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San Joaquin County Environmental Health Department 1868 East Hazelton Avenue, Stockton, California 95205-6232 Telephone: (209) 468-3420 Fax: (209) 468-3433 Web: www.sjgov.org/ehd RCRA Large Quantity Hazardous Waste Generator Inspection Report Facility Name: Facility Address: Date: ECS REFINING LLC 2222 S SINCLAIR AVE, STOCKTON November 03, 2014 SUMMARY OF VIOLATIONS (CLASS I, CLASS II, or MINOR - Notice to Comply) Item # Remarks 113 CCR 66262.20 Failed to prepare manifests for transportation of hazardous waste. Ethylene glycol was disposed of using consolidated manifesting procedures from the opening of this facility in 2011 until September 18, 2013. This facility is a large quantity generator and does not qualify for disposal of hazardous waste using consolidated manifesting procedures. This waste was transported off site for disposal without first preparing a uniform hazardous waste manifest. A generator shall prepare a Uniform Hazardous Waste Manifest on EPA Form 8700-22 prior to the transport of a hazardous waste for off-site transfer, treatment, storage or disposal. Ensure that a manifest is prepared each time hazardous waste is transported for off site transfer, treatment, storage or disposal. This is a Class II violation. 115 CCR 66262.23(a)(4) Failed to send generator manifest copies to DTSC within 30 days. The generator copy of manifest number 004475217JJK (11/8/13) was not sent to DTSC within 30 days of shipment of hazardous waste. The generator manifest copy shall be submitted to DTSC for every shipment on a manifest when California is either the generator state or the destination or consignment state. The generator manifest copy shall be mailed to: DTSC Generator Manifests P.O. Box 400 Sacramento, CA 95812-0400 Immediately mail a copy of the manifests listed and ensure that copies of all generator manifests are sent to DTSC within 30 days of shipping hazardous waste. This is a Class II violation. 116 CCR 66262.40(a) Failed to keep signed copy of manifests from the designated facility for three years. Manifest numbers 009479243JJK (5/8/12) and 009479250JJK (5/22/12) were not found on site. Hazardous waste generators shall retain copies of all manifests for three years or until a copy signed off by the destination facility is received. The signed off copy shall be retained and made readily available for review for three years. If the generator did not receive a copy of the manifest with the handwritten signature of the owner or operator of the facility to which the generator's waste was submitted within 35 days of the date the waste was accepted by the initial transporter, the generator shall contact the transporter and/or the owner or operator of the designated facility to determine the status of the waste. If the generator did not receive a copy of the signed off copy of the manifest within 45 days of the date that the waste was accepted by the initial transporter, the generator shall submit an Exception Report that includes a legible copy of the missing manifest, and a cover letter signed by the generator explaining the efforts to locate the hazardous waste and the results of those efforts. Exception reports shall be submitted to: DTSC Report Repository Generator Information Services Section P.O. Box 806 Sacramento, CA 95812-0806 Immediately locate a copy of the missing manifests or prepare and submit an exception report to DTSC. Submit to the EHD a copy of the signed off copy of the manifests or a copy of the exception report submitted to DTSC. This is a repeat violation, Class Il. Recei (initial): Inspector: Phone: ate: STACY RIVERA, Senior REHS (209) 468-3440 11/03/2014