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Orange County Health Care Agency Environmental Health - HHW Facility InspectionCosta Mesa Sanitary District ...an Independent Special District August 28, 2013 COPY Lisa Wales, REHS County of Orange, Health Care Agency, Environmental Health 1241 East Dyer Road, Suite 120 Santa Ana, CA 92705 -5611 RE: Response to CUPA Household Hazardous Waste Facility Inspection (Record ID #FA0062793) Dear Ms. Wales, Thank you for bringing the Household Hazardous Waste Facility inspection issues to our attention. In response to your June 19, 2013, inspection report, our contractor, CR &R, Inc. has prepared the attached response. Please contact David Latham of CR &R at (949) 646 -4617 with any questions. Thank you. Sincerely, r Scott Carroll General Manager 628 W. 19th Street / Costa Mesa, CA 92627 -2716 • (949) 645 -8400 / fax (949) 650 -2253 Protecting our community's health and the environment by providing solid waste and sewer collection services Crq e1q environmental services August 22, 2013 Scott Carroll Costa Mesa Sanitary District 628 W 19t' St. Costa Mesa, CA 92627 RE: Response to CUPA Household Hazardous Waste Facility Inspection Dear Mr. Carroll: CR &R, Inc. is providing the attached responses to the compliance items listed in the June 19, 2013 inspection report. CR &R is committed to providing quality household hazardous waste services to Costa Mesa Sanitary District and compliance with regulatory requirements. Thank you for bringing these issues to our attention regarding the household hazardous waste facility operations. Please contact Dean Ruffridge at 949.412.8244 Sincerely, Dean Ruffridge 11292 Western Ave. P. O. Box 125 Stanton. CA 90680 -2912 r: 800.826.9677 r: 714.826.9049 j. 714.890.6347 crrwasteservices.com the fore of a.gfeener general on Orange County Environmental Health Household Hazardous Waste Facility Inspection Report D006 Financial Assurance — Updated closure cost estimates were provided to the Orange County Certified Unified Program Agency (CUPA) on July 26, 2013. CR &R has scheduled the next updated closure cost financial assurance estimate to the CUPA by March 1" D009 Communication ,safety equipment, and emergency response —The first aid kit that was located within one of the locked storage containers and was readily available during operations but it has been located on the outside of the container. A safety shower /eyewash is accessible with 10 seconds as required by California Code of Regulations, Title 8, Section 5162. D013 Spill control equipment —The spill kit has been relocated closer to the operating area D099 Other — Signage with the correct phrasing has been installed. D099 Other, documents —The engineer certification of the storage containment area has been completed and a copy is attached. Copies of the following documents are now available onsite: closure cost financial assurance document, contract with CR &R as contractor, local permits, current inspection logs, Phase I environmental assessment, and the protocol for bulking oil -based paint. D009 Other, Waste Analysis —As noted in the inspection report, operating procedures are to not intentionally accept wastes that cannot be identified and this serves to minimize unidentified wastes found at the facility. Unknowns found in wastes delivered to the facility are kept separate until the proper classification can be determined. Facility staff is receiving refresher training on identification of unknowns and testing equipment is available at the facility. In addition, the hazardous waste contractor removing the wastes from the facility can assist with identification or verification of wastes. D099 Other, signage —Signs prohibiting food, beverages, and smoking have been posted D099 Other, secondary containment — Additional containment has been provided. I/ August 15, 2013 CR &R Incorporated 11292 Western Ave. Stanton, CA 90680 KEN OKAMOTO & ASSOCIATES, INC. STRUCTURAL ENGINEERS Attn: Mr. David Latham Re: Certification of HHW Storage Container at 7571 Lampson Ave., Garden Grove, CA Dear Mr. Latham, At your request, our office has visited the above address to observe and inspect the condition of the Hazardous Waste Containers. The containers are made of steel and self- contained. No rain water or water runoff will accumulate inside the containers since it is fully covered. The containers are free of cracks or gaps to contain leaks and spills, though some minor rust spots are visible. The containers are still serviceable since the rust is minor; and should continue to be monitored. There is no free liquid stored and the containers are elevated above the ground. The containers have a 1 '' /d' high lip on each end to contain any spilled liquid as well as secondary spill pallets with sufficient spill capacity located inside the containers. Based on our observation and to the best of our knowledge, the containers meet the regulatory requirements outlined for Title 22 of the House Hold Hazardous Waste Storage Container Engineer Certification; and meet the Regulatory requirements for sections 67450.25 Requirements applicable to permanent household hazardous waste collection facilities deemed to have a permit by rule and 66264.175 Containment. If you have any questions please feel free to call our office. Sincerely, Ken 0j afnoto, S.E. S2244 AExp. 12-31 -13 KO /ts 3186 -F AIRWAY AVE. . COSTA MESA, CA 92626 • (714) 444 -2422 • FAX (714) 444 -2122 + INSPECTION REPORT DA4226195 County of Orange, Health Care Agency, Environmental Health Page 1 of 3 "• 1241 EAST DYER ROAD, SUITE 120 SANTAANA, CA 92705 -5611 (714) 433 -6000 ochealthinfo.conVeh PR0088432 COSTA MESA SANTITARY DISTRICT Record ID: FA0062793 PHHW COLLECTION FACILITY Inspection Date: 06/1912013 7571 LAMPSON Reinspection Date: 08/1912013 GARDEN GROVE, CA 92841 Type of Facility: 5910 -HHW - PBR Service: A01- ROUTINE INSPER@CEI'VEO Mailing Address: Lisa Wales, REHS COSTA MESA SANTITARY DISTRICT HAZARDOUS WASTE SPECIALIST III ,�y Z 7 2Ai� SCOTT CARROLL (714) 559 -0101 628 W 19TH ST 7:00 -8:00 AM 6nIAlntAsAXI1ARU13IRICI COSTA MESA, CA 92627 LWales @ochca.com THE ITEMS NOTED BELOW WERE OBSERVED DURING COURSE OF THE SITE VISIT. ANY VIOLATIONS OBSERVED MUST BE CORRECTED D006 HHW The PHHWCF is not complying with Financial Assurance requirements (CA Code of Regulations 67450.30) Facility has not submitted and does not maintain on site proof of financial assurance for closure. Financial assurance is due to the CUPA by March 1 st of every year. Submit financial assurance documents to this agency by Friday, July 26, 2013. D009 - HHW Facility is not maintained with appropriate communication, safety equipment and emergency preparedness (CA Code of Regulations 67450.25(a)(2)(B)) The first aid kit was not immediately available within the operational area (first aid kit located within one of the locked cargo storage containers). Relocate the first aid kit so that it is immediately accessible if needed. D013 - HHW Communication or alarm system, portable fire extinguishers, spill control equipment, decontamination equipment & water are not available at facility (CA Code of Regulations 67450.25(a)(2)(B)) The spill kit was not immediately available within the operational area (located approximately 100 feet from the operational area). Relocate the spill kit so that it is immediately accessible if needed. OTHER WARNING SIGNS: Warning signs in English and in languages predominant in the area which state "DANGER! HAZARDOUS WATE AREA- UNAUTHORIZED PERSONNEL KEEP OUT' are not posted outside the receiving, handling and storage areas [CA Code of Regulations 67450.25 (a)(4) and 67450.4 (d)(8)]. Post the required sign. OTHER REQUIRED DOCUMENTATION: Documents required to be on site are missing. Provide and maintain copies of the following documents on site: - Information from the manufacturer or professional engineer indicating that the containment system is suitably designed [CA Code of Regulations 66264.175(c) or 67450.25 (a)(1)(A)] - Current financial assurance for closure documents [CA Code of Regulations 67450.30] -Copy of the contract between the operator and the City of San Clemente [CA Code of Regulations 67450.25(a)(3)(B) and 67450.4(b)(17)] - Copies of local permits [CA Code of Regulations 67450.25 (a)(3)(B) and 67450.4(b)(15) - Current inspection logs [CA Code of Regulations 66265.15 and 66265.195] -Phase I environmental assessment (due to DTSC & CUPA within 1 year of commencing operation) [HSC, section 25200.14; and CA Code of Regulations 66270.60(d)(B)(6) and 67450.25(a)(5)] - Written protocol for bulking oil -based paints [CA Code of Regulations 67450.25(a)(3)(B) and 67450.4(b)(14)] D099 -OTHER TRAINING: Staff conducting waste handling activities were not aware of the protocol for identifying unknown materials as stated in the Operation Plan on site. Resources for conducting testing of unknown materials were not available on site. Provide staff with the training, resources and equipment to perform any required analysis of unknown materials. D099 -OTHER WARNING SIGNS: Signs are posted prohibiting food, beverages, and smoking in the receiving, handling, and storage areas [CA Code of Regulations 67450.25 (a)(4) and 67450.4 (d)(8)]. Post the required sign. D099 -OTHER 7552 (Q.01) 6/2512013 INSPECTION REPORT DA4226195 County of Orange, Health Care Agency, Environmental Health Page 2 of 3 1241 EAST DYER ROAD, SUITE 120 SANTAANA, CA 92705 -5611 (714) 433 -6000 ochealthinfo.com /eh PR0088432 COSTA MESA SANTITARY DISTRICT Record ID: FA0062793 PHHW COLLECTION FACILITY Inspection Date: 06/19/2013 7571 LAMPSON GARDEN GROVE, CA 92841 SECODARY CONTAINMENT: Oil -based paint bulking and storage area is not secondarily contained [CA Code of Regulations 67450.25(a)(1) and 66264.175(b)(3)]. Provide secondary containment for these drums. COMMENTS ZZZ9 - INSPECTOR COMMENTS Onsite this date to conduct a routine inspection of the Household Hazardous Waste (HHW) facility. Inspection was conducted with Ron Drost of CR &R. This facility is not open to the public. Oil -based and latex paints are bulked at this location. PAPERWORK REVIEW: The following documents were not located on site (see violation): - Information from the manufacturer or professional engineer indicating that the containment system is suitably designed -Copy of the contract between the operator and the Costa Mesa Sanitary District - Copies of local permits - Current inspection logs -Phase I environmental assessment (due to DTSC & CUPA within 1 year of commencing operation) - Written protocol for bulking oil -based paints. These documents are required to be on site at the facility location. Provide a copy of these documents to the facility. Facility has not submitted required annual financial assurance documents to this agency (see violation). Financial assurance for closure activities is required to be submitted to this Agency by March 1 st of every year. Submit required documents to this agency by FRIDAY JULY 26, 2013. The following documents were on site: - Operating Plan including a Waste analysis plan - Materials exchange program quality assurance plan - Contingency plan - Closure plan - Copies of manifests with generator and transporter signature - Employee training documents ON SITE INSPECTION All storage containers and modules appeared to be in fair condition; no leaks were observed. The prior location (Orangethorpe) had new, prefabricated, HazMat storage containers. These were not brought to this location. Instead facility uses old cargo containers. This agency would like to see storage containers specifically designed for HazMat storage used at this location [CA Code of Regulations 67450.25(a)(4) and 67450.4(d)(6)]. All hazardous waste containers were stored closed when not in use. All waste containers were labeled with the generator's information, contents, hazardous characteristic, physical state and accumulation start date. There were no drums stored longer than one year. Bulking of oil -based paints is conducted within one of the storage containers for hazardous waste. There is no secondary containment and the area is not bermed to prevent runoff. Provide secondary containment for the oil -based paint drums (see violation). Stored wastes with the exception of the oil -based paints are secondarily contained. Secondary containment structures were dry. Per Ron, latex paint is bulked and the paint container allowed to air dry for approximately 4 hours before being placed in the municipal dumpster for disposal. After completing the bulking process do not allow containers to air dry unless they meet the definition of "empty container' per CA Code of Regulations 66261.7.b. Containers which have a pourable amount of waste in them do not meet the exemption from management as a hazardous waste. Equipment for spills and safety was on site but not within the operation area (see violation). Per Ron, spill kits are located within the building and at the entrance to the property (approximately 100 feet away). Add a spill kit to the operation area, preferably near the oil -based paint bulking process. Employees handling waste are provided tyvek suits, gloves, vests, 7552 (v3.01) 6/25/2013 • INSPECTION REPORT DA4226195 County of Orange, Health Care Agency, Environmental Health Page 3 of 3 1241 EAST DYER ROAD, SUITE 120 SANTA ANA, CA 92705 -5611 (714) 433 -6000 ochealth info. corr✓eh PR0088432 COSTA MESA SANTITARY DISTRICT Record ID: FA0062793 PHHW COLLECTION FACILITY Inspection Date: 06/19/2013 7571 LAMPSON GARDEN GROVE, CA 92841 and safety glasses. Portable fire extinguishers were present and a telephone is provided for communication. There is no air horn or fire alarm present. A first aid kit is available but is stored within a locked waste storage container (see violation). There was no eyewash or shower station available at the processing area however an eyewash station is located within the building near the processing and storage age. This agency has an indirect role in Emergency Equipment. Please provide proof that having the shower /eye wash inside the building meets OSHA requirements. Relocate the first aid kit so that it is not stored near hazardous waste containers and is immediately available if needed. Manifests for wastes were reviewed. Both the generator's initial copy and TSDF copy were present. Per Ron, wastes are picked up from residents, sorted and placed into drums on the truck for transporting back to the facility. Wastes which cannot be identified are returned to the homeowner before the truck moves to the next location. Per the Operations Plan (section C — Waste Characterization) located on site, a procedure for identifying unknowns indicates that tests to determine pH, water reactivity, and oxidizers are available at the site. When asked about these items. Ron could only find a few pH paper strips and was not aware of the procedure (see violation). Ensure the facility has the training, equipment, and resources available to perform any required analysis of unknowns. Provide training to all employees on all aspects of the operation plan including identification of unknown materials. The waste transfer process from the truck to the on site storage drums was not observed at this inspection. An inspection of this process will occur at a later date. Warning signs are not posted at the receiving, handling and storage areas (see violation). These areas, while not open to the public, are accessible to company employees who park next to the operation area. Provide and post all required signs including signs for unauthorized entry and prohibition of food, beverages, and smoking. Ensure the signs are legible from a distance of 25 feet and are written in English and in languages predominant in the area (see violation). The storage area is secured when closed (locked) and patrolled by a guard. Perimeter of facility inspected. No water run -off or staining was observed. Correct the above violations within 60 days with the exception of the Financial Assurance requirement which must be corrected by July 26, 2013. 1 declare that / have examined and received a copy of this inspection report. Print Name and Title Signature Date 7552 (v3.01) 6/25/2013