gallon drum during the Inspection was labelled indicating the drum is "Empty".
<br />7. Hazardous Waste Tanks: (32) CCR 66265.192 Failed to comply with new HW Tank
<br />Assessment requirements
<br />Prior to the inspection, SMM had determined a tank assessment was needed for the waste
<br />oil tank. That inspection was scheduled for 8-22-11. SMM has received a preliminary report
<br />and are making the necessary modifications to the tank. A final inspection of the waste tank
<br />has been scheduled so the PE may sign off that the work had been completed. However,
<br />given the 'Return to Compliance" date, a final copy Is not yet available. Once the final Tank
<br />Assessment has been approved, SMM will forward a copy to you at the address provided
<br />above.
<br />8- Contingency Plan & Training: (45) CCR 66265.52 Contingency Plan incomplete
<br />The Contingency Plan onsite at the time of inspection was observed to be missing partial
<br />contact information that was unavailable upon request; however, during a revision of the
<br />plan, the addition was added to the Emergency Response Binder. This has since been
<br />added to the binder and is no longer incomplete. Please see Exhibits 8, 9, 10, 11, 12, 13, 14,
<br />15, and 16.
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<br />signage were confirmed to be accurate for the drum used which is located at the
<br />accumulation site. As noted it was corrected onsite.
<br />During the inspection, it was noted that there were two black steel drums with Hazardous
<br />Waste labels dated April 29, 2011 and May 17, 2011; However, these drums were
<br />determined to be Re -Usable Adsorbent and not a waste. Refresher training with facility
<br />personnel has been completed to ensure compliance. The facility manager corrected this
<br />observation by removing the HW label.
<br />During the facility inspection, it was observed that one steel drum containing PCB ballasts
<br />had expired the accumulation date. The steel drum of PCB ballasts were transported by
<br />Veolia ES Technical Solutions on 910112011. Please see Exhibit 4 -PCB Manifest tracking
<br />number 000511944VES.
<br />4. Storage: (22) CCR 66266.81(b) Damaged lead acid batteries not property managed and
<br />labelled
<br />During the inspection, the labels were applied to both the over -sized battery, and the 55
<br />gallon black poly drum which contained damaged lead acid batteries. Due to the size of the
<br />over -sized battery, arrangements were made with the local battery recycier to pick up the
<br />battery. Before any transportation was made, a call was made to you to confirm method of
<br />disposal was compliant. Please see Exhibit 5 - Removal of Broken Steel Case Battery for &
<br />Shipment AMP Power Construction; Exhibit 6 -Properly labelled Broken Battery Drum.
<br />5. Containers: (27) CCR 66265.173(a) Failed to keep containers of HW closed except
<br />when adding or removing HW
<br />At the time of inspection, the two 5 gallon buckets containing solid debris and soil were
<br />immediately placed into the proper Hazardous Waste drum. Appropriate labelling and
<br />signage were confirmed to be accurate for the drum used which is located at the
<br />accumulation site. As noted it was corrected onsite.
<br />Two oil drain pans which are strictly used for draining sealed units, and gear reservoirs from
<br />appliances during operating hours were labelled as "Drained Daily". The accumulated
<br />contents were moved into the proper drums following daily operation. Exhibit 7 —drip pan
<br />stencil
<br />6. Containers: (30) CCR 66261.7(t) An empty HW or Haz Mat container (larger than 5
<br />gallons) was not marked with the date it was emptied and/or not managed within one
<br />year of being emptied.
<br />An empty 55 gallon drum during the Inspection was labelled indicating the drum is "Empty".
<br />7. Hazardous Waste Tanks: (32) CCR 66265.192 Failed to comply with new HW Tank
<br />Assessment requirements
<br />Prior to the inspection, SMM had determined a tank assessment was needed for the waste
<br />oil tank. That inspection was scheduled for 8-22-11. SMM has received a preliminary report
<br />and are making the necessary modifications to the tank. A final inspection of the waste tank
<br />has been scheduled so the PE may sign off that the work had been completed. However,
<br />given the 'Return to Compliance" date, a final copy Is not yet available. Once the final Tank
<br />Assessment has been approved, SMM will forward a copy to you at the address provided
<br />above.
<br />8- Contingency Plan & Training: (45) CCR 66265.52 Contingency Plan incomplete
<br />The Contingency Plan onsite at the time of inspection was observed to be missing partial
<br />contact information that was unavailable upon request; however, during a revision of the
<br />plan, the addition was added to the Emergency Response Binder. This has since been
<br />added to the binder and is no longer incomplete. Please see Exhibits 8, 9, 10, 11, 12, 13, 14,
<br />15, and 16.
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