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The following is an itemized list of hazardous waste violations that have not been <br /> addressed for JAAS AUTO SERVICE as of August 10, 2015. <br /> Open violations from September 24, 2014 inspection <br /> Violation#105 - Failed to determine if a waste is a hazardous waste or retain waste analysis on site for 3 <br /> years. <br /> Metal fines generated from brake grinding are being recycled as scrap metal without first determining particle size or <br /> hazardous properties. According to Mr. San, the metal grindings are hauled away as scrap metal approximately ono <br /> a week. Any person who generates a waste shall determine if the waste is a hazardous waste. Immediately stop <br /> recycling metal fines, make a hazardous waste determination for the brake grinding waste, and manage it according <br /> Title 22 hazardous waste regulations. Particles 100 microns or smaller must be handled as hazardous waste if the <br /> metal is determined to be a hazardous waste. Submit a statement and supporting documentation explaining how thi: <br /> waste was managed. This is a Class II violation. <br /> Violation#106 -Failed to prepare and implement a contingency plan. <br /> Facility failed to prepare a contingency plan. The owner or operator shall prepare a contingency plan designed to <br /> minimize hazards to human health or the environment from fires, explosions, or any unplanned release of hazardous <br /> waste to air, soil, or surface water and immediately implement that plan whenever there is a fire, explosion, or releas <br /> of hazardous waste which could threaten human health or the environment. Immediately prepare a contingency plar <br /> and submit a copy to the EHD. This is a Class II violation. <br /> Violation#110 -Failed to complete training on hazardous waste management and emergency response <br /> procedures. <br /> According to Mr. San, he has not had time to conduct full hazardous waste training in over a year. Personnel who <br /> handle hazardous waste shall be trained within six months of assignment and take part in an annual review of the <br /> initial training received. This program shall be directed by a person trained in hazardous waste management <br /> procedures. At a minimum, the training program shall be designed to ensure that facility personnel are able to <br /> respond effectively to emergencies by familiarizing them with emergency procedures, emergency equipment, and <br /> emergency systems, including where applicable: <br /> - hazardous waste management procedures relevant to the positions in which they are employed <br /> -contingency plan implementation <br /> - procedures for using, inspecting, repairing, and replacing facility emergency and monitoring equipment <br /> - key parameters for automatic waste feed cut-off systems <br /> -communications or alarm systems <br /> - response to fires or explosions <br /> -response to ground-water contamination incidents <br /> -shutdown of operations <br /> The owner or operator shall maintain the following documents and records at the facility: <br /> 1. the job title for each position at the facility related to hazardous waste management, and the name of each <br /> employee filling each job; <br /> 2. written job description for each position listed above; <br /> 3. written description of the type and amount of both introductory and continuing training that will be given to ea& <br /> person filing positions listed above; <br /> 4. records that document that the training has been given to and completed by facility personnel. <br /> Training records on current employees shall be kept until closure of the facility. Training records on former employe( <br /> shall be kept for at least three years from the date the employee last worked at the facility. Immediately provide <br /> employees with initial or refresher hazardous waste training. Submit a copy of the roster and the syllabus to the EHC <br /> This is a Class II violation. <br /> Page 6 of 10 <br />