HomeMy WebLinkAbout2020-03-05; Department of Environmental Health Violation Update; Calderwood, MichaelTo the members of the:
CITY COUNCIL
Date &_k CA ....f_ CC~
CM ...1:.. COO _:t:... DCM (3) ~
March 5, 2020
To:
From:
Via:
Re:
Council Memorandum
Honorable Mayor Hall and Members of the City Council
Michael Calderwood, Fire Chief
Jennie Marinov, Senior Management Analyst
Scott Chadwick, City Manager
Department of Environmental Health Violation Update
{cityof
.Carlsbad
Memo ID# 2020020
This memorandum provides an update following a notice of violation issued by the San Diego
County Department of Environmental Health (DEH) at Fire Station 1 on Feb. 27, 2020.
Background
Carlsbad fire stations collect and store medical waste generated from emergency medical
service vehicles. Sharps containers are located at each fire station to safely store used needles
and small glass medication vials. All collected medical waste is eventually transferred and
consolidated at Fire Station 5 for outside collection and disposal. ·
Discussion
DEH conducts a Certified Unified Program Agency (CUPA) routine inspection to verify
compliance with the Hazardous Materials Business Plan (HMBP) for the facility. On Feb. 27, DEH
conducted a routine inspection of Fire Station 1 with Public Works facilities maintenance staff.
During the inspection, the DEH inspector noted that the facility generates sharps waste from
emergency medical service vehicles at the station. This activity has not been previously
reported in the HMBP. Subsequently, the inspector issued the attached notice of violation
directing city staff to update the HMBP and add the sharps waste to the California
Environmental Reporting System (CERS) as chemical inventory information for hazardous waste
and/or medical waste.
Actions and Next Steps
On March 2, Public Works facilities maintenance staff updated the chemical inventory
information for Fire Station 1 in CERS and submitted a Corrective Action Form to document full
compliance.
Additionally, Carlsbad FD and Public Works facilities maintenance staff have confirmed sharps
waste at the other fire stations currently operating with HMBPs is being reported to DEH.
Fire Department
Safety Center 2560 Orion Way I Carlsbad, CA 92010 I 760-931-2141 t
DEPARTMENT OF ENVIRONMENTAL HEALTH VIOLATION UPDATE
Honorable Mayor Hall and Members of the City Council
March 3, 2020
Page 2
Following the inspector's recommendation, fire staff will ensure waste sharps containers are
labeled with the facility's address and phone number as soon as waste is accumulated in the
containers, and before being consolidated at Fire Station 5.
Conclusion
The violation has been fully corrected and closed. No additional enforcement actions are
anticipated.
Attachment: Notice of Violation
CC: Celia Brewer, City Attorney
Paz Gomez, Deputy City Manager, Public Works
John Maashoff, Public Works Manager
Nick Ordille, Assistant Fire Chief
Eric Evonsion, Battalion Chief
Fire Department
Safety Center 2560 Orion Way I Carlsbad, CA 92010 I 760-931-2141 t
COUNTY OF SAN DIEGO
COMPLIANCE INSPECTION REPORT · ·
INSPECTION DATE: 02/27/2020 PAGE 1 OF 7
RECORD ID#: DEH2004-HUPFP-204532
TIME START: 8:00 AM END: 9:20AM
FACILITY NAME: CARLSBAD FIRESTATION #1
ADDRESS: 1275 CARLSBAD VILLAGE DR
CITY/ZIP: CARLSBAD ------------------/92008
SPECIALIST: Mirna Shaker
INSPECTION CONTACT:Charles Balteria
TITLE: Program Manager
PHONE: (760) 434-2949
E-MAIL:charles.balteria@carlsbadca.gov
On the above date, the County inspected your facility under the authority of the California Health and Safety Code (H&SC), to determine compliance with applicable provisions
of the H&SC, the California Code of Regulations (CCR), and the San Diego County Code of Regulatory Ordinances (SDCC), This report serves as a Notice to Comply (H&SC 25187.8
& 25404.1.2) for any minor violations as defined in H&SC 25404 and 25117.6. This report may contain both minor and more significant (Class II) violations. Minor violations do
not include repeat violations or violations remaining uncorrected for more than 30 days (or as specified below). Minor violations do not include knowing, willful, intentional, or
chronic violations; nor do they include violations showing a pattern of neglect or disregard. The remarks below are intended to provide guidance to correct any violations
indicated on the attached violation report. You must submit a written response to this report within 30 days (or as specified below) demonstrating that all violations have been
corrected or include a written notice of disagreement that clearly states the reason for any disputed violations. Prompt correction can protect you from penalties for a "minor
violation". Penalties can be imposed for each day in violation for all other violations even if they are corrected promptly. However, correction within 30 days (or as specified
below) will make a penalty less likely.
NOTE: Reinspection fees will be charged if additional inspections are required to determine compliance.
Yes
[g]
gJ
[g]
N/A"5~~.
D Unified Program Facility Permit Current
□ .~ :Hazar doLJsJ'v'l~te·rials Business Plan Available
--=:-:;;:::--~-~-:_-~C,c===--3'-~~
D Employee Training is Adequate
Yes
□
[g]
[g]
N/A --:---.
[g] Contingency Plan Available □ LQG
□ Employee Training Records Available ~
□ Universal Waste Managed Properly
□ SQG
[}. ~ ~T Vi.Ms.t'e~Qtsp]i~ll'retqdsAvailable for Review □ [g] Waste Containers D Closed □ Labeled
-~~ ~ c=-3=--_,;s_-~--:;:,c:-"' ====-~~------ - -~ --
[g] D Emergency Contacts Current D Updated today
~®f.[j; ~~liifni~a-11[v~tgrvl&HfFcL_~e~~□ ~pd_ateg Jo day
CONSENT TO CONDUCT INSPECTION GRANTED BY: Charles Balteria
INTRODUCTION:
□ [g]
Routine Inspection
(HMBP, MW)
Waste Containers in Good Conditiqn
Permit Expires On. 03/31/2020
TITLE: Program Manager
Today I conducted a Certified Unified Program Agency {CUPA) routine inspection of Carlsbad Fire Station #1 to verify compliance
with the Hazardous Materials Business Plan (HMBP) requirements. Charles Balteria, Program Manager, gave me consent to
conduct today's inspection and was present during the facility walk·through.
This facility is a fire station with a back·up generator. The facility generates waste sharps in their fleet vehicles but consolidates
them at Fire station #5.
According to this inspection. this facility appears to be subject to:
• Hazardous Materials Business Plan (HMBP) requirements for storing/handling hazardous materials on site in reportable
quantities (~55 gallons of liquid, 500 pounds of solid, or 200 cubic feet of gas).
• The Medical Waste Generator requirements as a Small Quantity Generator (SQG) of medical waste
(< 200 lbs/month of medical waste).
VIOLATION# 1
HMD4216 Failed to submit or report in CERS chemical inventory information for hazardous waste and/or medical waste,
and keep up to date. SDCC 68.904(a)(2)
Classification: Class II
Observations:
The facility generates sharps waste on their fleet vehicles, however, the sharps waste are not being reported in the California
Environmenta.I Reporting System {CERS). The facility consolidates their medical waste at Fire station #5.
Corrective Action Due By:03/28/2020
This violation can be corrected by logging into CERS and reporting the sharps waste.
HM-924(01/15)
COUNTY OF SAN DIEGO
SUPPLEMENTAL COMPLIANCE·.
INSPECTION DATE: 02/27/2020 PAGE 2 OF 7 --RECORD ID#: DEH2004-HUPFP-204532
INSPECTION REPORT
Within 30 days, provide documentation of your corrective action. You may use the form at the end of this report and email to
mirna.shaker@sdcounty.ca.go
INSPECTION REMARKS:
California Environmental Reporting System (CERS ID: 10364050) last re-certification was on 2/24/20.
The HMBP is available on site.
The generator is maintained by Global Power on a monthly basis. Facility employees do not operate the generator.
Training documents for the City of Carlsbad maintenance staff were available for review for three years.
Ensure waste sharps containers are labeled with the facility's address and phone number as soon as waste is accumulated in the
containers, and before being consolidated at Fire station #5.
Helpful Websites:
• For guidance documents on hazardous materials-related topics,
go to: http://www.sandiegocounty.gov/content/sdc/deh/hazmat/hmd publications.html
• For information on the California Environmental Reporting System (CERS),
go to: http://www.sandiegocounty.gov/content/sdc/deh/hazmat/hmd cers.html
• If you have questions on: permit fees, business plan requirements, or hazardous waste regulations,
go to: http://www.sandiegocounty.gov/content/sdc/deh/hazmat.html
• To find out the latest San Diego County News and receive updates, subscribe to our govdelivery emails:
https://pubiic.govdelivery.com/accounts/CASAND/subscriber/new
If you have any questions regarding this inspection, please contact Mirna Shaker' , 760-535-2235,
Mirna.Shaker@sdcounty.ca.gov
INSPECTION PHOTOS
None
All regulated businesses are required by law to submit their Unified Program-related information and business updates
online through the California Environmental Reporting System (CERS). For additional information about CERS, go to: http://
www.sandiegocounty.gov/deh/hazmat/hmd cers.html
PRINTED NAME OF FACILITY REPRESENTATIVE ~ DATE SIGNED
Charles Balteria SIGNATURE 02/27/2020
TITLE OF FACILITY REPRESENTATIVE
Program Manager
Department of Environmental Health, Hazardous Materials Division, P.O. Box 129261, San Diego, CA 92112-9261
Phone: (858) 505-6880 http://www.sdcdeh.org
HM-924(01/15)
COUNTY OF SAN DIEGO
COMPLIANCE INSPECTION REPORT
Handlers of Hazardous Mat~rials and Small and Large
Quantity Generators of Hazardous Waste ,
INSPECTION DATE: 02/27/2020
RECORD ID#: DEH2004-HUPFP-204532
PAGE 3 OF 7
FACILITY NAME: *CARLSBAD FIRESTATION #1
ADDRESS:* 1275 CARLSBAD VILLAGE DR CITY/ZIP: *CARLSBAD 92008 ------------------------
Each violation checked below is for the section(s) of the California Health and Safety Code fHSC), California Code of Regulations {CCR), or the San Diego County Code {SDCC) indicated in italics. Incorporated provisions of Title 40 of the Code of Federal regulations {CFR are noted for reference. All violations must be corrected. Submit documentation of..
return to compliance to your Specialist. You may use the Corrective Action Form {HM-926) to document your return to compliance. Please coll {858} 505-6880 or your Specialist if
you have any questions. HMBP = Hazardous Materials Business Plan; CUPA = Certified Unified Program Agency; CERS = California Environmental Reporting System; SQG = Small
Quantity Hazardous Waste Generator; LQG = Large Quantity Hazardous Waste Generator
#
0 1010001
0 1010002
0 1010003
0 1010004
0 1010005
0 1010006
0 1010008
0 1010010
0 1010011
0 1010012
0 1010014
0 1010015
0 1010016
0 1020001
0 1030001
0 1020002
0 1040001
0 HMD1001
0 HMD1005
0 HMD1007
0 HMD1008
0 1010017
#
0 HMD0226
0 3030007
0 3030010
0 3030013
0 3030015
0 3030017
0 3030019
0 3030022
0 3030030
0 3030036
0 3010022
0 3020001
0 3030032
0 3030039
0 HMD0412
#
HM-923 (10-18)
HAZARDOUS MATERIALS REQUIREMENTS
VIOLATION DESCRIPTION
Failed to establish and implement a HMBP. HSC 25505{a) and 25507{a)
HMBP not submitted to the CUPA in CERS. HSC 25508{a)(l)(A); 27 CCR 15188{a),(b),{d)
Business Activities &/or Business Owner/Operator page not completed in CERS. 19 CCR 2652(a)(1); SDCC 68.904{b); HSC 25508{a){1){A)
Chemical inventory incomplete or not submitted in CERS. HSC 25505{a){l); 25507(a); 25508.l{a-b); 19 CCR 2654 (a) or (d)
Site map not submitted in CERS or not sufficient. HSC 25505(a){2); 25508.l(f); 19 CCR 2652{a){3)
Failed to update HMBP in CERS within 30 days of a substantial change to any portion of the HMBP, including inventory changes or facility information.
HSC 25508.l{a-f); 19 CCR 2654(d); SDCC 68.904(c){6)
HMBP not certified annually as complete and accurate in CERS. HSC 25508(a){1){A), 25508.2, 19 CCR 2654{b)
Emergency response plan and procedures to mitigate a release or threatened release not adequate, not established or not submitted in CERS. HSC
25505(a){3), 25508(a){l)(A); 19 CCR 2658
Failure to notify property owner in writing that the business is subject to the HMBP program. HSC 25505.1
Failure to provide a copy of HMBP to the property owner.within five working days_upon request from property owner. HSC 25505.1
Failure to submit emergency response plan in CERS, when not meeting agricultural handler exemption. HSC 25507.l{a) and 25508(a){l){A); 19 CCR 2670,
2671
Failure to subn:iit employee training plan in CERS, when not meeting agricultural handler exemption. HSC 25507.l{a) and 25508{a)(l)(A)
HMBP not established or submitted in CERS, when not meeting the remote site exemption. HSC 25507.2 and 25508(a){1){A)
Employee training and/or plan for safety procedures in the event of a release or threatened release of a hazardous material not adequate, not
established or not submitted in CERS. HSC 25505{a)(4), 25508{a)(l){A); 19 CCR 2658, 2659{a)
{AWM) Failure of agricultural handler to post warning signs on buildings where pesticides, petroleum, or fertilizers are stored, that are visible from any
direction of probable approach, contain all required information, and are in appropriate language. HSC 6.95 25507.l{a)(2); 19 CCR 2670, 2671
Initial &/or annual employee training not conducted in safety procedures for a hazardous material release or threatened release &/or employee training
records not available or not maintained for 3 years. HSC 25505{a){4); 19 CCR 2659(b)
Hazardous materials release or threatened release not immediately reported to the CUPA and OES upon discovery. HSC 25510{a); 19 CCR 2631(a)
Unified Program Facility permit not obtained for hazardous materials. SDCC 68.904; 68.905; 68.906, 68.907; 68.907 .1
Emergency contact not provided or current in CERS. HSC 25508.l(f); SDCC 68.904{b)
Highly toxic gas {TLV<10 ppm) not disclosed in CERS. SDCC 68.1113{a)
Annual carcinogen/reproductive toxin list not submitted in CERS. SDCC 68.1113{b)
HMBP not· readily available to facility personnel or the CUPA. HSC 25505{c)
HAZARDOUS WASTE REQUIREMENTS FOR SQGS ONLY
VIOLATION DESCRIPTION
Did not accumulate waste in a container or tank. 22 CCR 66262.34{d){2); 40 CFR 262.34{d)(2)
Failed to properly label/date hazardous waste container &/or tank. 22 CCR 66262.34{f)
Accumulated waste too long (>180 or 270 days) or {>90 days). HSC 25201{a), 25123.3{h)(l); 22 CCR 66262.34{d); 40 CFR 262.34{e) and/or (f)
Failed to accumulate hazardous waste·in a container that is in good condition. 22 CCR 66262.34(d)(2); 40 CFR 262.34{d)(2), 265.171
Failed to accumulate or store hazardous waste in a lined &/or compatible container. 22 CCR 66262.34{d){2); 40 CFR 262.34{d){2), 265.172
Failed to properly close hazardous waste container(s). 22 CCR 66262.34{d)(2); 40 CFR 262.34{d)(2), 265.173
Failed to inspect hazardous waste storage area at least weekly. 22 CCR 66262.34{d)(2); 40 CFR 262.34{d)(2), 265.174
Failed to properly separate incompatible waste. 22 CCR 66262.34{d){2); 40 CFR 262.34{d)(2), 265.177
Failed to maintain &/or operate facility to minimize the possibility of a fire, explosion, or any unplanned sudden or non-sudden release of hazardous
waste or hazardous waste constituents. 22 CCR 66262.34{d){2); 40 CFR 262.34{d)(4), 265.31
Failed to maintain adequate aisle space. 22 CCR 66262.34{d){2); 40 CFR 262.34{d)(4), 265.35
Failed to post, next to the telephone, emergency information containing the location of emergency equipment, contact names and phone numbers. 22
CCR 66262.34{d){2); 40 CFR 262.34{d){5){ii) .
Failure to ensure employees are thoroughly familiar with proper waste handling and emergency procedures during normal facility operations and
emergencies. 22 CCR 66262.34{d)(2); 40 CFR 262.34{d)(5)(iii) ·
Failed to maintain the following emergency response equipment or equivalent: 1) An internal communication or alarm system; 2) A communication
device, such as a telephone; 3) Portable fire extinguishers, fire/spill control equipment and decontamination equipment; and 4) Water at adequate
volume and pressure. 22 CCR 66262.34{d)(2); 40 CFR 262.34{d)(4), 265.32
Failed to have an emergency coordinator on the premises or on call, and available during an emergency. 22 CCR 66262.34{d)(2); 40 CFR 262.34{d){5)(i)
Failed to implement and/or coordinate emergency response measures du~ing an emergency, spill/release. 22 CCR 66262.34{d)(2); 40 CFR 262.34{d){5)
(iv)
HAZARDOUS WASTE TANK SYSTEMS FOR SQGS ONLY
VIOLATION DESCRIPTION
#
#
#
COUNTY OF SAN DIEGO
COMPLIANCE INSPECTION REPORT
Hazardous Materials and Hazardous Waste (continued)
INSPECTION DATE: 02/27/2020 PAGE 4 OF
RECORD ID#: DEH2004-HUPFP-204532
0 3030024
0 3030025
0 3030027
0 3030028
0 3050007
0 HMD1612
0 HMD1614
0 HMD1615
0 HMD0131
0 HMD0150
0 3030053
0 3010002
0 3010008
0 3010009
0 3010010
0 3010011
0 3010013
0 3010014
0 3030006
0 3010016
0 HMD0149
0 HMD0152
0 HMD0140
0 3250005
0 3050005
0 HMD0142
0 HMD0138
0 3010035
0 3010007
0 3030005
0 3050001
0 3050002
0 HMD0308
0 HMD0305
0 HMD0306
0 3030001
0 3030003
0 3030004
0 3050004
0 HMD0222
0 HMD0216
0 HMD0217'
0 HMD0219
0 3030057
0 HMD0023
Failed to operate uncovered tank to ensure at least 2 ft. offreeboard to prevent overtopping, unless the tank is equipped with a containment structure,
a drainage control system, or a diversion structure with a capacity that equals or exceeds the volume of the top 2 ft. of the tank. 22 CCR
66262.34(d)(2); 40 CFR 262.34(d)(3), 265.201(b)(c)
Failed to provide an overfill protection device on continuously fed hazardous waste tank(s). 22 CCR 66262.34(d)(2); 40 CFR 262.34(d)(3), 265.201(b)(4)
Failed to conduct daily tank inspection of discharge control system, monitoring equipment and waste level. 22 CCR 66262.34(d)(2); 40 CFR 265.201(c)
{1-3), 262.34(d)(3)
Failed to conduct weekly hazardous waste tank inspection(s) to detect signs of leakage and ensure that the construction materials, fixtures and
surrounding areas of the tank are in good condition. 22 CCR 66262.34(d)(2); 40 CFR 265.201(c)(4 & 5), 262.34(d)(3)
Failed to properly remove all waste upon closure, decontaminate, and document the closure of a hazardous waste tank system. 22 CCR 67383.3; 40 CFR
262.34(d)(3), 265.201(f)
Hazardous waste improperly stored in a tank system causing leaks, corrosion, or failure. 22 CCR 66262.34(d)(2); 40 CFR 262.34(d)(3), 265.201(b)
Failed to pre-notify the CUPA in writing prior to closing a hazardous waste tank system. 22 CCR 67383.3(a)(l)
Failed to properly accumulate ignitable or reactive waste in a tank system. 22 CCR 66262.34{d)(2); 40 CFR 262.34(d)(3), 265.201(g)
HAZARDOUS WASTE REQUIREMENTS FOR SQGS AND LOGS
RECORD KEEPING/OPERATIONAL REQUIREMENTS
VIOLATION DESCRIPTION
Unified Program Facility Permit not obtained &/or maintained for the generation of hazardous waste. SDCC 68.904; 68.905; 68.907.1
Failed to submit complete and accurate Facility Information in CERS. 27 CCR 15188(b-c); SDCC 68.904(b)
Failed to maintain waste analysis records, analytical records &/or waste determination results for at least 3 years. 22 CCR 66262.40(c)
Failed to obtain &/or maintain an active EPA ID Number. 22 CCR 66262.12(a)
Failed to properly complete a uniform hazardous waste manifest. 22 CCR 66262.23(a)
Failed to submit an Exception Report to DTSC for hazardous waste manifest. HSC 25123.3(h)(2); 22 CCR 66262.42(b), (c), &/or (d)
Failed to maintain copies of Uniform Hazardous Waste Manifest, consolidated manifest, or Bills of Lading for 3 years. HSC 25160.2(b)(3), 25185(a)(4); 22
CCR 66262.40(a), 66262.23(a)(3)
Failed to send copy of the uniform hazardous waste manifest to DTSC within 30 days of shipment. 22 CCR 66262.23(a)(4)
Failed to meet the consolidated manifesting requirements for waste shipment. HSC 25160.2(b)(3) &/or (c)
Failed to retain at the generator's place of business disposal records of spent lead-acid batteries for at least 3 years. 22 CCR 66266.81(a)(4)(A) &/or (B)
Failed to determine if a hazardous waste is restricted or prohibited from land disposal and has to be treated. 22 CCR 66268.7(a)(l)
Failure of recycler who recycles more than 100 kilograms per month of a recyclable material to submit the biennial Recyclable Materials Report (RMR) in
CERS when claiming exclusion or exemption. HSC 25143.l0(a), (c) &/or (d)
Failed to keep disposal receipts for drained used oil filters and/or drained fuel filters for 3 years. HSC 25250.22; 22 CCR 66266.130(c)(5)
Failed to report &/or update the required inventory information for hazardous waste(s) generated at the facility in CERS. SDCC 68.904(a)(2)
Failed to have Land Disposal Restriction documentation onsite for 3 years. 22 CCR 66268.7(a)(8)
Failed to obtain a Treatment, Storage and Disposal Facility (TSDF) permit or authorization to store/treat/dispose of hazardous waste. HSC 25201(a)
Failed to have adequate records demonstrating claim of exemption or exclusion for recyclable materials. HSC 25143.2(f)
Failed to notify the CUPA in CERS for onsite hazardous waste treatment/tiered permitting. HSC 25201(a)
Manifest signed by the TSDF not available for inspection. 22 CCR 66262.40(a); HSC 25185(a)(4)
Failure to annually submit notification of generator's intent to remotely consolidate hazardous waste. HSC 25110.l0(d)
DISPOSAL AND TRANSPORTATION
VIOLATION DESCRIPTION
Failed to prepare a hazardous waste manifest for the transport of a waste for off-site transfer, treatment, storage, or disposal. HSC 25160(b)(l) or (2),
25160.2{b)(9); 22 CCR 66262.20(a)
Failed to make a proper waste determination. 22 CCR 66262.11, 66262.40(c)
Failed to use a DTSC registered hazardous waste transporter to transport hazardous waste. HSC 25163{a)
Failed to properly dispose of hazardous waste at an authorized facility. HSC 25189.S(a)
Impermissible dilution of hazardous waste. 22 CCR 66268.3(a)
Disposed of used oil illegally. HSC 25250.S(a), 25189.S(a)
Failed to properly dispose of oil-based paint &/or hazardous waste latex paint liquid. HSC 25217.1, 25189.S(a)
STORAGE AND HANDLING
VIOLATION DESCRIPTION
Failed to meet the management requirements when handling or storing spent lead-acid batteries. 22 CCR 66266.81(a)
Failed to properly manage 'damaged' spent lead acid batteries so as to minimize the release of acid and lead and to protect the handlers and the
environment 22 CCR 66266.81{b)
Failed to properly manage, store, label &/or recycle used oil filters &/or used fuel filters. HSC 25250.22; 22 CCR 66266.130
Generator intentionally contaminated used oil with another hazardous waste other than minimal amounts of fuel. HSC 25250.7(a), (c)
Failed to properly label Excluded Recyclable Materials (ERM) accumulated in a container or tank. HSC 25143.9(a)
Failed to label hazardous material container within 10 days after the container was discovered to be mislabeled or inadequately labeled. HSC 25124(b)(3)
(A); 22 CCR 66262.34(f) ,
Failed to repackage and properly label damaged/deteriorated hazardous material container within 96 hours. HSC 25124{b)(3)(B); 22 CCR 66262.34(f)
Failed to properly segregate used oil &/or fuel drained from filters. HSC 25250.22(b)(4); 22 CCR 66266.130(c)(6)
Failed to comply with hazardous waste satellite container regulation. 22 CCR 66262.34{e)
Failed to properly empty container, failed to manage non-empty container, or inner liner removed from a container. 22 CCR 66261.7(b), (d), (e) &/or (r)
HM-923 (10-18)
,,
COUNTY OF SAN DIEGO
COMPLIANCE INSPECTION REPORT
-~ -
INSPECTION DATE: 02/27/2020 PAGE 5 OF 7
RECORD ID#: DEH2004-HUPFP-204532
Hazardous Materials and Hazard~us Waste (continued)
0 3030058
0 3030060
#
0 3010004
0 HMD0151
0 3020003
0 3030008
0 3030011
0 HMD0147
0 3030051
0 3040004
0 HMD0307
0 3010005
0 3010020
0 3010006
#
0 3010033
0 3010034
0 3030055
HM-923 (10-18)
Failed to mark date on empty container larger than 5 gallons &/or manage it within one year. 22 CCR 66261.7(f)
Failure of the owner or operator managing laboratory ha~ardous waste in a laboratory accumulation area to comply with the accumulation, storage,
management, training, and/or record-keeping requirements. HSC 25200.3.l(b) and/or (c)
UNIVERSAL WASTE HANDLER REQUIREMENTS
VIOLATION DESCRIPTION
Failed to obtain a California ID Number from DTSC or federal ID Number from USEPA prior to accumulating 5,000 kgs or more of Universal Waste. 22 CCR
66273.32(a-b)
Failed to maintain universal waste handler training records for 3 years. 22 CCR 66273.36(c),(d)
Failed to properly train handlers of universal waste in universal waste management and response procedures. 22 CCR 66273.36(a),(b)
Failed to properly label or mark Universal Waste container, package, or pallet (excluding CESQUWG) 22 CCR 66273.34
Failed to properly dispose of Universal Waste within one year. 22 CCR 66273.35(a) &/or (b)
Failed to keep records of offsite Universal Waste shipment(s) available for inspection for 3 years. 22 CCR 66273.39(c),(d)(2)
Failed to meet accumulation, labeling, marking, &/or containment standards for Universal Waste aerosol containers. HSC 25201.16(f)
Failed to manage universal waste in a manner to prevent release(s) to the environment. 22 CCR 66273.33; 66273.33.5
Disposal of universal waste (UW) to an unauthorized point. HSC 25189.5(a); 22 CCR 66273.31(a), 66273.8(b)
Failure of a universal handler of electronic devices or CRTs from an offsite source to notify DTSC 30 days prior to acceptance. 22 CCR 66273.32(c)
Failure of a universal waste handler to submit an annual report that includes all required information to DTSC by February 1 of every year . 22 CCR
66273.32(d)
Failure of the universal waste handler who sends electronic devices or CRTs to any foreign destination to notify DTSC 60 days prior to export and send a
copy to the CUPA. 22 CCR 66273.40(a)(3)
CERTIFIED APPLIANCE RECYCLER REQUIREMENTS
VIOLATION DESCRIPTION
Failure to obtain Certified Appliance Recycler certification (CAR) from DTSC. HSC 25211-.4
Failure of certified appliance recycler (CAR) to provide documentation that all materials that require special handling (MRSH) have been properly
removed and managed. HSC 25211.2, 25211.3 ·
Failure of certified appliance recycler (CAR) to properly remove and dispose of all materials that require special handling (MRSH). HSC 25211.3, 25212
(a), (b), and/or (c)
COUNTY OF SAN DIEGO
COMPLIANCE INSPECTION REPORT
Medical Waste Generators
INSPECTION DATE: 02/27/2020
RECORD ID#: DEH2004-HUPFP-204532
PAGE 6 OF 7
Each violation checked below is for the section(s) of the California health and Safety Code (HSC), California Code of Regulation {CCR), or the San Diego County Code {SDCC)
indicated in italics. All violations must be corrected. Submit documentation of return to compliance to your Specialist. You may use the Corrective Action Form (HM-926) to
document your return to compliance. Please call {858) 505-6880 or your Specialist if you have any questions. UPF = Unified Program Facility; MW=. Medical Waste; USPS= United States Postal Service; DOT= Department of Transportation .
#
1
#
#
#
0 HMD4201
~ HMD4216
0 HMD4202
0 HMD4203
0 HMD4204
0 HMD4205
0 HMD4206
0 HMD4207
0 HMD4208
0 HMD4209
0 HMD4210
0 HMD4211
0 HMD4212
0 HMD4213
0 HMD4214
0 HMD4215
0 HMD4306
0 HMD4307
0 HMD4308
0 HMD4219
0 HMD4220
0 HMD4251
0 HMD4252
0 HMD4253
0 HMD4254
0 HMD4255
0 HMD4256
0 HMD4257
0 HMD4258
0 HMD4259
0 HMD4260
0 HMD4311
0 HMD4313
0 HMD4301
0 HMD4302
0 HMD4303
0 HMD4309
0 HMD4310
HM-9255 MW {06-17)
VIOLATION DESCRIPTION
MEDICAL WASTE GENERATORS
STORAGE AND LABELING
UPF Permit not obtained. HSC 117705, SDCC 68.904; 68.905; 68.906; 68,907.1; 68.1202
Failed to submit or report in CERS chemical inventory information for hazardous waste and/or medical waste, and keep up to date. SDCC 68.904(a)(2)
Medical waste (MW) not separated from other waste at the point of origin. HSC 118275
Enclosure or designated accumulation area for MW containers not secured. HSC 118307, 118310
MW designated accumulation area not posted with an approved, legible biohazardous waste "warning sign" in English & Spanish or in another language,
in addition to English which can be read from a distance of at least 25 feet. HSC 118310
Medical SOLID WASTE not secured to deny access to unauthorized persons. SDCC 68.1211
Leak or spill of MW not properly decontaminated. HSC 118300
Sharps not stored in approved container or labeled with the words "sharps waste" or with the international biohazard symbol and the word
"BIOHAZARD". HSC 118285(a) & (d)
Full sharps container not taped closed or tightly-lidded to preclude loss of contents. HSC 118285(b)
Primary containers accumulating MW not labeled with an electronic tracking system label or a label with generator's name, address and phone number.
SDCC 68.1205
Medical waste not stored in approved and properly marked biohazard bags. HSC 118275(a)
Biohazard bags,not tied off to prevent leakage or expulsion of contents during storage and handling. HSC 118280(a)
Biohazardous bags not containerized in rigid, leak resistant, and covered containers or bins when placed for storage, handling, or transport. HSC
118280(c)
Waste container or bin not labeled with the words "Biohazardous Waste" or with the international biohazard symbol and the word "BIOHAZARD" on the
lid and sides. HSC 118280(c)
Reusable containers or bins for MW storage not thoroughly washed and decontaminated and maintained in a clean and sanitary manner. HSC 118295,
118305
Frozen (0"C/32"F) biohazardous waste stored for more than 90 days. HSC 118280(e)(2)
Full sharps container stored more than 30 days at >0"C. HSC 118285(c)
Biohazard bag waste stored more than 7 days at >0"C (for generators of 20 or more pounds a month). HSC 118280(e)(l)(A)
Biohazard bag waste stored >30 days at >0"C (for generators of <20Ibs/m'onth). HSC 118280(e)(l)(B)
MW interim storage area not marked with warning signs or international biohazard symbol legible from a distance of 5 feet. HSC 118307, 118310
MW interim storage area not properly secured. HSC 118307
TREATMENT AND DISPOSAL
VIOLATION DESCRIPTION
MW treated by unapproved method/procedure. HSC 118215
Standard written operating procedures for steam sterilization not established. HSC 118215(a)(2)(A)
Recording thermometer not calibrated annually. HSC 118215(a)(2)(B)
No records of annual thermometer calibration checks onsite for at least the past 2 years. HSC 118215(a)(2)(B)
Heat-sensitive tape or other approved method _not used for each load treated onsite. Hsc· 118215(a)(2)(C)
Monthly biological indicator or other approved indicator not used to confirm proper sterilization. HSC 118215(a)(2)(D)
Onsite steam sterilization did not reach 121· C (250" F) for at least 30 minutes. HSC 118215(a)(2)(B)
Treatment records or logs of dates, time, and temperature not maintained for at least 2 years. HSC 118215(a)(2)(E)
Disposal of untreated MW to an unauthorized point. HSC 118340
TRANSPORTATION REQUIREMENTS
VIOLATION DESCRIPTION
Transportation of MW without State Hauler Registration, USPS or requirements of the DOT "Materials of Trade Exceptions." HSC 118025
Medical waste tracking documents or logs not in vehicle transporting medical waste. HSC 118040(a)
Medical waste tracking documents or logs not complete. HSC 118040(b)
VIOLATION DESCRIPTION
SMALL QUANTITY GENERATORS ONLY
(<200 POUNDS OF MEDICAL WASTE GENERATED PER MONTH)
Medical Waste Management Plan (MWMP) not submitted to HMO (initial/updates), if onsite treatment. HSC 117935
Did not maintain and show proof of "onsite" medical waste treatment records for 3 years. HSC 117943
Did not maintain on file disposal receipts, tracking or shipping documents for medical waste shipped offsite for at least 3 years. HSC 117945
MWMP or equivalent information not on site (only for SQG doing onsite treatment or comply with pharmaceutical waste hauling exemption). HSC
117935, 118032
Did not meet the requirements of the pharmaceutical waste hauling exemption. HSC 118032
LARGE QUANTITY GENERATORS ONLY
#
#
#
0 HMD4351
0 HMD4352
0 HMD4353
0 HMD4501
0 HMD4502
0 HMD4503
0 HMD4504
0 HMD4505
0 HMD4506
0 HMD4401
0 HMD4402
0 HMD4403
0 HMD4411
0 HMD4412
0 HMD4413
0 HMD4421
0 HMD4422
0 HMD4423
0 HMD4432
0 HMD4441
0 HMD0147
0 HMD0307
HM-9255 MW {06-17)
COUNTY OF SAN DIEGO
COMPLIANCE INSPECTION REPQRT
Medical Waste Generators (contfoue_d)
INSPECTION DATE: 02/27/2020
RECORD ID#: DEH2004-HUPFP-204532
(>= 200 POUNDS OF MEDICAL WASTE GENERATED PER MONTH)
VIOLATION DESCRIPTION
MWMP not submitted to HMD (initial/updates) or incomplete. HSC 117960, 117970
Records of medical waste treatment not.available for 2 years. HSC 117975, 118215(a)(2)(E)
PAGE 7 OF
Did not make available disposal receipts, tracking or shipping documents for at least 2 years for medical waste shipped offsite. HSC, 117975
LOG MW ONSITE TREATMENT FACILITY
(>= 200 POUNDS OF MEDICAL WASTE GENERATED PER MONTH)
VIOLATION DESCRIPTION
Onsite MW treatment permit not obtained or renewed. HSC 117950, 118130; CCR 65620, 65623
Current copy of the MW treatment permit not available. HSC 118165, 118180; CCR 65621(f), 65623
Condition(s) of the MW treatment permit violated. CCR 65623
Operators who treat medical waste not trained in proper equipment use, proper protective equipment to wear and if necessary, proper cleanup of spills.
HSC 117967(a)
Initial and/or annual training for operators that treat medical waste not provided. HSC 117967(b)
Initial and/or annual training documentation for operators that treat medi.cal waste not available for two years, HSC 117967(c)
VIOLATION DESCRIPTION
Trace chemotherapy waste not segregated from other MW. HSC 118275(a)(4)
Trace chemotherapy waste container not labeled "Chemotherapy Waste" or "CH.EMO" on the lid and the sides. HSC 118275(a)(4)
Illegal disposal of chemotherapy waste. HSC 118340
Pathology waste not segregated from other MW. HSC 118275(a)(5)
Pathology waste container not labeled "Pathology Waste" or "PATH" on the lid and the sides. HSC 118275(a)(5)
Illegal disposal of pathology waste. HSC 118340
Pharmaceutical waste not segregated from other MW. HSC 118275(a)(6)
Pharmaceutical waste not labeled "HIGH HEAT" or "INCINERATION ONLY" on the lid and the sides. HSC 118275(a)(6)
Pharmaceutical waste stored more than 90 days when container is full, or stored longer than one year (maximum allowable time). HSC 118280(f)
Illegal disposal of pharmaceutical waste. HSC 118340, 118222(b)
Disposal of photo/hazwaste to an unauthorized point. HSC 25189.5
Failed to keep records of offsite Universal Waste shipment(s) available for inspection for 3 years. 22 CCR 66273.39(c),(d)(2)
Disposal of universal waste (UW) to an unauthorized point. HSC 25189.S(a), 25189(c),(d); 25189.2(c); 22 CCR 66273.31(a), 66273.8(b)
COUNTY OF SAN DIEGO
CORRECTIVE ACTION FORM TO
DOCUMENT RETURN TO COMPLIANCE
FACILITY NAME: CARLSBAD FIRESTATION #1
ADDRESS: 1275 CARLSBAD VILLAGE DR
CITY/ZIP: CARLSBAD /92008 ---------------
INSPECTION DATE: 02/27/2020
RECORD ID#: DEH2004-HUPFP-204532
SPECIALIST: Mirna Shaker
INSPECTION CONTACT:Charles Balteria -----------TITLE: Program Manager
PHONE: (760) 434-2949
E-MAIL:charles.balteria@carlsbadca.gov
VIOL# DATE INDICATE HOW VIOLATIONS WERE CORRECTED DUE DATE CORRECTED (Attach Any Supporting Documentation}
#1 HMD4216 3/2/2020 The HMBP for the facility has been updated in CERS to include sharps waste. See attached. 03/28/2020
I certify under penalty of law that this facility has corrected all violations marked an the Compliance Inspection Report/Notice of Violation. I have personally examined and arri
familiar with the information submitted and believe the information is true, accurate and complete. I am authorized to file this certification for the facility, and am aware that
there are significant penalties for submitting false information.
PRINTED NAME OF FACILITY REPRESENTATIVE
Charles Balteria
TITLE OF FACILITY REPRESENTATIVE
DATE SIGNED
2020
SEND COMPLETED FORM AND SUPPORTING DOCUMENTATION TO THE ADDRESS LISTED BELOW
COUNTY OF SAN DIEGO USE ONLY
REVIEWED BY:
SPECIALIST'S COMMENTS:
O All violations noted on date listed above were corrected
D Based On Information Provided By.The Facility
D Based On Field Verification By Specialist
DATE:
D RTC entered by Specialist on_: ----------
□ RTC entered by Office Assistant on: -------
Department of Environmental Health, Hazardous Materials Division, P.O. Box 129261, San Diego, CA 92112-9261
http://www.sdcdeh.org 858-505-6880
HM-926(01/15)
·.: I