Tiered Permitting Checklist Summary of Violations

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1 County of Sacramento Environmental Management Department Environmental Compliance Division Armstrong Ave. Suite A Mather, CA Voice (8am 5pm): 916/ FAX: 916/ Tiered Permitting Checklist Summary of Violations This is an inspection element checklist of common types of violations of Federal, State, or local laws and regulations. For specific details about your inspection, refer to your Notice to Comply (NTC). VIOLATION CODE All Tiers Q CCR AUTHORITY DESCRIPTION This facility has the required equipment necessary for the hazards that are posed by the HW handled Q CCR Leaks and/or spills from the HW tank system are managed immediately Q CCR HW tank systems are operated properly Q CCR (b), Incompatible wastes are managed properly Q411 / Q474 / Q533 Q467 / Q527 / Q592 Q475 / Q534 / Q601 File Review HSC 25201(a) Facility has a valid Permit to Operate from the CUPA HSC (a) A permit to treat HW has been obtained 22 CCR (a), (j) A written incident report for release, fire and/or explosion was submitted Q600 HSC Facility has a valid Permit to Operate from the CUPA Q CCR (j) Submitted a contingency plan activation report to CUPA PBR/CA Q438 / Q CCR HW tank systems have secondary containment Q416 / Q CCR (a)(2) An Adjustment for the Closure Cost Estimate was completed by March 1 of each year Q417 / Q CCR (a)(1) A Treatment Unit Written Estimate of Closure Costs was submitted Q418 / Q CCR (a)(3), (a)(4) Closure Cost Estimate was revised for a Closure Plan and/or cost increase change Q413 / Q535 22CCR , HSC (b)(1) Phase I Environmental Assessment Checklist submitted Q424 / Q CCR (k) A complete HW tank system assessment was kept on file at the facility Q425 / Q548 Q427 / Q550 Q429 / Q CCR (a), (b), (c), (e) (h) (g) Existing HW tank system without secondary containment has been assessed and certified annually Treatment: Reassessment of the TP Tank systems P.E. Assessment Existing HW tank system assessment is complete Q431 / Q CCR (l), (m) Replacement of parts for the HW tank system have been approved by the CUPA Q436 / Q CCR (a) HW tank system is inspected at least once each operating day Q CCR (b) Cathodic protection systems are inspected Page 1 of 6

2 Q466 / Q CCR , , The HW tank system was properly closed Q CCR HW tank systems are operated properly Q CCR (b), Incompatible wastes are managed properly Q CCR (a) Ignitable or reactive HW containers are protected from sources of ignition or reaction CA Q445 Q446 Q447 Q448 Q449 Q450 Q451 Q452 Q453 Q454 HSC (a)(1)(G), (a)(11), (b)(1) HSC (a)(1)(A), (a)(1)(C), (a)(1)(D), (a)(1)(E), (a)(1)(F), (a)(2) (a)(3) (a)(4) (a)(5) (a)(6) (a)(7) (a)(8) (a)(9) Aqueous wastes containing hexavalent chromium are treated Aqueous wastes containing listed inorganic constituents, except asbestos, are treated Aqueous wastes with listed organic constituents are treated Wastes which contain or are contaminated with listed constituents, except asbestos, are treated Alum, gypsum, lime, sulfur or phosphate sludges are treated Listed special wastes that meet the criteria and requirements of special wastes are treated Wastes, except asbestos, that have been classified by DTSC as special wastes are treated Soils contaminated with listed metals are treated Oil mixed with water and oil/water separation sludges are treated Inorganic acid or alkaline wastes are treated Q790 HSC (a), (b) Conditionally Authorized: Hazardous Waste Treatment Process Combinations Q793 HSC 6.5, (c)(4); CA Treatment: Secondary Containment for Treatment in Containers Q414 HSC (e) Onsite HW Treatment Information submitted Q415 HSC (k) Amended Onsite HW Treatment Information submitted Q439 HSC (c)(6), (c)(7) Records for conducting HW treatment are maintained onsite for five years Q440 HSC (c)(5), (c)(7) Records for scheduling and logging inspections are maintained onsite for five years Q445 HSC (a)(1)(G), (a)(11), (b)(1) Aqueous wastes containing hexavalent chromium are treated Q468 HSC (g) The HW treatment unit was closed properly and the CUPA was notified CE Q496 Q CCR HSC (c)(3) 22 CCR HSC (c)(4) HW classified as special waste is treated to remove water from HW HW classified as special waste is treated to remove components from HW Q498 HSC (c)(5) HW from food or food byproducts is treated for corrosivity or toxicity Q499 HSC (c)(6) HW is treated by gravity separation Q500 HSC (c)(7) HW is treated by neutralization in a laboratory Q501 HSC (c)(8) HW treatment is carried out in a QA/QC laboratory Page 2 of 6

3 Q502 HSC Reusable soiled textile materials are laundered at the facility Q503 Q504 Q505 Q506 Q507 Q508 Q509 Q510 Q511 Q512 Q513 Q514 Q CCR (a)(1); HSC CCR (a)(2); HSC CCR (a)(3); HSC CCR (a)(4); HSC CCR (a)(5); HSC CCR (a)(8); HSC CCR (a)(6); HSC CCR (a)(7); HSC 6.5, (c)(4) 22 CCR (a)(9); HSC CCR (a)(10); HSC CCR (a)(11); HSC (c)(1), (c)(2), 22 CCR (a)(12); HSC (c)(1), 22 CCR (a); HSC 6.5, (c) Aqueous wastes containing hexavalent chromium are treated Aqueous wastes containing listed metals and/or fluoride salts are treated Aqueous wastes with < 10% total organic carbon and < 1% total volatile organic compounds are treated Wastes which contain or are contaminated with listed metals and/or fluoride salts are treated Alum, gypsum, lime, sulfur or phosphate sludges are treated Inorganic acid or alkaline wastes are treated Listed special wastes that meet the criteria and requirements of special wastes are treated Wastes, except asbestos, that have been classified by DTSC as special wastes are treated Soils contaminated with listed metals are treated Various used oil wastes and oil/water separation sludges are treated Empty contaminated containers are treated Multi-component resins are treated Conditionally Exempt: Hazardous Waste Treatment Process Combinations Q476 HSC (d)(7) Onsite HW Treatment Information submitted Q477 HSC (i) Amended Onsite HW Treatment Information submitted Q494 HSC (d)(3), (d)(5), (d)(6) Records for conducting HW treatment are maintained onsite for three years Q495 HSC (d)(4), (d)(5) Records for scheduling and logging inspections are maintained onsite for three years PBR Q CCR (d)(4)(D) Training for cyanide treatment has been provided Q CCR (c)(5) Effluent or treatment residuals are discharged compliantly Q566 Q CCR (d)(7)(A), (d)(7)(B), (d)(7)(C) 22 CCR or ; 22 CCR (d)(1), (d)(2) Spent cyanide-containing process solutions are treated Cyanide-containing aqueous wastes are treated Q CCR (a)(1) Aqueous wastes containing hexavalent chromium are treated Q CCR (a)(8) Inorganic acid or alkaline wastes are treated Q570 Q571 Q CCR (a)(2): 22 CCR (a)(2) 22 CCR (a)(1)(B) and (a)(2)(B) 22 CCR (a)(2) 22 CCR (a)(4) Aqueous wastes containing listed metals and/or fluoride salts are treated Aqueous wastes with < 10% total organic carbon and < 1% total volatile organic compounds are treated Wastes which contain or are contaminated with listed metals and/or fluoride salts are treated Q CCR (a)(5) Alum, gypsum, lime, sulfur or phosphate sludges are treated Q574 Q CCR CCR (a)(6) 22 CCR CCR (a)(7) Listed special wastes that meet the criteria and requirements of special wastes are treated Wastes, except asbestos, that have been classified by DTSC as special wastes are treated Page 3 of 6

4 Q CCR (a)(2): 22 CCR (a)(9) Soils contaminated with listed metals are treated Q CCR (a)(10) Various used oil items and oil/water separation sludges are treated Q CCR (a)(11) Empty contaminated containers are treated Q CCR (a)(12) Multi-component resins are treated Q CCR (d)(4)(A), (d)(4)(B), (d)(4)(C) Cyanide-containing waste generation has been reduced Q CCR 45, (c)(12); PBR Treatment: Secondary Containment for Treatment in Containers Q CCR (b)(2) Onsite HW Treatment Information submitted Q CCR (c)(2) Amended Onsite HW Treatment Information submitted Q CCR (c)(10) Annual Report submitted Q CCR and CCR (b) Ground water contamination and monitoring data was reported Q CCR Preparedness and prevention equipment is tested and maintained Q CCR (d)(7)(E) Records for cyanide treatment were maintained at the facility for three years Q CCR HW contingency plan is complete Q CCR HW contingency plan is maintained at the facility and submitted to required authorities Q CCR Corrective action documents are submitted Q CCR Training for HW management has been completed and records are maintained at the facility Q CCR HW contingency plan has been prepared and implemented Q CCR (c)(8) Documents for operating a FTU are maintained onsite Q CCR Ignitable or reactive HW containers are located at least 50 ft. from the property line Q CCR HW container storage areas are inspected at least weekly Q CCR HW containers are compatible with the HW being stored Q CCR HW containers are in good condition Q CCR HW containers are always kept closed except when adding or removing HW Q CCR This facility maintains adequate aisle space for unobstructed response to emergencies Q CCR This facility has the required equipment necessary for the hazards that are posed by the HW handled Q CCR The facility is maintained and operated to minimize the release of a HW Q CCR Leaks and/or spills from the HW tank system are managed immediately Q CCR The facility has adequate security Q CCR (c)(7) The exterior of the treatment unit is marked permanently P/THHWCF Q CCR (a)(4), (d)(3) The location is large enough for safe operation Page 4 of 6

5 Q CCR (a)(4), (d)(5) The location has a physical barrier to delineate the perimeter of the handling and storage areas Q CCR (a)(4), (d)(4) The surface at the location is adequately paved and protected Q CCR (a)(4), (e) The location consolidates HW properly Q CCR (a)(4), (d)(1) The location is clearly marked to control public access Q CCR (a)(4), (d)(7) The location has a canopy/roof that covers the waste handling areas Q CCR (a)(4), (d)(9) The location has a HW storage area that is secured and lighted Q CCR (a)(4), (d)(6) The location has an approved area/structure to store containers of ignitable/reactive HW Q CCR (a)(4), (d)(10) The location has traffic control that has been approved Q CCR (a)(4), (d)(8) The location has posted warning signs Q CCR (a)(4), (d)(2) The location has an approved buffer zone Q CCR (a)(4), (h) Reports and records for operating the P/THHWCF are maintained for three years Q630 Q631 Q655 PHHWCF Q CCR (a)(4), (i) 22 CCR (a)(4), (g) 22 CCR (a)(3)(B), (b)(9) File Review 22 CCR (d)(6) A written report of any incident of noncompliance was submitted to the CUPA within 15 days Records for accepting HW from a small quantity commercial source have been established (CESQG's) The location accepts HW from small quantity commercial sources separate from household HW PHHWCF Information submitted and authorization to operate received from CUPA Q654 HSC (a) A permit to treat HW has been obtained Q CCR (b) A written closure cost estimate was submitted Q CCR (b)(1) An adjusted written closure cost estimate for inflation was submitted Q CCR (c) Financial Assurance Certification for Closure submitted Q CCR Preparedness and prevention equipment is tested and maintained Q CCR (b) Cathodic protection systems are inspected Q CCR (k) A complete HW tank system assessment was obtained and kept on file at the facility Q612 Q614 Q CCR (a), (b), (c), (e) (h) (g) Existing HW tank system without secondary containment has been assessed and certified annually Treatment: Reassessment of the TP Tank systems P.E. Assessment Existing HW tank system assessment is complete Q CCR (l), (m) Replacement of parts for the HW tank system have been approved by the CUPA Q CCR HW contingency plan is complete Q CCR HW contingency plan is maintained at the facility and submitted to required authorities Q CCR Training for HW management has been completed and records are maintained at the facility Page 5 of 6

6 Q CCR HW contingency plan has been prepared and implemented Q CCR (a) HW tank system is inspected at least once each operating day Q CCR (c)(9)(D), CCR (b) Ground water contamination and monitoring data was reported Q CCR HW tank systems have secondary containment Q CCR (a)(2)(G) Tank systems are in compliance with applicable requirements Q CCR (a)(2)(G)(5)(A) Phase I Environmental Assessment Checklist and Certification submitted Q CCR (a)(2)(A) A written waste analysis plan has been prepared Q CCR (a)(3) An Operation Plan was properly completed and maintained at the facility Q CCR Ignitable or reactive HW containers are located at least 50 ft. from the property line Q CCR HW container storage areas are inspected at least weekly Q CCR HW containers are compatible with the HW being stored Q CCR HW containers are in good condition Q CCR HW containers are always kept closed except when adding or removing HW Q CCR This facility maintains adequate aisle space for unobstructed response to emergencies Q CCR This facility has the required equipment necessary for the hazards that are posed by the HW handled Q CCR The facility is maintained and operated to minimize the release of a HW Q CCR Leaks and/or spills from the HW tank system are managed immediately Q CCR HW tank systems are operated properly Q CCR (b), Incompatible wastes are managed properly Q CCR 45; 22 CCR (a) Ignitable or reactive HW containers are protected from sources of ignition or reaction Q CCR The facility has adequate security Q CCR , , The HW tank system was properly closed Q CCR (a)(6) HW was disposed of within one year from the date of collection THHWCF File Review Q CCR (b) An Operation Plan was properly completed and maintained at the facility Q CCR (f) The location was cleaned up within 144 hours of the termination of the session 3/6/2017 JM W:\DATA\FORMSARCHIVE\HM\CHECKLISTS - ALL EC MARCH 2017\TIERED PERMITTING CHECKLIST SUMMARY OF VIOLATIONS.DOC Page 6 of 6

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