HomeMy WebLinkAbout2022-01-13; County of San Diego Compliance Inspection Report on the Safety Training Center (District 2); Gomez, PazTo the members of the:
CITY COUNCIL
Date 1/1~124-CA ~ CC _y__
CM V ACM -/ DCM {3)..JL
Jan. 13, 2022
Council Memorandum
To:
From:
Honorable Mayor Hall and Members of the City Council
Paz Gomez, Deputy City Manager Publi~rks
Via: Geoff Patnoe, Assistant City Manager &-2:t'
{city of
Carlsbad
Memo ID# 2022007
Re: County of San Diego Compliance Inspection Report on the Safety Training Center (District 2)
This memorandum provides information on a compliance inspection report from the County of
San Diego Hazardous Materials Division, or HMD, on the Safety Training Center, or STC.
Background
The HMD conducts routine inspections of permitted facilities under the authority of the
California Health and Safety Code, or H&SC, to determine compliance with applicable provisions
of the H&SC, the California Code of Regulations, or CCR, and the San Diego County Code of
Regulatory Ordinances, or SDCC.
On Nov. 30, 2021, HMD staff arrived at the STC to inspect the facility with emphasis on shooting
range maintenance operations and related activities generating hazardous waste. Upon
completion of the on-site inspection, HMD inspectors informed city staff of two violations. A
final inspection report was provided to the STC Manager on Dec. 30, 2021.
Discussion
On Nov. 30, 2021, staff provided the HMD inspectors a facility tour and overview of operations,
shooting range maintenance and cleaning activities, and access to all records, waste storage
areas and waste treatment systems. All permitting requirements were current.
This was the fourth inspection of the STC since the facility opened in 2012. The last two
inspections occurred in August 2016 and September 2018, with no reportable violations or
corrective actions. Training activities have increased at the STC; however, the maintenance and
hazardous waste handling activities have remained the same since the last inspection in 2018.
Violation # 1:
Inspectors observed wastewater sludge generated from the facility wet-cleaning operations
accumulating on site in a 55-gallon pre-treatment drum requiring disposal within the hazardous
waste accumulation time limits of 12 months.
Public Works Branch
Fleet and Facilities Department
405 Oak Avenue I Carlsbad, CA 92008 I 760-434-2980 t
Council Memo -County of San Diego Compliance Inspection Report on the STC (District 2)
Jan. 13, 2022
Page 2
Action/Response:
Staff has requested additional guidance from the HMD as there is a discrepancy in the
interpretation of the wastewater treatment process used at the STC. The current process is
permitted through the Encina Wastewater Authority, or EWA. The HMD interprets the
treatment process as a satellite hazardous waste storage area.
In the interim, staff will coordinate with US Ecology and Veolia to determine the best method to
transport the wastewater sludge off-site for proper disposal. Staff will continue to work with
the HMD to determine how the treatment areas will be reported in the future and documented
in the California Environmental Reporting System, or CERS.
Violation # 2:
Inspectors observed heating, ventilation and air conditioning, or HVAC, filters and other lead-
contaminated debris stored behind the 25-yard range backstop area with containers that did
not have hazardous waste labels. While hazardous waste labels were placed on the stalls above
the storage area, each individual container or box did not bear these individual labels.
Action/Response:
The backstop area is a controlled access area and is clearly marked as a lead-contaminated
hazardous waste storage location for the STC. Staff designed and printed specific labels that
were placed on secondary containers containing lead-contaminated debris to meet the labeling
requirements outlined in the final inspection report. Action has been completed.
Next Steps
Staff will prepare a written response within 30 days of the report, as required by the HMD. Staff
will provide another Council Memorandum after all actions have been completed.
Attachment: A. STC Compliance Inspection Report dated Nov. 30, 2021
cc: Scott Chadwick, City Manager
Celia Brewer, City Attorney
Laura Rocha, Deputy City Manager, Administrative Services
Michael Calderwood, Fire Chief
Mickey Williams, Police Chief
Judy von Kalinowski, Human Resources Director
Robby Contreras, Assistant City Atton:1ey
Kristina Ray, Community & Engagement Director
John Maashoff, Public Works Manager
Ed Garbo, Risk Manager
Jason Kennedy, Safety Training Center Manager
ATTACHMENT A COUNTY OF SAN DIEGO
COMPLIANCE INSPECTION REPORT
FACILITY NAME: Carlsbad Safety Training Center (STC)
ADDRESS: 5750 ORION ST ------------------.,..,.-------CITY/ZIP: CARLSBAD /92010 -----------------------
INSPECTION DATE: 11/30/2021 PAGE 1 OF 10
RECORD ID#: DEH2014-HUPFP-000889
TIME START: 10:00 AM END: 1:00 PM
SPECIALIST: Alaaeddine Zahra
INSPECTION CONTACT:Jason Kennedy -------'-------TITLE: Facility Manager
PHONE: (760) 602-7584
E-MAIL:jason.kennedy@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.
[RI Unified Program Fqcilify Permit Current [RI Contingency Plan Available [RI LQG D SQG
[RI Hazardous Materials Business Plan Available [RI Employee Training Records Available
[RI Employee Trainjng@Ac:lequate [RI Universal Waste Managed Properly
[RI Waste Disposal Records Available for Review [RI Waste Containers [RI Closed D Labeled
[RI Emergency Contacts Current D Updated today [RI Waste Containers in Good Condition
[RI Chemical Inventory/Map Current D Updated today Permit Expires On 01/31/2022
CONSENT TO CONDUCT INSPECTION GRANTED BY: Jason Kennedy TITLE: Facility Manager
INTRODUCTION:
A routine compliance inspection was conducted at this facility on 11/30/2021.
Present from the Hazardous Materials Division (HMD) were Alaaeddine Zahra, EHSIII and Mirna Shaker, EHSII.
On-site facility representatives that assisted with the inspection were:
-Jason Kennedy, Facility Manager
-Jayce Galeazzi, Project Manager
-Jose Estrada, Facility Attendant
Consent for the inspection and to take photos was granted by Jason Kennedy.
This is a training facility for City of Carlsbad Police and Fire Department personnel and other public agencies, the facility operates
a shooting range on site.
The scope of the inspection covered the Hazardous Materials Business Plan, the Hazardous Waste Generator program (including
tiered permitting) and the Medical Waste Management Act program requirements.
Based on documents reviewed and statements by Jason Kennedy, the facility appears to be a Large Quantity
Generator (LQG) of RCRA hazardous waste ( .'.'.'.....1,000 kg of non-acute RCRA hazardous waste in a single month).
A summary of violations was issued on the day of inspection and the full report was issued on 12/13/2021.
The facility generates the following hazardous waste streams:
1-Dry cleaning of the range via a HEPA vacuum generates gun powder/metal fines managed as hazardous waste.
2-Wet cleaning of the range floor via "zamboni" accumulates gun powder/shooting range dust contaminated wastewater
(treated on site via a Conditionally Authorized tiered permitted filtration system).
3-Maintenance of the backstop (about once every 6 months), larger bullet fragments are recycled and fined ust is managed as
hazardous waste.
4-Maintenance of the facility HVAC system, generates pre-filters, mid-filters, and HEPA filters, all managed as hazardous waste.
5-Other range generated lead contaminated debris, such as waste sticky mats and rubber blocks with lead shot.
6-Spent/empty shotgun shells.
7-Spent filters used for filtering and reusing of ultrasonic cleaner liquid. The facility operates multiple ultrasonic cleaners where
HM-924(01/15)
COUNTY OF SAN DIEGO
SUPPLEMENTAL COMPLIANCE
INSPECTION REPORT
INSPECTION DATE: 11/30/2021 PAGE 2 OF 10 - -RECORD ID#: DEH2014-HUPFP-000889
firearms are cleaned. The solution inside the ultrasonic cleaners use a water based cleaner. Per Jason Kennedy, the spent
cleaning solution is not disposed but is replenished and is filtered for lead. The filters contaminated with lead are disposed as
hazardous waste. Per Jason Kennedy, after the ultrasonic cleaner is used, the firearms are then cleaned further with microfiber
towels. Using generator knowledge, the facility has determined the waste towels to be nonhazardous and are managed through
a laundry cleaning service.
8-Spent filters from CA wastewater treatment system.
9-Sludge accumulating at the bottom of the drum used to accumulate pre-treatment wastewater.
The facility cleans the range as following:
1-Larger bullet casings are collected.
2-Range floor is dry cleaned via HEPA vacuum.
3-Range floor is wet cleaned via zamboni
This facility has the following BMPs in place to minimize releases of hazardous waste from the range to the environment:
-HVAC with a three stage filtration sytem: Each gun range operates an HVAC system that pushes air away from the shooters
towards the backstop area where air is filtered through the three stage filtration system before being exhausted outside the
facility through roof exhausts. The filtration system is monitored for use via a gauge and replaced routinely as needed.
-Facility takes routine wipe samples from the roof where the filtration system exhausts to ensure that the filtration system is
operating properly.
-Routine maintenance of the backstop media to minimize excessive contamination of the backstop (vendor is Action Target).
-Sticky mats that are replaced routinely are used to minimize tracking of lead dust by range users.
-Maintaining the range under negative pressure and re-balancing of the ventilation system when necessary to ensure negative
pressure is maintained.
Range Floor Debris & Gun Powder:
-Per Jason Kennedy, the range floor collected debris contains enough gun powder to make the waste stream ignitable which is
why the vacuum waste is managed as ignitable hazardous waste .
-Zamboni generated wastewater contains gun powder and toxic metals from shooting range operations, this wastewater is
accumulated in a 55-gallon drum pre-treatment, the facility has determined that sludge accumulating at the bottom of the drum
may become ignitable if dried up and therefore when ready to be disposed (after cleaning of the drum) will be managed under
an ignitable waste stream to ensure safe hauling/disposal.
Conditionally Authorized Hazardous Waste Treatment System:
The facility operates a conditionally authorized (CA) treatment unit consisting of a drum and a filtration system made of 4
different sized particulate filters.
The wastewater collected from wet floor cleaning via the facility "Zamboni" (cleaning equipment) is first accumulated in a 55-
gallon drum then pumped to the filtration system. Effluent from the filtration system is drained to sewer and spent filters are
managed as hazardous waste. The facility collected samples from the treated effluent (before draining to sewer) and based on
sample analysis deemed the effluent non-hazardous and within acceptable discharge limits for local industrial wastewater
control program.
Sludge Accumulation in Pre-treatment Hazardous Waste Drum:
Over time, sludge begins accumulating in the bottom of the the 55-gallon drum (pre-treatment container), per Jason Kennedy,
the sludge contains gunpowder and other fines and should be managed as ignitable hazardous waste when disposed because if
the sludge was to dry during transport it may become ignitable.
When I asked Jason Kennedy why would the sludge be ignitable Jason Kennedy stated that when the Zamboni is used to clean
the range some trace sludge remains on the equipment, and when the sludge dries up it turns into a powder-like substance
which ignites easily if a flame is introduced to the mixture.
HM-924(01/15)
COUNTY OF SAN DIEGO
SUPPLEMENTAL COMPLIANCE
INSPECTION REPORT
INSPECTION DATE: 11/30/2021 PAGE 3 OF 10 --RECORD ID#: DEH2014-HUPFP-000889
Ammo Sent to Camp Pendleton:
-Per Jason Kennedy, ammunition received from the sheriffs department (i.e. surrendered ammo) is taken to Base Range at
Camp Pendleton and is either used or blown up for training purposes. Please note that the facility is responsible to make a
proper waste determination at the point of generation of the waste. If the waste is determined to be a hazardous waste, it must
be properly managed and hauled off as a hazardous waste.
Be advised, per 22 CCR§ 66261.2 (d)(l), a material is a waste if it is being recycled through being used in a manner constituting
disposal. Commercial chemical materials listed in section 66261.33, which are discarded commercial chemical products, off-
specification species, and which are applied to the land and application to the land is their ordinary manner of use are non-RCRA
hazardous wastes.
Other Notes:
Per Jason Kennedy, air monitoring was conducted on staff performing routine cleaning of the range.
Per Jason Kennedy, only he and Jose Estrada have access to the hazardous waste storage area and this area is inspected daily.
Ensure HW accumulation areas are inspected at least on a weekly basis.
VIOLATION# 1
3030057 Failed to comply with hazardous waste satellite container regulation. 22 CCR 66262.34(e)
Classification: Class II
Observations:
Observed wastewater sludge generated from the facility wet-cleaning operations accumulating on site in the 55-gallon
pretreatment drum, staff stated the drum is a satellite container for storage of pre-treatment hazardous waste.
Per Jason Kennedy, the sludge has been accumulating for over 12 months.
Accumulation time limit for pre-treatment waste:
Be advised that hazardous waste accumulating in the pre-treatment drum must meet hazardous waste accumulation time limits
for the facility (90 days for LQG's, or 12-months total on site for satellite accumulation) including any sludge accumulating in the
pre-treatment drum.
You may contact your hazardous waste hauler to determine if sludge accumulating in the bottom of the pre-treament drum can
be mixed and disposed with other waste streams on site under the same manifest line item.
Corrective Action Due By:01/31/2022
As soon as possible but within 30 days:
1-Ensure that the hazardous waste sludge accumulating at the bottom of the pre-treatment drum is disposed via a hazardous
waste hauler. Submit manifests showing the dispsoal.
2-Conduct a review of the satellite accumulation requirements and submit a statement indicating whether the pretreatment ·
drum will be handled as a satellite container in the future if so, ensure satellite requirements are being met (i.e. labeling).
More on satellite accumulation requirements can be found here:
https:// dtsc.ca .gov/ accu mu la ti ng-h aza rdous-wastes-at-ge nerator-sites/#sate I lite%20a ccu mu lation
VIOLATION # 2
3130003 Failed to properly label/date hazardous waste container or portable tank. 22 CCR 66262.34(f), 66262.34(a)(2),
66262.34(a)(3)
HM-924(01/15)
COUNTY OF SAN DIEGO
SUPPLEMENTAL COMPLIANCE
INSPECTION REPORT
INSPECTION DATE: 11/30/2021 PAGE 4 OF 10
Classification: Minor
Observations:
RECORD ID#: DEH2014-HUPFP-000889
During the inspection I observed the facility HVAC filters and other lead contaminated debris waste are being stored in
cardboard boxes, two carts, and plastic bags behind the 25 yard range backstop area.
--
The containers were not labeled with a hazardous waste label however the wall above the area where the waste is stored was
labeled with a hazardous waste label which is not sufficient and does not meet the regulations requiring the container itself be
labeled.
Corrective Action Due By: -----As soon as possible but within 30 days, ensure that all hazardous waste containers are properly labeled with a hazardous waste
label.
INSPECTION REMARKS:
Facility chooses to manage spent taser darts as medical sharps waste although the Per Jason Kennedy the darts are not
contaminated with blood.
Some program requirements include:
Hazardous Materials Business Plan:
Facilities that handle hazardous materials in quantities of (and above): 55 gallons for liquids, 200 cuft for gases, 500 LBS for
solids
are subject to the hazardous materials business plan program requirements.
-Note that facilities subject to the hazardous materials business plan are required to conduct annual employee training as per
the employee training plan which is part of the hazardous materials business plan.
-Furthermore facilities are required to maintain records for training for 3 years.
-Employee training template can be found here: https://www.sandiegocounty.gov/content/dam/sdc/deh/hmd/pdf/hm-954%
20(01-07}.pdf
-Information in CERS must be annually re-certified if no changes occur or within 30 days of change of information that may
affect emergency response.
-Annual recertification (if no changes) can easily be complted by visiting CERS and clicking on the "Start/Edit Submittal" button
next to your facility info, then clicking on "Create all HMBP submittal elements" button and following the prompts until the
submittal is confirmed. Detailed instructions on how to recertify can be found here: http://www.sandiegocounty.gov/content/
dam/sdc/deh/hmd/hmd_calepa_Annual%20HazMat%201nventory%20Certification.pdf
-Your facility's hazardous materials business plan must be available/accessible on site.
Hazardous Waste Program (LQG):
Facilities that generate any amounts of hazardous waste are subject to the Hazardous Waste Generator Program
-All hazardous waste containers must be closed when not in use, hazardous waste containers of 5 gallon capacity and above
storing hazardous waste must be labeled with a hazardous waste label.
-Hazardous waste disposal manifests must be maintained on site for the past 3 years.
-Large quantity generators of hazardous waste that generate 1000kg or more (or ~275 gallons) of hazardous waste per month
may accumulate waste for a maximum period of 90 days.
-EPA ID number must be active for facilities that generate hazardous waste (annual renewal may be done on line).
-Application for EPA ID number and renewal of EPA ID# can be found here: http://www.dtsc.ca.gov/HazardousWaste/upload/
GISS_FORM_1358.pdf
-For Large Quantity Generators of Hazardous Waste, Hazardous Waste Accumulation areas must be inspected weekly, HW tanks
daily.
-Contingency plan must be posted next to a telephone line.
-LQG of hazardous waste that accumulate hazardous waste in tanks that meet HW tank standards and must certify the tanks via
a CA professional engineer.
-Hazardous waste generator requirements summary guidance document can be found here: https://www.dtsc.ca.gov/
HM-924(01/15)
COUNTY OF SAN DIEGO
SUPPLEMENTAL COMPLIANCE
INSPECTION REPORT
INSPECTION DATE: 11/30/2021 PAGE 5 OF 10
RECORD ID#: DEH2014-HUPFP-000889
HazardousWaste/upload/HWMT""FS_Generator_Requirements.pdf
-LQG's must train staff on Hazardous Waste requirements per 22 CCR 66265.16 and maintain records.
Conditional Authorization Hazardous Waste Treatment Guidance:
https://www.sandiegocounty.gov/content/dam/sdc/deh/hmd/pdf/hm_dtsc_ftu_ca.pdf
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://public.govdelivery.com/accounts/CASAND/subscriber/new
If you have any questions regarding this inspection, please contact Alaaeddine Zahra, (858) 525-5834,
a laaedd ine.za h ra@sdcounty.ca .gov
INSPECTION ATTACHMENTS
Document Name Document Description
1
--
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
I
TITLE OF FACILITY REPRESENTATIVE
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 Materials and Small and Large
Quantity Generators of Hazardous Waste
INSPECTION DATE: 11/30/2021 PAGE 6 OF 10
RECORD ID#: DEH2014-HUPFP-000889
FACILITY NAME: *Carlsbad Safety Training Center (STC)
ADDRESS:* 5750 ORION ST CITY/ZIP: *CARLSBAD 92010 ------------------------
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 yaur 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. 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 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
0 3010030
#
HM-923 (08-21)
HAZARDOUS MATERIALS REQUIREMENTS
VIOLATION DESCRIPTION
Failed to establish and implement a HMBP. HSC 25505(a) and 25507(a)
HMBP not submitted in CERS within the required timeframe. HSC 25508(a)(l); 27 CCR 15188(a),(b),(d)
Business activities &/or Business Owner/Operator page not complete or accurate in CERS. 19 CCR 2652(a)(l); SDCC 68.904(b); HSC 25508(a)(l), 25508(a)
(3)
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 as complete and accurate in CERS by the required due date. HSC 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), 25508(a)(3); 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); 19 CCR 2670,
2671
Failure to submit employee training plan in CERS, when not meeting agricultural handler exemption. HSC 25507.l(a) and 25508(a)(l)
HMBP not established or submitted in CERS, when not meeting the remote site exemption. HSC 25507.2 and 25508(a)(l)
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), 25508(a)(3); 19 CCR 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 DES 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)
HMBP not readily available to facility personnel or the CUPA. HSC 25505(c)
HAZARDOUS WASTE REQUIREMENTS FORSQGS 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)
·Failed to properly dispose of hazardous waste within 180 days (or 270 days if waste is transported over 200 miles). 22 CCR 66262.34(d); HSC 6.5
25123.3(h)(l)
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 during an emergency, spill/release. 22 CCR 66262.34(d)(2); 40 CFR 262.34(d)(5)
(iv)
Failed to submit an Exception Report to DTSC for hazardous waste manifest. HSC 25123.3(h)(2); 22 CCR 66262.42(a), (c-d)
HAZARDOUS WASTE TANK SYSTEMS FOR SQGS ONLY
VIOLATION DESCRIPTION
#
#
#
COUNTY OF SAN DIEGO
COMPLIANCE INSPECTION REPORT
Hazardous Materials and Hazardous Waste (continued)
INSPECTION DATE: 11/30/2021
RECORD ID#: DEH2014-HUPFP-000889
PAGE 7 OF 10
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 3010037
0 3010007
0 3030005
0 3050001
0 3050002
0 HMD0308
0 HMD0305
0 HMD0306
0 3030001
0 3030003
0 3030012
0 3030004
0 3050004
0 HMD0222
0 HMD0216
0 HMD0217
0 HMD0219
Failed to operate uncovered tank to ensure at least 2 ft. of free board 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 a copy of the uniform hazardous waste manifest that originated in paper form to DTSC within 30 days of shipment. 22 CCR 66262.23(a)(4);
HSC 25160(b)(l)(c)
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.lO(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 properly manage a recyclable material. HSC 25143.2, 25143.9
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.lO(d)
Failure to notify the CUPA of aerosol can processing procedures prior to commencement of operations. HSC 25201.160)
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 25189.5(a)
Impermissible dilution of hazardous waste. 22 CCR 66268.3(a)
Disposed of used oil illegally. HSC 25250.S(a), 25189.5(a)
Failed to properly dispose of oil-based paint &/or hazardous waste latex paint liquid. HSC 25217.1, 25189.5(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)
(RCRA LQG) Failed to properly dispose of hazardous waste within 90 days. 22 CCR 66262.34(a), (c); HSC 6.5 25123.3(b)(l)
Failure to properly manage used oil filters and/or fuel filters in accordance with the requirements. HSC 25250.22; 22 CCR 66266.130
Failure to prevent intentional contamination of used oil with other hazardous waste other than minimal amounts of vehicle fuel. HSC 25250.7(a)
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)
HM-923 (08-21)
1
#
#
COUNTY OF SAN DIEGO
COMPLIANCE INSPECTION REPORT
Hazardous Materials and Hazardous Waste (continued)
INSPECTION DATE: 11/30/2021
RECORD ID#: DEH2014-HUPFP-000889
PAGE 8 OF 10
0 3030057
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 3110030
0 3010033
0 3010034
0 3030055
Failed to comply with hazardous waste satellite container regulation. 22 CCR 66262.34{e)
Failed to mark date on empty container larger than 5 gallons &/or properly manage it within one year. 22 CCR 66261.7
Failure of the owner or operator managing laboratory hazardous 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 USE PA 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, 66273.33.6
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 PV modules, electronic devices, and/or CRTs from an offsite source to notify DTSC 30 days prior to acceptance. 22 CCR
66273.32{c), (e)
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), (f)
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)(2),(3)
Failed to notify the CUPA of aerosol processing procedures prior to commencement of operations. HSC 25201.160)
CERTIFIED APPLIANCE RECYCLl:R 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 25212
HM-923 (08-21)
COUNTY OF SAN DIEGO
COMPLIANCE INSPECTION REPORT
Handlers of J!azardous Materials and Small and Large
Quantity Generators o(_Hazardous Waste
INSPECTION DATE: 11/30/2021
RECORD ID#: DEH2014-HUPFP-000889
PAGE 9 OF 10
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 call (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 3110008
0 3110009
0 3110010
0 3110007
0 3010009
#
2 [El 3130003
0 3030012
0 3130004
0 3130005
0 3130006
0 3130007
0 3130008
0 3130009
0 3130010
0 3130013
0 HMD0235
#
0 3110011
0 3110012
0 3120001
0 3130015
0 3130016
0 HMD0418
0 3130018
0 3020002
0 3010023
0 HMD0414
0 3130014
0 HMD0417
#
0 3110013
0 3110014
0 3110015
0 3130011
0 3130012
0 3130019
0 3130020
0 3140001
HM-923 (08-21)
VIOLATION DESCRIPTION
HAZARDOUS WASTE REQUIREMENTS FOR LOGS ONLY
RECORDKEEPING/OPERATIONAL REQUIREMENTS
Failed to prepare every four years a source reduction evaluation review and plan. 22 CCR 67100.4{a), HSC 25244.19(a)
Failed to prepare a summary progress report every four years. 22 CCR 67100.9(a)
Failed to complete a hazwaste management performance report and/or maintain for review. HSC 25244.20{a), 25244.21(a); 22 CCR 67100.3{a)
(RCRA LQG) Failed to complete the Biennial Report by March 1st on even numbered year and maintain a copy for 3 years. 22 CCR 66262.40(b),
66262.41{b)
Failed to submit an Exception Report to DTSC for hazardous waste manifest. HSC 25160(b)(3); 22 CCR 66262.42(b), (c), &/or {d)
STORAGE AND HANDLING
VIOLATION DESCRIPTION
Failed to properly label/date hazardous waste container or portable tank. 22 CCR 66262.34(f), 66262.34(a)(2), 66262.34(a)(3)
{RCRA LQG) Failed to properly dispose of hazardous waste within 90 days. 22 CCR 12 66262.34{a), (c); HSC 6.5 25123.3{b)(1)
Accumulated hazardous waste more than 90 days without a DTSC storage permit. HSC 25123.3(b)(1); 22 CCR 66262.34(a) and (c)
Failed to transfer waste from a container that is in poor condition to another container that is in a good condition. 22 CCR 66265.171
Failed to accumulate hazardous waste in a lined or compatible container. 22 CCR 66265.172
Failed to keep a hazardous waste container or portable tank closed. 22 CCR 66265.173{a)
Failed to inspect hazardous waste storage area(s) at least weekly. 22 CCR 66265.174
Failed to keep reactive and/or ignitable waste at least 50 ft. from the property line. 22 CCR 66265.176
Failed to properly separate incompatible waste. 22 CCR 66265.17(b), 66265.177
Facility failed to maintain and/or operate to minimize the possibility of a fire, explosion, or any unplanned sudden or non-sudden release of hazardous
waste or hazardous waste constituents to air, soil, or surface water which could threaten human health or the environment. 22 CCR 66265.31
Generator did not accumulate hazardous waste in a container or tank. 22 CCR 66262.34(a)(1)(A)
TRAINING. CONTINGENCY PLAN & ER PROCEDURES
VIOLATION DESCRIPTION
Failed to have a written Contingency Plan which is designed to minimize hazards to human health or the environment from fires, explosions, or any
unplanned sudden or non-sudden release of hazardous was.te or hazardous waste constituents to air, soil, or surface water. 22 CCR 66265.Sl(a)
Failed to maintain onsite a copy of the Contingency Plan and all its revisions and submit a copy to the local emergency agencies that may be called upon
to provide emergency services. 22 CCR 66265.53
Failed to maintain training documents and records at the facility. 22 CCR 66265.16(d) & (e)
Failed to test and maintain all communications or alarm systems, fire protection equipment, spill control equipment, and decontamination equipment to
assure its proper operation in time of emergency. 22 CCR 66265.33
Failed to maintain aisle space to allow the unobstructed movement of personnel, fire protection, spill-control equipment, etc. to any area of facility
operation in an emergency. 22 CCR 66265.35
Failed to take precautions to prevent accidental ignition or reaction of ignitable or reactive waste, including the posting of a "No Smoking" sign(s), &
separate and protect from sources of ignition or reaction. 22 CCR 66265.17(a)
Failed to immediately implement the Contingency Plan during an emergency and whenever there is a fire, explosion, or release of hazardous waste or
hazardous waste constituents which could threaten human health or the environment. 22 CCR 66265.Sl{b)
Employee training program not adequate. 22 CCR 66265.16{a) and/or (b)
Contingency plan content is missing information and/or listing of required actions or descriptions. 22 CCR 66265.52
Failed to train employees at least annually. 22 CCR 66265.16(c)
Failed to equip facility with required emergency equipment, water at adequate pressure and volume, internal communication system, &/or spill
response equipment. 22 CCR 66265.32
Failed to have an emergency coordinator on the premises or on call, and available to respond during an emergency and when a release occurs. 22 CCR
66265.55
HAZARDOUS WASTE TANK SYSTEM FOR LOGS ONLY
VIOLATION DESCRIPTION
Failed to obtain and maintain a written assessment certified by an independent, qualified, registered professional engineer for the hazardous waste tank
system. 22 CCR 66265.192{a), 66265.192(h)(1), or 66265.191(a)
Hazardous waste tank system assessment documentation failed to include all required information. 22 CCR 66265.192(k)
Failed to obtain CUPA approval prior to the replacement of equipment for a tank system. 22 CCR 66265.192(1), 66265.192{m)
Failed to maintain tank operating requirements: 1) Spill prevention control; 2) Overfill prevention control, and/or; 3) maintenance of sufficient freeboard
in uncovered tanks. 22 CCR 66265.194{a),{b)
Failed to conduct daily inspections and/or maintain the inspection records for hazardous waste tank system. 22 CCR 66265.195{a){c)
Failed to provide proper secondary containment and/or leak detection for hazardous waste tank system. 22 CCR 66265.193(a) &/or (c)(3)
Failed to inspect and document the cathodic protection system within six months after initial installation, and annually thereafter, and to inspect all
sources of impressed current at least bimonthly. 22 CCR 66265.19S(b)
Failed to properly respond to a tank system spill/leak, follow emergency procedures as required, and/or remove all released waste from the secondary
containment. 22 CCR 66265.56, 66265.196, 66265.194(c)
COUNTY OF SAN DIEGO
COMPLIANCE INSPECTION REPORT
Hazardous Materials and Hazardous Waste (continued)
INSPECTION DATE: 11/30/2021
RECORD ID#: DEH2014-HUPFP-000889
0 3150002
0 HMD1604
0 HMD1607
0 HMD1608
0 HMD1609
0 HMD1611
0 HMD1619
0 HMD1620
0 HMD1621
0 HMD1623
0 HMD1624
0 HMD1625
0 3130026
0 3130022
0 3130025
0 3030062
HM-923 (08-21)
Failed to properly close a hazardous waste tank system ensuring the minimization of further maintenance and requirements are met. 22 CCR 66265.111,
66265.114, 66265.197(a), 67383.3
Failed to maintain secondary containment empty. 22 CCR 66265.196{b) and (c); 66265.194(c)
Failed to adequately design or maintain corrosion protection. 22 CCR 66265.191(b)(3) or 66265.192(a) and (f)
Failed to complete annual integrity assessment for existing hazardous waste tank system without secondary containment. 22 66265.191(a) (e)
Failed to immediately remove unfit hazardous waste tank system from service. 22 CCR 66265.196
Failed to properly complete and/or document closure of a hazardous waste tank system. 22 CCR 67383.3, 66265.197(a), (b)
Failed to have required safety measures for hazardous waste tank system holding ignitable or reactive waste. 22 CCR 66265.198(a)(b)
Failed to immediately remove from service a hazardous waste tank system that leaked or spilled waste. 22 CCR 66265.196(b),(c)
Failed to notify DTSC when a release to environment occurred from a hazardous waste tank system. 22 CCR 66265.196(e)(l)or(3)
Failed to develop and/or implement a written plan and schedule to perform VOC emissions inspections and monitoring of tank or container. 22 CCR
66265.1089(b)
Failed to comply with the 3 year record keeping requirement for tank accumulating VOC waste. 22 CCR 66265.1090(a)
Failed to properly control air pollutant emissions for tank accumulating VOC waste. 22 CCR 66265.202, 66265.1083(b) and 66265.1085(b)
Failed to meet emissions control standards for HW tank system with voe waste. 22 CCR 66265.202 and 66265.1082 (a),(b) &/or (c)
Failed to label stationary hazardous waste tank as hazardous waste and mark with accumulation start date. 22 CCR 66262.34(f)(2) &/or (3)
Failure to comply with VOC emission requirements for containers and/or a portable tank. 22 CCR 66262.34(a)(1); 66265.178
Failed to comply with the emission control standards for equipment (piping, valves, pumps, connectors, etc.) containing 10% or more VOCs. 22 CCR
66262.34(a)(l)(A) & 66265.1050(b)
COUNTY OF SAN DIEGO
CORRECTIVE ACTION FORM TO
DOCUMENT RETURN TO COMPLIANCE
FACILITY NAME: Carlsbad Safety Training Center (STC)
ADDRESS: 5750 ORION ST ---------------------CI TY/ZIP: CARLSBAD /92010 ---------------------
INSPECTION DATE: 11/30/2021
RECORD ID#: DEH2014-HUPFP-000889
SPECIALIST: Alaaeddine Zahra
INSPECTION CONTACT:Jason Kennedy -------=--------TITLE: Facility Manager
PHONE: (760) 602-7584
E-MAIL:jason.kennedy@carlsbadca.gov
DATE -' INDICATE HOW VIOLATIONS WEHE CORRECTED VIOL# DUE DATt CORRECTED ,, (Attach Any Suppor,ting Documentation) .
#1 3030057 01/31/2022
#2 3130003
I certify under penalty of Jaw that this facility has corrected all violations marked on the Compliance Inspection Report/Notice of Violation. I have personally examined and am
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 DATE SIGNED
TITLE OF FACILITY REPRESENTATIVE SIGNATURE
SEND COMPLETED FORM AND SUPPORTING DOCUMENTATION TO THE ADDRESS LISTED BELOW
COUNTY OF SAN DIEGO USE ONLY
REVIEWED BY:
SPECIALIST'S. COM-'MENTS:
DAIi 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 Assistanton: ______ _
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)