Chula Vista City Council
October 7, 2025

Government Publication Date: Dec 4, 2023
Hazardous Materials Information Reporting System:
rr-HMIRS-bb
The Hazardous Materials Incident Reporting System (HMIRS) database contains unintentional hazardous materials release information reported to the U.S. Department of Transportation, Pipeline and Hazardous Materials Safety Administration.

Government Publication Date: Nov 26, 2023
National Clandestine Drug Labs: rr-NCDL-bb
The U.S. Department of Justice ("the Department"), Drug Enforcement Administration (DEA), provides this data as a public service. It contains addresses of some locations where law enforcement agencies reported they found chemicals or other items that indicated the presence of either clandestine drug laboratories or dumpsites. In most cases, the source of the entries is not the Department, and the Department has not verified the entry and does not guarantee its accuracy.

Government Publication Date: Jul 26, 2023
Toxic Substances Control Act:
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The Environmental Protection Agency (EPA) is amending the Toxic Substances Control Act (TSCA) section 8(a) Inventory Update Reporting (IUR) rule and changing its name to the Chemical Data Reporting (CDR) rule.

The CDR enables EPA to collect and publish information on the manufacturing, processing, and use of commercial chemical substances and mixtures (referred to hereafter as chemical substances) on the TSCA Chemical Substance Inventory (TSCA Inventory). This includes current information on chemical substance production volumes, manufacturing sites, and how the chemical substances are used. This information helps the Agency determine whether people or the environment are potentially exposed to reported chemical substances. EPA publishes submitted CDR data that is not Confidential Business Information (CBI).

Government Publication Date: Apr 11, 2019
Hist TSCA:
rr-HIST TSCA-bb
The Environmental Protection Agency (EPA) is amending the Toxic Substances Control Act (TSCA) section 8(a) Inventory Update Reporting (IUR) rule and changing its name to the Chemical Data Reporting (CDR) rule.

The 2006 IUR data summary report includes information about chemicals manufactured or imported in quantities of 25,000 pounds or more at a single site during calendar year 2005. In addition to the basic manufacturing information collected in previous reporting cycles, the 2006 cycle is the first time EPA collected information to characterize exposure during manufacturing, processing and use of organic chemicals. The 2006 cycle also is the first time manufacturers of inorganic chemicals were required to report basic manufacturing information.

Government Publication Date: Dec 31, 2006
FTTS Administrative Case Listing:
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An administrative case listing from the Federal Insecticide, Fungicide, & Rodenticide Act (FIFRA) and Toxic Substances Control Act (TSCA), together known as FTTS. This database was obtained from the Environmental Protection Agency's (EPA) National Compliance Database (NCDB). The FTTS and NCDB was shut down in 2006.

PFAS E-MANIFEST

PFAS IND
HMIRS
NCDL
TSCA

HIST TSCA

FTTS ADMIN
417 erisinfo.com | Environmental Risk Information Services Order No: 24031800886 Government Publication Date: Jan 19, 2007
FTTS Inspection Case Listing: rr-FTTS INSP-bb
An inspection case listing from the Federal Insecticide, Fungicide, & Rodenticide Act (FIFRA) and Toxic Substances Control Act (TSCA), together known as FTTS. This database was obtained from the Environmental Protection Agency's (EPA) National Compliance Database (NCDB). The FTTS and NCDB was shut down in 2006.

Government Publication Date: Jan 19, 2007
Potentially Responsible Parties List:
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Early in the site cleanup process, the U.S. Environmental Protection Agency (EPA) conducts a search to find the Potentially Responsible Parties (PRPs). The EPA looks for evidence to determine liability by matching wastes found at the site with parties that may have contributed wastes to the site.

This listing contains PRPs, Noticed Parties, at sites in the EPA's Superfund Enterprise Management System (SEMS).

Government Publication Date: Jan 26, 2024
State Coalition for Remediation of Drycleaners Listing:
rr-SCRD DRYCLEANER-bb
The State Coalition for Remediation of Drycleaners (SCRD) was established in 1998, with support from the U.S. Environmental Protection Agency (EPA) Office of Superfund Remediation and Technology Innovation. Coalition members are states with mandated programs and funding for drycleaner site remediation. Current members are Alabama, Connecticut, Florida, Illinois, Kansas, Minnesota, Missouri, North Carolina, Oregon, South Carolina, Tennessee, Texas, and Wisconsin. Since 2017, the SCRD no longer maintains this data, refer to applicable state source data where available.

Government Publication Date: Nov 08, 2017
Integrated Compliance Information System (ICIS):
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The Integrated Compliance Information System (ICIS) database contains integrated enforcement and compliance information across most of U.S.

Environmental Protection Agency's (EPA) programs. The vision for ICIS is to replace EPA's independent databases that contain enforcement data with a single repository for that information. Currently, ICIS contains all Federal Administrative and Judicial enforcement actions and a subset of the Permit Compliance System (PCS), which supports the National Pollutant Discharge Elimination System (NPDES). This information is maintained by the EPA Headquarters and at the Regional offices. A future release of ICIS will completely replace PCS and will integrate that information with Federal actions already in the system. ICIS also has the capability to track other activities that support compliance and enforcement programs, including incident tracking, compliance assistance, and compliance monitoring.

Government Publication Date: Aug 26, 2023
Drycleaner Facilities:
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A list of drycleaner facilities from Enforcement and Compliance History Online (ECHO) data as made available by the U.S. Environmental Protection Agency (EPA), sourced from the ECHO Exporter file. The EPA tracks facilities that possess NAIC and SIC codes that classify businesses as drycleaner establishments.

Government Publication Date: Jan 20, 2024
Delisted Drycleaner Facilities:
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List of sites removed from the list of Drycleaner Facilities (sites in the EPA's Integrated Compliance Information System (ICIS) with NAIC or SIC codes identifying the business as a drycleaner establishment).

Government Publication Date: Jan 20, 2024
Formerly Used Defense Sites: rr-FUDS-bb
Formerly Used Defense Sites (FUDS) are properties that were formerly owned by, leased to, or otherwise possessed by and under the jurisdiction of the Secretary of Defense prior to October 1986, where the Department of Defense (DOD) is responsible for an environmental restoration. The FUDS Annual Report to Congress (ARC) is published by the U.S. Army Corps of Engineers (USACE). This data is compiled from the USACE's Geospatial FUDS data layers and Homeland Infrastructure Foundation-Level Data (HIFLD) FUDS dataset which applies to the Fiscal Year 2021 FUDS Inventory.

Government Publication Date: May 15, 2023
FUDS Munitions Response Sites:
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Boundaries of Munitions Response Sites (MRS), published with the Formerly Used Defense Sites (FUDS) Annual Report to Congress (ARC) by the U.S.

Army Corps of Engineers (USACE). An MRS is a discrete location within a Munitions response area (MRA) that is known to require a munitions response. An MRA means any area on a defense site that is known or suspected to contain unexploded ordnance (UXO), discarded military munitions (DMM), or munitions constituents (MC). This data is compiled from the USACE's Geospatial MRS data layers and Homeland Infrastructure Foundation- Level Data (HIFLD) MRS dataset.

Government Publication Date: May 15, 2023
Former Military Nike Missile Sites:
rr-FORMER NIKE-bb

FTTS INSP
PRP

SCRD DRYCLEANER
ICIS

FED DRYCLEANERS

DELISTED FED DRY
FUDS

FUDS MRS

FORMER NIKE
418 erisinfo.com | Environmental Risk Information Services Order No: 24031800886 This information was taken from report DRXTH-AS-IA-83A016 (Historical Overview of the Nike Missile System, 12/1984) which was performed by Environmental Science and Engineering, Inc. for the U.S. Army Toxic and Hazardous Materials Agency Assessment Division. The Nike system was deployed between 1954 and the mid-1970's. Among the substances used or stored on Nike sites were liquid missile fuel (JP-4); starter fluids (UDKH, aniline, and furfuryl alcohol); oxidizer (IRFNA); hydrocarbons (motor oil, hydraulic fluid, diesel fuel, gasoline, heating oil); solvents (carbon tetrachloride, trichloroethylene, trichloroethane, stoddard solvent); and battery electrolyte. The quantities of material a disposed of and procedures for disposal are not documented in published reports. Virtually all information concerning the potential for contamination at Nike sites is confined to personnel who were assigned to Nike sites. During deactivation most hardware was shipped to depot-level supply points. There were reportedly instances where excess materials were disposed of on or near the site itself at closure. There was reportedly no routine site decontamination.

Government Publication Date: Dec 2, 1984
PHMSA Pipeline Safety Flagged Incidents:
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This list of flagged pipeline incidents is made available by the U.S. Department of Transportation (US DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA). PHMSA regulations require incident and accident reports for five different pipeline system types. Accidents reported on hazardous liquid gravity lines (§195.13) and reporting-regulated-only hazardous liquid gathering lines (§195.15) and incidents reported on Type R gas gathering (§192.8(c)) are not included in the flagged incident file data.

Government Publication Date: Nov 6, 2023
Material Licensing Tracking System (MLTS): rr-MLTS-bb
A list of sites that store radioactive material subject to the Nuclear Regulatory Commission (NRC) licensing requirements. This list is maintained by the NRC. As of September 2016, the NRC no longer releases location information for sites. Site locations were last received in July 2016.

Government Publication Date: May 11, 2021
Historic Material Licensing Tracking System (MLTS) sites: rr-HIST MLTS-bb A historic list of sites that have inactive licenses and/or removed from the Material Licensing Tracking System (MLTS). In some cases, a site is removed from the MLTS when the state becomes an "Agreement State". An Agreement State is a State that has signed an agreement with the Nuclear Regulatory Commission (NRC) authorizing the State to regulate certain uses of radioactive materials within the State.

Government Publication Date: Jan 31, 2010
Mines Master Index File:
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The Master Index File (MIF) is provided by the United States Department of Labor, Mine Safety and Health Administration (MSHA). This file, which was originally created in the 1970's, contained many Mine-IDs that were invalid. MSHA removes invalid IDs from the MIF upon discovery. MSHA applicable data includes the following: all Coal and Metal/Non-Metal mines under MSHA's jurisdiction since 1/1/1970; mine addresses for all mines in the database except for Abandoned mines prior to 1998 from MSHA's legacy system (addresses may or may not correspond with the physical location of the mine itself); violations that have been assessed penalties as a result of MSHA inspections beginning on 1/1/2000; and violations issued as a result of MSHA inspections conducted beginning on 1/1/2000.

Government Publication Date: May 1, 2023
Surface Mining Control and Reclamation Act Sites:
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An inventory of land and water impacted by past mining (primarily coal mining) is maintained by the Office of Surface Mining Reclamation and Enforcement (OSMRE) to provide information needed to implement the Surface Mining Control and Reclamation Act of 1977 (SMCRA). This inventory contains information on the type and extent of Abandoned Mine Land (AML) impacts, as well as information on the cost associated with the reclamation of those problems. The data is based upon field surveys by State, Tribal, and OSMRE program officials. It is dynamic to the extent that it is modified as new problems are identified and existing problems are reclaimed. Disclaimer: Per the OSMRE, States and tribes who enter their data into eAMLIS (AML Inventory System) may truncate their latitude and longitude so the precise location of usually dangerous AMLs is not revealed in an effort to protect the public from searching for these AMLs, most of which are on private property. If more precise location information is needed, please contact the applicable state/tribe of interest.

Government Publication Date: Jun 13, 2023
Mineral Resource Data System:
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The Mineral Resource Data System (MRDS) is a collection of reports describing metallic and nonmetallic mineral resources throughout the world.

Included are deposit name, location, commodity, deposit description, geologic characteristics, production, reserves, resources, and references. This database contains the records previously provided in the Mineral Resource Data System (MRDS) of USGS and the Mineral Availability System/Mineral Industry Locator System (MAS/MILS) originated in the U.S. Bureau of Mines, which is now part of USGS. The USGS has ceased systematic updates of the MRDS database with their focus more recently on deposits of critical minerals while providing a well-documented baseline of historical mine locations from USGS topographic maps.

Government Publication Date: Mar 15, 2016
DOE Legacy Management Sites:
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PIPELINE INCIDENT
MLTS

HIST MLTS
MINES
SMCRA
MRDS

LM SITES
419 erisinfo.com | Environmental Risk Information Services Order No: 24031800886 The U.S. Department of Energy (DOE) Office of Legacy Management (LM) currently manages radioactive and chemical waste, environmental contamination, and hazardous material at over 100 sites across the U.S. The LM manages sites with diverse regulatory drivers (statutes or programs that direct cleanup and management requirements at DOE sites) or as part of internal DOE or congressionally-recognized programs, such as but not limited to: Formerly Utilized Sites Remedial Action Program (FUSRAP), Uranium Mill Tailings Radiation Control Act (UMTRCA Title I, Tile II), Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), Resource Conservation and Recovery Act (RCRA), Decontamination and Decommissioning (D&D), Nuclear Waste Policy Act (NWPA). This site listing includes data exported from the DOE Office of LM' s Geospatial Environmental Mapping System (GEMS). GEMS Data disclaimer: The DOE Office of LM makes no representation or warranty, expressed or implied, regarding the use, accuracy, availability, or completeness of the data presented herein.

Government Publication Date: Dec 12, 2023
Alternative Fueling Stations:
rr-ALT FUELS-bb
This list of alternative fueling stations is sourced from the Alternative Fuels Data Center (AFDC). The U.S. Department of Energy's Office of Energy Efficiency & Renewable Energy launched the AFDC in 1991 as a repository for alternative fuel vehicle performance data, which provides a wealth of information and data on alternative and renewable fuels, advanced vehicles, fuel-saving strategies, and emerging transportation technologies. The data includes Biodiesel (B20 and above), Compressed Natural Gas (CNG), Electric, Ethanol (E85), Hydrogen, Liquefied Natural Gas (LNG), Propane (LPG), and Renewable Diesel (R20 and above) fuel type locations.

Government Publication Date: Aug 30, 2023
Superfunds Consent Decrees:
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This list of Superfund consent decrees is provided by the Department of Justice, Environment & Natural Resources Division (ENRD) through a Freedom of Information Act (FOIA) applicable file. This listing includes Consent Decrees for CERCLA or Superfund Sites filed and/or as proposed within the ENRD's Case Management System (CMS) since 2010. CMS may not reflect the latest developments in a case nor can the agency guarantee the accuracy of the data. ENRD Disclaimer: Congress excluded three discrete categories of law enforcement and national security records from the requirements of the FOIA; response is limited to those records that are subject to the requirements of the FOIA; however, this should not be taken as an indication that excluded records do, or do not, exist.

Government Publication Date: Apr 19, 2023
Air Facility System:
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This EPA retired Air Facility System (AFS) dataset contains emissions, compliance, and enforcement data on stationary sources of air pollution.

Regulated sources cover a wide spectrum; from large industrial facilities to relatively small operations such as dry cleaners. AFS does not contain data on facilities that are solely asbestos demolition and/or renovation contractors, or landfills. ECHO Clean Air Act data from AFS are frozen and reflect data as of October 17, 2014; the EPA retired this system for Clean Air Act stationary sources and transitioned to ICIS-Air.

Government Publication Date: Oct 17, 2014
Registered Pesticide Establishments:
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This national list of active EPA-registered foreign and domestic pesticide and/or device-producing establishments is based on data from the Section Seven Tracking System (SSTS). The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) Section 7 requires that each producing establishment must place its EPA establishment number on the label or immediate container of each pesticide, active ingredient or device produced. An EPA establishment number on a pesticide product label identifies the EPA registered location where the product was produced. The list of establishments is made available by the U.S. Environmental Protection Agency (EPA).

Government Publication Date: Mar 1, 2023
Polychlorinated Biphenyl (PCB) Transformers:
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Locations of Transformers Containing Polychlorinated Biphenyls (PCBs) registered with the United States Environmental Protection Agency. PCB transformer owners must register their transformer(s) with EPA. Although not required, PCB transformer owners who have removed and properly disposed of a registered PCB transformer may notify EPA to have their PCB transformer de-registered. Data made available by EPA.

Government Publication Date: Oct 15, 2019
Polychlorinated Biphenyl (PCB) Notifiers:
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Facilities included in the national list of facilities that have notified the United States Environmental Protection Agency (EPA) of Polychlorinated Biphenyl (PCB) activities. Any company or person storing, transporting or disposing of PCBs or conducting PCB research and development must notify the EPA and receive an identification number.

Government Publication Date: Oct 30, 2023
State

PFAS Sampling Locations: rr-PFAS SAMPLING-bb

ALT FUELS

CONSENT DECREES
AFS
SSTS
PCBT
PCB

PFAS SAMPLING
420 erisinfo.com | Environmental Risk Information Services Order No: 24031800886 This data is sourced from the State Water Board's GeoTracker Per- and Polyfluoroalkyl Substances (PFAS) Map tool which contains individual sampling points (i.e., soil boring, groundwater monitoring well, drinking water well for municipal drinking water systems, etc.) or a site location with PFAS analytical data. Includes analytical results that are finalized and submitted electronically by the Responsible Parties via GeoTracker's Electronic Submittal of Information Portal, and after it's accepted by a Regional Water Quality Control Board.

Government Publication Date: Sep 25, 2023
Dry Cleaning Facilities:
rr-DRYCLEANERS-bb
A list of drycleaner related facilities that have EPA ID numbers. These are facilities with certain SIC codes: power laundries, family and commercial, linen supply, commercial laundry, dry cleaning and pressing machines - Coin Operated Laundry and Dry Cleaning. This is provided by the Department of Toxic Substance Control.

Government Publication Date: Dec 20, 2021
Delisted Drycleaners:
rr-DELISTED DRYCLEANERS-bb
Sites removed from the list of drycleaner related facilities that have EPA ID numbers, made available by the California Department of Toxic Substance Control.

Government Publication Date: Jan 31, 2022
Non-Toxic Dry Cleaning Incentive Program: rr-DRYC GRANT-bb A list of grant recipients of the Non-Toxic Dry Cleaning Incentive Program made available by the California Air Resources Board (CARB). The program provides grants to eligible dry cleaning businesses to assist them in transitioning away from PERC machines to alternative non-toxic and non-smog forming technologies.

Government Publication Date: Jan 31, 2022
PFAS GeoTracker Cleanup Sites:
rr-PFAS GT CLEANUPS-bb
A list of applicable cleanup sites from the State Water Resources Control Board's (SWRCB) GeoTracker data management system where one or more of the potential contaminants of concern are identified in the PFAS Master List of PFAS Substances made available by the Environmental Protection Agency (US EPA).

Government Publication Date: Nov 30, 2023
PFOA/PFOS Groundwater:
rr-PFAS GW-bb
A list of water wells from the Groundwater Ambient Monitoring and Assessment Program (GAMA) Groundwater Information System with the groundwater chemical perfluorooctanoic acid (PFOA) (NL = 0.014 UG/L) or perfluorooctanoic sulfonate (PFOS) (NL = 0.013 UG/L). The GAMA Groundwater Information System search is made available by California Water Boards.

Government Publication Date: Jan 7, 2024
PFAS Investigations:
rr-PFAS INVEST-bb
This list of potential Per- and Polyfluoroalkyl Substance (PFAS) sites is compiled from the California State Water Resources Control Board's (SWRCB) PFAS Investigations Map tool. The SWRCB issued investigative orders, per California Water Code (CWC) Section 13267 and/or 13383, to these sites.

This does not mean that PFAS has been produced, used, or discharged at these sites. Orders were also issued to the public water systems to sample wells in the vicinity of these locations. The data includes locations for airports, landfills, suspected chrome plating facilities, publicly owned treatment works (aka wastewater treatment plants), bulk fuel terminals, refineries, and military facilities that have potential sources of PFAS.

Government Publication Date: Nov 28, 2022
Hazardous Waste and Substances Site List - Site Cleanup:
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The Hazardous Waste and Substances Sites (Cortese) List is a planning document used by the State, local agencies and developers to comply with the California Environmental Quality Act requirements in providing information about the location of hazardous materials release sites. This list is published by California Department of Toxic Substance Control.

Government Publication Date: Mar 15, 2023
Toxic Pit Cleanup Act Sites:
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The Toxic Pits Cleanup Act (TPCA) list identifies sites suspected of containing hazardous substances where cleanup has not yet been completed. This list was maintained by the State Water Resources Control Board (SWRCB), is not longer maintained, and updates are not planned.

Government Publication Date: Jul 1, 1995
List of Hazardous Waste Facilities Subject to Corrective Action: rr-DTSC HWF-bb This is a list of hazardous waste facilities identified in Health and Safety Code (HSC) § 25187.5. These facilities are those where Department of Toxic Substances Control (DTSC) has taken or contracted for corrective action because a facility owner/operator has failed to comply with a date for taking corrective action in an order issued under HSC § 25187, or because DTSC determined that immediate corrective action was necessary to abate an imminent or substantial endangerment.

DRYCLEANERS

DELISTED DRYCLEANERS

DRYC GRANT

PFAS GT CLEANUPS

PFAS GW

PFAS INVEST

HWSS CLEANUP

TOXIC PITS

DTSC HWF
421 erisinfo.com | Environmental Risk Information Services Order No: 24031800886 Government Publication Date: Jul 18, 2016
EnviroStor Inspection, Compliance, and Enforcement: rr-INSP COMP ENF-bb A list of permitted facilities with inspections and enforcements tracked by the California Department of Toxic Substance Control's (DTSC) EnviroStor data management system.

Government Publication Date: Nov 23, 2023
School Property Evaluation Program Sites: rr-SCH-bb
A list of sites registered with The Department of Toxic Substances Control (DTSC) School Property Evaluation and Cleanup (SPEC) Division. SPEC is responsible for assessing, investigating and cleaning up proposed school sites. The Division ensures that selected properties are free of contamination or, if the properties were previously contaminated, that they have been cleaned up to a level that protects the students and staff who will occupy the new school.

Government Publication Date: Feb 15, 2024
California Hazardous Material Incident Report System (CHMIRS):
rr-CHMIRS-bb
A list of reported hazardous material incidents, spills, and releases from the California Hazardous Material Incident Report System (CHMIRS). This list has been made available by the California Office of Emergency Services (OES).

Government Publication Date: Oct 16, 2023
Historical California Hazardous Material Incident Report System (CHMIRS): rr-HIST CHMIRS-bb A list of reported hazardous material incidents, spills, and releases from the California Hazardous Material Incident Report System (CHMIRS) prior to 1993. This list has been made available by the California Office of Emergency Services (OES).

Government Publication Date: Jan 1, 1993
Handlers from Hazardous Waste Manifest Data: rr-HAZNET-bb A list of handlers not otherwise classified as Treatment, Storage, Disposal facilities (TSDF) or generators from the facilities and manifests data made available by the California Department of Toxic Substances Control (DTSC) in their Hazardous Waste Tracking System (HWTS).

Government Publication Date: Oct 24, 2016
Generators from Hazardous Waste Manifest Data: rr-HAZ GEN-bb List of handlers listed as having generated waste from the facilities and manifests data made available by the California Department of Toxic Substances Control (DTSC) in their Hazardous Waste Tracking System (HWTS).

Government Publication Date: Dec 31, 2017
TSDF from Hazardous Waste Manifest Data: rr-HAZ TSD-bb
List of Treatment, Storage, and Disposal Facilities (TSDFs) from the facilities and manifests data made available by the California Department of Toxic Substances Control (DTSC) in their Hazardous Waste Tracking System (HWTS).

Government Publication Date: Dec 31, 2017
Historical Hazardous Waste Manifest Data: rr-HIST MANIFEST-bb A list of historic hazardous waste manifests received by the Department of Toxic Substances Control (DTSC) from year the 1980 to 1992. The volume of manifests is typically 900,000 - 1,000,000 annually, representing approximately 450,000 - 500,000 shipments.

Government Publication Date: Dec 31, 1992
DTSC Registered Hazardous Waste Transporters: rr-HW TRANSPORT-bb The California Department of Toxic Substances Control (DTSC) maintains this list of Registered Hazardous Waste Transporters.

Government Publication Date: Jan 2, 2024
Registered Waste Tire Haulers: rr-WASTE TIRE-bb
This list of registered waste tire haulers is maintained by the California Department of Resources Recycling and Recovery.

Government Publication Date: Dec 5, 2023
California Medical Waste Management Program Facility List: rr-MEDICAL WASTE-bb This list of Medical Waste Management Program Facilities is maintained by the California Department of Public Health. The Medical Waste Management Program (MWMP) regulates the generation, handling, storage, treatment, and disposal of medical waste by providing oversight for the implementation of the Medical Waste Management Act (MWMA). The MWMP permits and inspects all medical waste off-site treatment facilities, medical waste transporters, and medical waste transfer stations. This list contains transporters, treatment, and transfer facilities.

INSP COMP ENF
SCH
CHMIRS

HIST CHMIRS
HAZNET

HAZ GEN

HAZ TSD

HIST MANIFEST

HW TRANSPORT

WASTE TIRE

MEDICAL WASTE
422 erisinfo.com | Environmental Risk Information Services Order No: 24031800886 Government Publication Date: Jan 8, 2024
Historical Cortese List: rr-HIST CORTESE-bb
List of sites which were once included on the Cortese list. The Hazardous Waste and Substances Sites (Cortese) List is a planning document used by the State, local agencies and developers to comply with the California Environmental Quality Act requirements for providing information about the location of hazardous sites.

Government Publication Date: Nov 13, 2008
Cease and Desist Orders and Cleanup and Abatement Orders:
rr-CDO/CAO-bb
The California Environment Protection Agency "Cortese List" of active Cease and Desist Orders (CDO) and Cleanup and Abatement Orders (CAO). This list contains many CDOs and CAOs that do NOT concern the discharge of wastes that are hazardous materials. Many of the listed orders concern, as examples, discharges of domestic sewage, food processing wastes, or sediment that do not contain hazardous materials, but the Water Boards' database does not distinguish between these types of orders.

Government Publication Date: Dec 6, 2021
California Environmental Reporting System (CERS) Hazardous Waste Sites:
rr-CERS HAZ-bb
List of sites in the California Environmental Protection Agency (CalEPA) Regulated Site Portal which fall under the following regulatory programs:

Hazardous Chemical Management, Hazardous Waste Onsite Treatment, Household Hazardous Waste Collection, Hazardous Waste Generator, RCRA LQ HW Generator. The CalEPA oversees the statewide implementation of the Unified Program which applies regulatory standards to protect Californians from hazardous waste and materials.

Government Publication Date: Jan 17, 2024
Delisted Environmental Reporting System (CERS) Hazardous Waste Sites:
rr-DELISTED HAZ-bb
This database contains a list of sites that were removed from the California Environmental Protection Agency (CalEPA) in the following regulatory programs: Hazardous Chemical Management, Hazardous Waste Onsite Treatment, Household Hazardous Waste Collection, Hazardous Waste Generator, RCRA LQ HW Generator.

Government Publication Date: Nov 29, 2018
Sites in GeoTracker:
rr-GEOTRACKER-bb
GeoTracker is the State Water Resource Control Boards' data management system for sites that impact, or have the potential to impact, water quality in California, with emphasis on groundwater. This is a list of sites in GeoTracker that aren't otherwise categorized as LUST, Land Disposal Sites (LDS), Cleanup Sites, or sites having Waste Discharge Requirements (WDR). This listing includes program types such as Underground Injection Control (UIC), Confined Animal Facilities (CAF), Irrigated Lands Regulatory Program, plans, and non-case information.

Government Publication Date: Nov 30, 2023
Mines Listing:
rr-MINE-bb
This list includes mine site locations extracted from the Mines Online database, maintained by the California Department of Conservation. Mines Online (MOL) is an interactive web map designed with GIS features that provide information such as the mine name, mine status, commodity sold, location, and other mine specific data. Please note: Mine location information is provided to assist experts in determining the location of mine operators in accordance with California Civil Code section 1103.4 and reflects information reported by mine operators in annual reports provided under Public Resources Code section 2207. While the Division of Mine Reclamation (DMR) attempts to populate MOL with accurate location information, the DMR cannot guarantee the accuracy of operator reported location information.

Government Publication Date: Jun 16, 2023
Recorded Environmental Cleanup Liens:
rr-LIEN-bb
The California Department of Toxic Substance Control (DTSC) maintains this list of liens placed upon real properties. A lien is utilized by the DTSC to obtain reimbursement from responsible parties for costs associated with the remediation of contaminated properties.

Government Publication Date: Dec 18, 2023
Waste Discharge Requirements: rr-WASTE DISCHG-bb
List of sites in California State Water Resources Control Board (SWRCB) Waste Discharge Requirements (WDRs) Program in California, made available by the SWRCB via GeoTracker. The WDR program regulates point discharges that are exempt pursuant to Subsection 20090 of Title 27 and not subject to the Federal Water Pollution Control Act. The scope of the WDRs Program also includes the discharge of wastes classified as inert, pursuant to section 20230 of Title 27.

Government Publication Date: Nov 30, 2023
Toxic Pollutant Emissions Facilities:
rr-EMISSIONS-bb

HIST CORTESE

CDO/CAO

CERS HAZ

DELISTED HAZ

GEOTRACKER
MINE
LIEN

WASTE DISCHG

EMISSIONS
423 erisinfo.com | Environmental Risk Information Services Order No: 24031800886 A list of criteria and toxic pollutant emissions data for facilities in California made available by the California Environmental Protection Agency - Air Resources Board (ARB). Risk data may be based on previous inventory submittals. The toxics data are submitted to the ARB by the local air districts as requirement of the Air Toxics "Hot Spots" Program. This program requires emission inventory updates every four years.

Government Publication Date: Dec 31, 2020
Clandestine Drug Lab Sites:
rr-CDL-bb
The Department of Toxic Substances Control (DTSC) maintains a listing of drug lab sites. DTSC is responsible for removal and disposal of hazardous substances discovered by law enforcement officials while investigating illegal/clandestine drug laboratories.

Government Publication Date: Jan 19, 2021
Tribal
No Tribal additional environmental record sources available for this State.

County
CDL
424 erisinfo.com | Environmental Risk Information Services Order No: 24031800886 h-Definitions
Database Descriptions: This section provides a detailed explanation for each database including: source, information available, time coverage, and acronyms used. They are listed in alphabetic order.

Detail Report: This is the section of the report which provides the most detail for each individual record. Records are summarized by location, starting with the project property followed by records in closest proximity.

Distance:

The distance value is the distance between plotted points, not necessarily the distance between the sites' boundaries. All values are an approximation.

Direction: The direction value is the compass direction of the site in respect to the project property and/or center point of the report.

Elevation: The elevation value is taken from the location at which the records for the site address have been plotted. All values are an approximation.

Source: Google Elevation API.

Executive Summary: This portion of the report is divided into 3 sections:
'Report Summary'- Displays a chart indicating how many records fall on the project property and, within the report search radii. 'Site Report Summary'-Project Property'- This section lists all the records which fall on the project property. For more details, see the 'Detail Report' section.
'Site Report Summary-Surrounding Properties'- This section summarizes all records on adjacent properties, listing them in order of proximity from the project property. For more details, see the 'Detail Report' section.

Map
Key: The map key number is assigned according to closest proximity from the project property. Map Key numbers always start at #1. The project property will always have a map key of '1' if records are available. If there is a number in brackets beside the main number, this will indicate the number of records on that specific property. If there is no number in brackets, there is only one record for that property.

The symbol and colour used indicates 'elevation': the red inverted triangle will dictate 'ERIS Sites with Lower Elevation', the yellow triangle will dictate 'ERIS Sites with Higher Elevation' and the orange square will dictate 'ERIS Sites with Same Elevation.' Unplottables:

These are records that could not be mapped due to various reasons, including limited geographic information. These records may or may not be in your study area, and are included as reference.

Definitions

APPENDIX C

REGULATORY AGENCY RECORDS

Requestor Name: Date:

Telephone: ( ) Fax: ( )
Company/Organization Name:

Mailing Address:

Email Address:

County of San Diego

DEPARTMENT OF ENVIRONMENTAL HEALTH AND QUALITY

HAZARDOUS MATERIALS DIVISION
P.O. BOX 129261 SAN DIEGO, CA 92112-9261
PHONE: (858) 505-6880 | www.sdcdehq.org

PUBLIC RECORDS REQUEST FOR THE HAZARDOUS MATERIALS DIVSION

A separate form must be completed for each address or parcel number. Email your completed form to [email protected].

OR
Exact Address (Street, City and Zip Code) Assessor Parcel Number

Records requested from: to All Records
Date Date

Please indicate the purpose of your search by checking all that apply:

Hazardous Materials (HMD) Permits Underground Storage Tank (UST) Files Other (explain below):

Please be advised that records are returned electronically via email unless otherwise requested by checking the box. Photocopy and/or scanned file fees may apply. Photocopies requested

OFFICE USE ONLY BELOW THIS LINE
A search for records requested above has been conducted by DEHQ and the following apply:

HMD files for the permit number(s) listed below are available. # # # # #
UST files for the permit number(s) listed below are available. # # # # #
Other files for the permit number(s) listed below are available. # # # # #
No records were found for the address/APN requested.

Files copied/scanned for: of Date:
# of pages copied/scanned: Cost $ email mail pickup Date Completed:

Signature of DEHQ Representative Date DEHQ-9098 (Rev. 02/23)
Dan Weis
3/18/24
760-672-6338
Date: 3/18/2024
Weis Environmental, LLC
1938 Kellogg Avenue, Suite 116
Carlsbad, CA 92008
[email protected]
3497 Main Street, Chula Vista, CA 91911
3/18/24
3/18/24
HUPFP-214305
HUPFP-206738
HUPFP-139211
3/18/24
·-
Olountu of
GARY W. ERBECK

DIRECTOR
March 26, 2001
Mr. Gary Veerkamp

DEPARTMENT OF ENVIRONMENTAL HEALTH

HAZARDOUS MATERIALS DIVISION
P.O. BOX 129261, SAN DIEGO, CA 92112·9281.
(619) 338-2222 FAX (819) 338-2377
1-800-253-9933

PG&E DISPERSE GENERATION FACILITY
California Center
345 California Street, suite 2600
San Francisco, CA 94104
Dear Mr. Veerkamp:

RICHARD HAAS

ASSISTANT DIRECTOR
SUBJECT: RISK MANAGEMENT PLAN (RMP)- PUBLIC DOCUMENT FOR 19%-AQUEOUS AMMONIA - H01955
The San Diego County Hazardous Materials Division (HMO) has completed an initial review of the RMP Public Document for the facility located at 1968 Don Lee Place, Escondido, CA 92029.

Pursuant to section 2745.2(a)(3) of Title 19 in the California Code of Regulations the following items require clarification correction, or revision: . . · · . : . ' ' ;. . ' · · • § 2745.3 RMP Executive Summary Component:: ·.
. ' '. :· .: :-.:;..::. _·:-
Point of Clarification: Within Section 1.4, ·reference is made to the use of "polyballs" as a • · . . . method of passive mitigation. Expand on this method of mitigation to include the product name and the basis for a reduction of the surface area of the· ammonia liquid by 80%. · As noted at the conclusion of section 1.7, the completion of the RMP Technical Document is an essential part of the Risk Management Program. Completion of this document prior to the initial ammonia delivery is required. Maintain a copy of the RMP Technical Document at the facility. §2745.4 RMP Offsite Consequence Analysis Component. ·'.

Point of Correction: On page 4-3, Table 4-1, indicate the "Release Quantity" in units of pounds (not gallons) for the worst-case and alternative case scenarios.

Point of Clarification: On page 4-4, Section 4.2, in the worst-case scenario section, significant reduction in the surface area of a spill is said to be accomplished' by the use of "floating polyballs". To obtain a better understanding of the use of polyballs as a mitigation method and to assess their efficacy in this situation, provide the following inform_ationJegarding the. . .. ,: .. polyballs: manufacture, composition, chemical and exposure compatibilities, availability, and a complete description of the product that will be used at the Escondid() Peak Power Generating Plant. In addition, provide documentation demonstrating under what ·conditions of use (size, . number and number of layers) the stated 80% reduction in liquid surface'area is accomplished: · ;'•' !'. r,
... : .. ·. J: : · ·
1 '"1
· "Environmental and public health through leadership, !!.;·•,; ; •·. ; • I
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• - 2- March 27, 2001
• §2745.4 RMP Offsite Consequence Analysis Component (continued) Within the RMP, define "polyballs" and explain how a surface area reduction of 80% is accomplished.

Point of Clarification: On page 4-6 Section 4.3, in the Alternative-case Release Scenarios section, a spill of 54.2 gallons is described when a transfer hose decouples during a loading operation. It is also stated that the duration of the spill (30 seconds) was determined by when the valve was shut off. Provide within the RMP the location of the shut off valve and the standard operating procedures associated with its operation. In addition, with the decoupling of a transfer hose from a delivery truck to the ammonia tank, descr[be what controls are in place to prohibit the remaining ammonia within the delivery truck and/or the contents of the ammonia tank from discharging to the ground.

Point of Correction: On page 4-7 Section 4.3, in the Alternative-case Release Scenario section, the distance to end-point is presented as the distance to end point for the worst-case scenario.

Change this sentence to read, "alternative case scenario".

Point of Correction: On page 4-10, Table 1, the "assumed spill surface polyball coverage" is stated as 80%. This is inconsistent with other statements within the RMP that indicate the polyball coverage will be 100%. Correct the references to polyball coverage within the RMP to indicate the required coverage that would yield and 80% reduction in the surface area of an ammonia spill within the brimmed area.
§2740.1 Registration
In addition to the corrections noted above, submit the registration data pursuant to California Code of Regulation, Title 19, Section 2740.1(d)(1-12).
. -··:. - . -
Within 60 days (4-4-01), re-submit the corrected, revised RMP, to this office for review. If you have any questions I can be reached at (619) 338-2453. Thank you for your cooperation. n Kolb, REHS, Environmental Health Specialist II
Hazardous Materials Division
cc: Zachary Jacobs, Jacobs Consulting
Matthew Trainor, Supervising Environmental Health Specialist Ed Slater, Supervising Environmental Health Specialist
Mr. Lamont Landis, Fire Prevention Specialist
File: H39211

CERTIFIED MAIURRR
'
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FACILITY ID#

BUSINESS

BUSINESS
CITY
CITY
PAGER#

SAN DIEGO COUNTY
DEPARTMENT OF ENVIRONMENTAL HEALTH -.CUPA
HAZARDOUS MATERIALS DIVISION ·
P.O. BOX 129261, SAN DIEGO, CA 92112-9261
(619) 338-2222 FAX (619) 338-2377
1-800-253-9933

BUSINESS OWNER/OPERATOR IDENTIFICATION

ENDING DATE

ALWAYS SUBMIT A COPY OF THIS COMPLETED PAGE WITH SUBMITTAL OF ANY OTHER UNIFIED PROGRAM CONSOLIDATED FORM.
110
112
113
116
122
128
130
law that I have personally examined and
ATIYE 135
136
DEH:HM-UPCF-BUSINESS OWNER/OPERATOR IDENTIFICATION (10/00) OES FORM 2730 (1/99) GARY W. ERBECK

DIRECTOR
November 27,2000
Mr. Joe Zerucha
•
Qiountu of

DEPARTMENT OF ENVIRONMENTAL HEALTH

HAZARDOUS MATERIALS DIVISION
P.O. BOX 129261, SAN DIEGO, CA 92112-9261
(619) 338-2222 FAX (619) 338-2377
1-800-253-9933

PG&E DISPERSE GENERATION FACILITY
California Center
345 California Street, suite 2600
San Francisco, CA 94104
Dear Mr. Zerucha:

RICHARD HAAS

ASSISTANT DIRECTOR
SUBJECT: RISK MANAGEMENT PLAN (RMP)- PUBLIC DOCUMENT FOR AQUEOUS AMMONIA- 839211
The San Diego County Hazardous Materials Division (HMD) has completed an initial review of the RMP Public Document for the facility located at 3497 Main Street, Chula Vista, CA 91911. Pursuant to section 2745.2(a)(3) ofTitle 19 in the California Code of Regulations the following items need to be corrected, revised, or clarified:
§2745.3 RMP Executive Summary Component
Observation - Distance to endpoints are stated.

Recommendation - Proposed regulations prohibit the public from photocopying offsite consequence analysis information. Distance to endpoint information should not be included in the Executive Summary.
§2745.4 RMP Offsite Consequence Analysis Component
Observation- Poly balls and secondary containment account for a significant factor of passive mitigation. Adequate information describing how the poly balls will be stored, inspected and maintained is not provided.

Recommendation - Specifically describe how the poly balls will be stored (lying in the bottom of the secondary containment, held in baskets, etc ... ) lfpolyballs are lying directly on the ground of the secondary containment describe how maintenance personnel will have access to the area without damaging the balls. If the balls are to be stored in baskets the mitigation effect provided by the polyballs will be reduced during the initial release period, requiring changes in the "Environmental and public health through leadership, partnership and science" Mr. Joe Zerucha
•
-2-
•
November 27, 2000.
worst case scenario. Specifically describe:
+ How the poly balls will be inspected and maintained for damage that may be incurred due to sun exposure and/or rain.
+ How will rainwater be prevented from entering, or removed from the secondary containment area. If rainwater is allowed to accumulate in the secondary containment, how often will the water be removed? Be advised any opening in the secondary containment (holes for piping, drainage, etc ... ) must be adequately sealed/secured to prevent leaks.

Observation- Footnote b. of table 4-1 and the first paragraph on page 4-4, indicate 80% poly ball coverage of the surface area of a spill.

Recommendation- Change wording to indicate 100% poly-ball coverage, which provides 80% reduction in liquid surface area.

Observation- Page 4-4 indicates the modeling protocol was approved by HMO. However some of the modeling presented was not approved. Specifically, the scaling of the distance to end point based on the ratio of the Aftox emission rate as compared to the EPA emission rate was not part of original modeling protocol. No supporting documentation is submitted for the assumption that the emission rate is proportional to the concentration at a given distance. As presented, the air modeling methodology is difficult to understand and follow.

Recommendation- As agreed upon at the meeting of November 17, 2000, an evaporation rate shall be calculated for both the worse case and alternative case scenario using EPA's Guidance on the application of Refined Dispersion Models for Hazardousffoxic Air Releases (May 1993).

The distance to toxic end point will be calculated by AFTOX. The AFTOX distance to end point will then be multiplied by the ratio of the AFTOXIEPA evaporation rate which will yield the final distance to toxic end point of200 ppm. Submit the modeling methodology as described. Provide language that supports easy understanding for the reader. Show the specific calculation used in Appendix A.

Recommendation- Based on the corrective actions and recommendations above, revisions to the scenarios may show impacts to public, environmental and sensitive receptors. Revisions to the appropriate sections should be made.
§2745.5 RMP Five-year Accident History Component
Observation- Typo error, page 5-l, paragraph indicates HMMD, this is incorrect.

Recommendation- Should be HMO.

Observation- Page 5-2 indicates the phone# for HMO is 338-5555, this is incorrect.

Recommendation- The correct phone number, 619-338-2222.

I . , • '·
\ . ..
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Mr. Joe Zerucha
•
-3- .vember 27, 2000
§2745.6 RMP Program 2 Prevention Program Component
Observation- Page 6-1 indicates that aqueous ammonia is the only "regulated chemical" in use.

Recommendation- Change wording to indicated aqueous ammonia is the only "regulated substance" as defined by Sec 2745.3.

Observation- On page 6-2 it is noted that the detection and monitoring controls listed in table

6.2 have the ability to activate audio and/or visual alarms.

Recommendation- All ammonia alarms should have visual recognition considering that noise created during nonnal operating could "drown" out audio alarm signals.

Observation- Table 6.3, recommendation 15, indicates that ammonia pumps will be shut down if High High alarms occur on 2 of 4 sniffers citing concerns over false readings. Recommendation 16 indicates shut down of the ammonia system if there is a time excursion over the 75ppm limit. HMD recognizes the integrated safeguards and the remote monitoring capabilities of system operation.

However considering the unmanned nature of the facility immediate response from PG&E personnel should be made to verify any alarm (high or low) for ammonia detectors. · Recommendation Provide guidelines/procedures for PG&E personnel response to any ammonia detection alarm. Guidelines must include response time and the time requirements for PG&E personnel to arrive on site.
"• .
2745.8 RMP Emergency Response Program Component
Recommendation- Be advised local fire fighters, the hazardous materials incidence response teams, local and emergency planning committees (local offsite first responders) primary responsibility is to protecting public health. Facility owners and operators have the primary responsibility to spill response and mitigation. References to coordinated emergency response should not imply that local offsite first responders will be responsable for spill response. Facility owners and operators should have emergency response and cleanup equipment and personnel available to respond. Considering the unmanned nature of the facility, response planning and training with local first responders is appropriate. If specialized equipment, supplies and training are identified a result of tabletop exercises facility owners and operators are responsible for providing these items. The emergency response plan should be amended to reflect the needs identified during tabletop exercises. Initial tabletop exercises should be conducted with local first responders prior to start up. Contact Mr. Mike Handman at 619-338-2216 to initiate training with the local emergency responders.

Pursuant to section 9.1 and 9.2, submit a copy of the Hazardous Materials Business Plan and the emergency response SOP's for this facility.

Observation- HMD guidelines require two copies of the public document be submitted. To date only one copy has been submitted.

Recommendation- After revisions have been made submit two copies of the complete public document.

Mr. Joe Zerucha
•
-4-
•
November 27, 2000
NOTE: A physical site walk down and inspection of the facility must be conducted after completion of construction, and prior to aqueous ammonia being brought on site above threshold planning quantities. Based on this site inspection and the fmal construction, revisions to the RMP may be required. At a minimum the following items should be addressed:
+ Exact number and location of ammonia sensors.
+ Initial training of topics indicated in section 6.4 Employee and Contractor Training Requirements.
+ Administrative SOP's listed on pages 3-2, 3-3, 6-5, 6-6. + Recommendations listed on pages 6-4 and 6-5.
+ Forms to be used for incident follow-up.

Within 60 days (02/23/01), submit the above corrections to this office for review. If you have any questions I can be reached at (619) 338-2453. Thank you for your cooperation. olb, REHS, Environmental Health Specialist II
dous Materials Division
cc: Zachary Jacobs, Engineering Consultant, And Jacobs Consulting Michael Dorsey, Chief, HMD
Matthew Trainor, Supervising Environmental Health Specialist Michael Vizzier, Supervising Environmental Health Specialist (acting) File: H392ll

CERTIFIED MAILIRRR
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*
Jacobs Consulting
Zachary Jacobs
5006 Mission Blvd.

Diego, CA 92109
•
- 5- November 28, 2000
• • • •
• • • • •
PG&E
Energy Group.

January 22, 2001
Mr. John Kolb, REHS
Environmental Health Specialist II
Hawrdous Materials Division
JAN 26 12 59 PM '01
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HE.A.' .,1. c'''"'"t-s • · · r - • 1IJ
San Diego County Department of Environmental Health
P.O. Box 129261
San Diego, CA 92112-9261
Subject: RMP Public Document (County Reference #H39211) Dear Mr. Kolb:

California Center
345 California Street
Suite 2600
San Francisco, CA 94104
415.288.5600
Fax: 415.288.5770
7500 Old Georgetown Road
Suite 1300
Bethasda, MO 20814-8161
301.280.6800
Fax: 310.280.6900
This letter is in response to your initial review of the RMP Public Document for our peak power plant facility, which will be located at 3497 Main Street, Chula Vista, CA 91911. In the following sections, I explain how we have corrected, revised, or clarified issues that you brought out in your initial review letter dated 11/27/00.
2745.3 RMP Executive Summary Component
- Distance to endpoint infonnation will not be included in the Executive Summary pages. 2745.4 RMP Offsite Consequence Analysis Component
- Polyball storage, maintenance, and inspections are detailed in Section 3.2 of the revised RMP Public Document. Polyballs will be stored lying on the surface of the secondary containment area. When maintenance is performed in the secondary containment area, workers will clear a walkway and work area free of polyballs. Polyballs will not be removed from the containment area, they will simply be pushed back and "dammed" with 2"X6" boards. This will ensure that the balls are not damaged during maintenance.
- Polyballs will be inspected regularly. If polyballs are deteriorating or damaged for any reason, they will be replaced. The polyballs will be put on a replacement program as recommended by the manufacturer.
- Rainwater will fall in the area where polyballs are stored. The rainwater will drain to a valve that will remain closed during normal operation. This valve will be opened by the PG&E DG Area Manager after rain has occurred. It is estimated that there will be no more than one-half inch (W') of rainwater in the area prior to the valve being opened. The capacity of the secondary containment will exceed 110% of the tank volume plus rainfall from a 100 year, 24-hour storm. - Secondary containment areas will be designed and constructed adequately and sealed to prevent leaks.
- Wording in the footnote below Table 4-1 and the fll'st paragraph on page 4-4 have been changed to reflect your recommendation.
- Worst case and alternate scenario modeling was performed as agreed upon at our November 17, 2000 meeting. Section 4.0 was faxed to you by James Westbrooke. This section of the report was deemed to be acceptable.

PG&E National Energy Group and any other company referenced herein which uses the PG&E name or logo are not the same company as Pacific Gas and Electric Company, the California utility. These companies are not regulaterl by the California Public Utilities Commission, and customers do not have ID buy products from these companies in . . . ... ' . . . . ·'"- •
••
• •
••
January 22, 2001

2745.5 Five Year Accident History Component
- We have corrected typographical enors and updated the correct HMD phone number. 2745.6 RMP Program 2 Prevention Program Component
- We have made the correction on page 6-1 to "regulated substance." - All ammonia alarms will have visual recognition as opposed to audio alarms. - PG&E DG personnel will respond to all alarms (false or otherwise). The San Diego PG&E DG Area Manager will respond as follows:

One Alarm - After the system parameters are checked out by the Remote Operator and it is determined to be a false alarm, it is estimated that a PG&E DG Area Manager representative will respond to the false alarm within 4 hours. The Area Manager will take maintenance measures to determine how the alarm was triggered and how to get the sensor back on-line.

Two Alarms -The ammonia system will be shut down immediately by the Remote Operator. This will minimize or eliminate further discharge of ammonia (assuming it is not a double false alarm).

System parameters (tank level, pressure release, etc.) will be monitored remotely and a PG&E DG representative will be dispatched to the site immediately.

If alarms persist after system is shut down, local emergency clean-up contractors will be dispatched immediately. Also, local Fire Depatbnent and the County HAZMAT Team will be notified of the spill. Local responders will serve to protect the public and the clean-up contractor will be primarily responsible for release mitigation and spill clean up.
2745.8 RMP Emergency Response Program Component
- PG&E 00 realizes that they have primary responsibility for spill response and mitigation. PG&E 00 will contract with a local company to be on call for spill response 24 hours, 7 days a week. This contractor will be trained in spill response practices for aqueous ammonia and will be familiar with the facility. If special spill clean-up and mitigation equipment is required, it will be located on site or contained in the contracted emergency response vehicle. - Due to the unmanned nature of this facility, PG&E DG also realizes that facility emergency response planning and training with the local ftrst responders is appropriate. PG&E DG will perform tabletop exercises with the local emergency responders and their contracted emergency responder. The facility emergency response plan will be amended and improved as a result of tabletop exercises. PG&E DG will meet with Mr. Mike Handman to initiate training with the local emergency responders. - Section 9.0 of the Public RMP will serve as the foundation for emergency response at this facility.

However, specific detailed emergency response procedures will be developed and contained in the RMP Technical Document. The "Hazardous Materials Business Plan" will be one of the plans in the RMP Technical Document that will identify names and phone number of all responsible PG&E-DG responders and altemates.

Other Issues:
- Two copies of the RMP Public Document will be submitted to the HMD after the revisions have been made.
- PG&E also realizes the following:

A physical site walk down and inspection of the facility must be conducted after completion of construction and prior to aqueous ammonia being brought on site above threshold planning quantities. Based on this site inspection and a final construction, revisions to the RMP may be required. At a minimum, the following items will be addressed and contained in the RMP Technical Document:
' • •
.. _. ...

January 22, 2001

• Exact number and location of ammonia sensors.
• Initial training oftopics indicated in section 6-4 Employee and Contractor Training Requirements. • Administrative SOP's listed on pages 3-2, 3-3, 6-5, 6-6. • Recommendations listed on pages 6-4 and 6-5.
• Forms to be used for incident follow-up.

Please review the revised Public RMP and contact me with any remaining questions. I can be reached at 415-288-5678.

Sincerely,
PG&E Dispersed Generating Company, LLC
Gary Veerka
Manager
Design and Installation
cc: Zachary Jacobs, Jacobs Consulting
Dale Mesple
..
.. PG&E National
Energy

VIA OVERNIGHT MAIL
June 21, 2002
Mr. Brad Long
County of San Diego
Department of Environmental Health
Hazardous Materials Division
PO Box 129261, MSD561
San Diego, CA 92112-9261
D. E. H.

M!< ILfl OOi-1
Subject: Response to Compliance Inspection Report
PG&E Dispersed Generating Company, LLC
Chula Vista Power Plant (facility no. 139211)
Dear Mr. Long:

California Center
345 California Street
Suite 2600
San Francisco, CA 94104
415.288.5600
Fax: 415.288.5770
7500 Old Georgetown Road
Suite 1300
Bethesda, MD 20814-6161
301.280.6800
Fax: 310.280.6900
This letter is in response to the Compliance Inspection Report issued to PG&E Dispersed Generating Company, LLC (PG&E DG) on May 22, 2002, following your inspection of the Chula Vista Power Plant. Below is our response to Violation 6HV1 096 and the items listed as Observation/Violation in the report.

Observation- Records for training outlined in the Hazardous Materials Business Plan are unavailable.

Violation 6HV1096 - Personnel training records not available to show that personnel have received complete initial and annual refresher training. CCR 2732(B) Corrective Action- Keep documentation of employee training on hazardous materials handling & emergency procedures - include employee's signature. Keep documentation onsite for 3 years.

RESPONSE:

The required initial operator training was conducted through a combination of on-line courses, review of site procedures, on-site on-the-job training, and a practical evaluation of competency.

The Hazardous Materials Business Plan, Section III details four training areas, in general they are: hazardous materials handling (specifically ammonia loading/unloading procedures), a review of emergency response and coordination, use of emergency response equipment, and emergency response plan implementation. Prior to the inspection, the current operators were trained on these four areas. PG&E DG and the Operations Manager required that training was completed prior to authorization for the employee to operate process equipment unsupervised.

PG&E National Energy Group and any other company referenced herein which uses the PG&E name or logo are no/ the same company as Pacific Gas and Electric Company, the California utility. These companies are not regulated by the California Public Utilities Commission, and customers do not have to buy products from these companies in order to continue to receive quality regulated services from the umity.

B. Long
County of San Diego DEH H.tviD
June 21, 2002

The remainder of the training established by the RMP Technical Document has been completed since the inspection, with the exception that review of emergency response procedures to be performed in conjunction with the local Fire Department and the chemical clean-up contractor.

This specific requirement is maintained by our chemical clean-up contractor, Advanced Cleanup Technologies, Incorporated. Advanced Cleanup Technologies, Incorporated is well established in San Diego County and has an on-going relationship of coordination with the county's many local fire departments.

Documentation for the on-line courses, site procedures and on-site training is maintained electronically and hard copies may be printed as necessary. The review of site procedures and the on-site training conducted prior to the inspection were not documented through certifications signed by the employees, but training was recorded in the operators daily logs and through task tracking documentation held by the Operations Manager. Training prior to the inspection and subsequent training have now been documented through certifications signed by the employee(s). Future training will be similarly documented and maintained on-site, accessible for review.

With regard to annual refresher training, no current employee has been stationed at the facility for longer than 12 months, therefore annual refresher training has not occurred. Annual refresher training will occur near the anniversary of the initial training received, or within a timeframe of 12 months.

Observation/Violation- The owner or operator did not resolve all issue[s] during the hazard review, before dates indicated (startup).

Corrective Action -With-in 30 days resolve all issues, or revise recommendations identified during the hazard analysis. Maintain documentation of action taken onsite for review.

RESPONSE:

Table 6.3 of the RMP Public Document presented 25 recommendations as a result of the hazard review. Of the 25 recommendations 15 were addressed prior to the inspection on May 22, 2002.

Four of the remaining recommendations (Nos. 4, 5, 12, and 19) have been addressed by revisions or additions to procedures and SOPs, and 4 recommendations have been determined to be unnessessary or inappropriate for the site "as-built" (Nos. 6, 13, 18, and 21).

The remaining 2 recommendations are related to operating procedures for preventive maintenance (No. 3) and developing inspection, maintenance, and operating procedures (No. 22). These procedures are being developed and are approximately 75 percent complete. It is expected that these procedures will be completed by August 1, 2002. PG&E DG is intent on standardizing relevant operating procedures, where applicable, across all six of our peak power generating facilities throughout the country. This intent on standardization is at the root of our delay in finalizing the remaining procedures.
•
B. Long
County of San Diego DEH HlviD
June 21, 2002

Observation/Violation- The owner operator did not insure that each employee presently operating a process, or each employee newly assigned has been trained or tested competent in the operating procedures, that pertain to their duties. 2755.4(A) Corrective Action -With-in 30 days conduct and document training or testing on the operating procedures for employees. Newly assigned employees should be trained prior to assuming duties pertaining to the operating procedures. Maintain documentation on­ site available for review.

RESPONSE:

The operators received training prior to the inspection (dating back October 2001, January­ February 2002, etc.) on the operating procedures pertaining to their duties, both through previous job experience and extensive on-the-job training by qualified PG&E National Energy Group personnel. The required initial operator training was conducted through a combination of on-line courses, review of site procedures, on-site on-the-job training, and a practical evaluation of competency. However, documentation was not readily accessible during the inspection. The records documenting the successful completion of operator process equipment training are maintained as task tracking documentation held by the PG&E DG Operations Manager and are kept electronically. Training prior to the inspection and subsequent training have now been documented through certifications signed by the employee(s). Future training will be similarly documented and maintained on-site, accessible for review.

Observation/Violation -The owner or operator did not perform inspections and tests on process equipment, consistent with applicable manufacturer recommendations, industry standards or codes, good engineering practices, or prior operating experience. 2755.5 (D). A recent calibration check of the ammonia sensors found several sensors not in working order. During the inspection Mr Gregory indicated repairs are being conducted and a program for ongoing equipment maintenance is being developed. Currently inspections are conducted only during operating periods.

Corrective Action - Continue to develop and implement an equipment maintenance program. The HMD recommends physical inspections be conducted weekly. Maintain records onsite for review.

RESPONSE:

In general, procedures for equipment inspection, testing, and maintenance are near completion.

It is expected that the procedures for the ammonia system will be complete by August 1. 2002.

PG&E DG is intent on standardizing relevant operating procedures, where applicable, across all six of our peak power generating facilities throughout the country. This intent on standardization is at the root of our delay in finalizing the remaining procedures. The operator(s) at the facility routinely assess the functionality of the ammonia sensors prior to an operational day, in that, the absence of a "false positive" is indicative of a properly functioning sensor. The manufacturer estimates useful life of the sensor at 12 months. The failed sensors at the Chula Vista Power Plant were placed into service May 2001, and therefore have reached their B. Long
County of San Diego DEH Hi'viD
June 21,2002
Page4
expected useful life. PG&E DG took prudent corrective action upon identifying the malfunctioning sensors. Once a sensor transmitted a "false positive," the operator attempted to re-calibrate the sensor. The sensors would not re-calibrate and therefore are being replaced.

This is consistent with the manufacturer's recommendations. In the future, operators will annotate the daily "walk-down" list indicating a functioning ammonia sensor.

Observation/Violation - Emergency response plan training for all employees in relevant procedures and relevant aspects of the emergency response program are unavailable. 2765.2(A)(3)
Corrective Action - With in 30 days, conduct and document training for employees on the emergency response program. Maintain documentation of training on site for review.

RESPONSE:

Employee training on the emergency response plan was completed prior to the inspection.

Certification records, signed by the employee, are maintained on-site. Future training will be similarly documented and maintained on-site, accessible for review.

If you have any questions regarding these responses, please call me at (303) 215-1488.

Sincerely,
PG&E Dispersed Generating Company, LLC
Plant Manager
• • COUNTY OF SAN DIEGO

1.;.·_-···· COMPLIANCE ••..•••.••••.•.•
BUSINESS NAME PG&E DISPERSED GENERATING LLC.

ADDRESS: 3497 MAIN STREET
CITY/ZTP CHULA VISTA 91911 PHONE TITLE
C-----r . Page/of .
' DATE 5-22-02
EST NO 139211

SPECIALIST LONG
BUS. CODE K52
BSART
On the above date an inspection of your business/facility was conducted in order to determine compliance with the California Health and Safety Code (H&S) Chapters 6.5, 6. 7, 6.95; Titles 19, 22 and 23 of the California Code of · Regulations (CCR); and the San Diego County Code (SDCC). The following remarks are intended to provide guidance . · to correct the violations noted on the attached violation report. -ROUTINE INSPECTION CONDUCTED ON 5-21-2002, CONSENT FOR THE INSPECTION GIVEN BY BILL JOLLY £. ZW2J ,
INSPECTION OF JU;QUIREMENTS UNDER:

HAZARDOUS MATERIALS (HSC 6.95)
HAZARDOUS WASTE GENERATOR (HSC 6.5)
CALIFORNIA ACCIDENTAL RELEASE PROGRAM (CAL-ARP), (HSC 6.95)

INFORMATION VERIFIED DURING THE INSPECTION
-HAZARDOUS MATERIALS INVENTORY
-HAZARDOUS WASTE STREAMS GENERATED
-EMERGENCY CONTACT PERSONNEL
SPILL PREVENTION CONTROL AND COUNTERMEASURE <SPCC) PLAN -A SPILL PREVENTION CONTROL AND COUNTERMEASURE (SPCC) HAS BEEN PREPARED FOR THIS FACILITY. THE SPCC WAS CERTIFIED BY A PROFESSIONAL ENGINEER (CAL-15674), ON 10- 01-2000

HANDOUTS PROVIDED DURING THIS INSPECTION
-GENERAL HAZARDOUS WASTE REQlliREMENTS (GHWR)
-CHEMICAL INVENTORY REPORTING PAGE
-HAZARDOUS MATERIALS BUSINESS PLAN (HMBP) CERTIFICATION STATEMENT

OPERATION, AND REGULATION OF HAZARDOUS WASTE TANKS FOR
GUIDANCE. --<>-"'
'-"--
--- ...... '::_:: ---:::--..... _ ...... ... ,:__ .... "''·· HAZARDOUS WASTE TANK MANAGEMENT STANDARDS, 22 CCR 66265.190 ET AL.

BE ADVISED-lfENDING RESULTS OF THEW ASTE DETERMINATION OF TURBINE WASH WATER­ ANY TANK SYSTEMS (T ANKS:SUMPS, PUMPS, ANCILLARY EQUIPMENT) THAT STORES, HANDLES, TREATS HAZARDOUS W ASTifwiLL.:_BE SUBJECT TO HAZARDOUS WASTE TANK MANAGEMENI: STANDARDS:JSEE HANDOUT·b)NSTRJ!CTION, OPERATION, AND REGULATION

OF HAZARDOUS WASTE TANKS FOR
.

HAZARDOUS MATERIALS BUSINESS PLAN . · .
-AN UPDATED HAZARDOUS MATERIALS BUSINESS PLAN WAS SUBMITTED FOR REVIEW

DURING THE INSPECTION
zy;/u(o -z:..

Signature of Business Representative Date Signed
Dfu-.4--rt.,J v­
Title
• • COUNTY OF SAN DIEGO
I i ; .. ··•••··••··.•·····•··•· • il
BUSINESS NAME PG&E DISPERSED GENERATING LLC.

ADDRESS: 3497 MAIN STREET
CITY/ZIP CHULA VISTA. 91911 PHONE TITLE
PageZ-mr'
DATE 5-22-02
EST. NO 139211

SPECIALIST LONG
BUS. CODE K52

TIMET ART END
CONTACT:ED. GREGORY

OBSERVATION- RECORDS FOR TRAINING OUTLINED IN THE HAZARDOUS MATERIALS BUSINESS PLAN ARE UNAVAILABLE.

VIOLATION 6HV1096 PERSONNEL TRAINING RECORDS NOT AVAILABLE TO SHOW THAT PERSONNEL HAVE RECEIVED COMPLETE INITIAL AND ANNUAL REFRESHER TRAINING. CCR 2732(8) .

CORRECTIVE ACTION- KEEP DOCUMENTATION OF EMPLOYEE TRAINING ON HAZARDOUS MATERIALS HANDLING & EMERGENCY PROCEDURES-INCLUDE EMPLOYEE'S SIGNATURE.

KEEP DOCUMENTATION ONSITE FOR 3 YEARS.

REMARK -FOR CONTINUED COMPLIANCE ANNUALLY CERTIFY THE HAZARDOUS MATERIALS BUSINESS PLAN. SUBMIT COMPLETED HAZARDOUS MATERIALS BUSINESS PLAN CERTIFICATION STATEMENT TO THIS OFFICE. UPDATES TO CHEMICAL INVENTORY SHOULD BE SUBMITTED ON FORM ''HAZARDOUS MATERIALS INVENTORY-CHEMICAL DESCRIPTION".

CALIFORNIA ACCIDENTAL RELEASE PROGRAM <CAL-ARP)
SECTION 2735.6 CAL-ARP PRQGRAM MANAGEMENT SYSTEM. 2735.6 REMARK- THE OWNER OR OPERATOR SUBJECT TO PROGRAM 2 OR 3 MUST DEVELOP A

MANAGEMENT SYSTEM TO OVERSEE THE IMPLEMENTATION OF THE RISK MANAGEMENT PROGRAM ELEMENTS, [2735.6(A)]. THE HMD RECOMMENDS THAT THE PERSON RESPONSIBLE FOR IMPLEMENTATION OF THE RMP ALSO BE THE PERSON THAT CERTIFIES THE RMP.

SECTION 2755.2 HAZARD REVIEW. PGRM 2,

OBSERVA TIONNIOLA TION- THE OWNER OR OPERATOR DID NOT RESOLVE ALL ISSUED DURING

THE HAZARD REVIEW, BEFORE DATES INDICATED (START-UP)
CORRECTIVE ACTION- WITH -IN 30 DAYS RESOLVE ALL ISSUES, OR REVISE RECOMMENDATIONS IDENTIFIED DURING THE HAZARD ANALYSIS. MAINTAIN DOCUMENTATION OF ACTION TAKEN ON7 SITE FOR REVIEW.

SECTION 2755.4 TRAINING. PGRM 2..._2755.4

OBSERVA TIONNIOLA TION- THE OWNER OPERATOR DID NOT INSURE THAT EACH EMPLOYEE

PRESENTLY OPERATING A PROCESS, OR EACH EMPLOYEE NEWLY ASSIGNED HAS BEEN TRAINED OR TESTED COMPETENT IN THE OPERATING PROCEDURES, THAT PERTAIN TO THEIR DUTIES. 2755.4(A)
CORRECTIVE ACTION- WITH-IN 30 DAYS CONDUCT AND DOCUMENT TRAINING OR TESTING ON THE OPERATING PROCEDURES FOR EMPLOYEES. NEWLY ASSIGNED EMPLOYEES SHOULD BE TRAINED PRIOR TO ASSUMING DUTIES PERTAINING TO THE OPERATING PROCEDURES. MAINTAIN DOCUMENTATION ON-SITE AVAILABLE FOR REVIEW.

Signature of Business Representative Date Signed
Dfe.rt:t:-1 M4,..,...r
Title
COUNTY.OF SAN DIEGO.

I<> .... .·}?1
BUSINESS NAME PG&E DISPERSED GENERATING LLC.

ADDRESS: 3497 MAIN STREET
CITY/ZIP CHULA VISTA. 91911 PHONE TITLE
SECTION 2755.5 MAINTENANCE. PGRM 2
Page }of-f
DATE 5-22-02
EST. NO 139211

SPECIALIST LONG
BUS. CODE K52

TIMET ART END
CONTACT:ED. GREGORY

REMARK- BE ADVISED THE OWNER OR OPERATOR MUST TRAIN EMPLOYEES INVOLVED IN MAINTAINING THE ON-GOING MECHANICAL INTEGRITY OF THE PROCESS. , 2755.5(8). RECOMMEND QUALIFICATIONS OF CONTRACT EMPLOYEES BE VERIFIED.

OBSERVATIONNIOLATION- THE OWNER OR OPERATOR DID NOT PERFORM INSPECTIONS

AND TESTS ON PROCESS EQUIPMENT, CONSISTENT WITH APPLICABLE MANUFACTURER

RECOMMENDATIONS, INDUSTRY STANDARDS OR CODES, GOOD ENGINEERING PRACTICES, OR PRIOR OPERATING EXPERIENCE. 2755.5(D). A RECENT CALIBRATION CHECK OF THE AMMONIA SENSORS FOUND SEVERAL SENSORS NOT IN WORKING ORDER. DURING THE INSPECTION MR.

GREGORY INDICATED REPAIRS ARE BEING CONDUCTED AND A PROGRAM FOR ONGOING EQUIPMENT MAINTENANCE IS BEING DEVELOPED. CURRENTLY INSPECTIONS ARE CONDUCTED ONLY DURING OPERATING PERIODS.

CORRECTIVE ACTION- CONTINUE TO DEVELOP AND IMPLEMENT AN EQUIPMENT MAINTENANCE PROGRAM. THE HMD RECOMMENDS PHYSICAL INSPECTIONS BE CONDUCTED WEEKLY. MAINTAIN RECORDS ONSITE FOR REVIEW.

ARTICLE 7. EMERGENCY RESPONSE PROGRAM. ARTICLE 7

OBSERVA TIONNIOLA TION- EMERGENCY RESPONSE PLAN TRAINING FOR ALL EMPLOYEES IN

RELEVANT PROCEDURES AND RELEVANT ASPECTS OF THE EMERGENCY RESPONSE PROGRAM ARE UNAVAILABLE. 2765.2(A)(3)
CORRECTIVE ACTION- WITH IN 30 DAYS, CONDUCT AND DOCUMENT TRAINING FOR EMPLOYEES ON THE EMERGENCY RESPONSE PROGRAM. MAINT A1N DOCUMENTATION OF TRAINING ON SITE FOR REVIEW.

BE ADVISED-EMERGENCY RESPONSE PLAN SHOULD BE PERIODICALLY REVIEWED AND UPDATED, AS APPROPRIATE. REFLECT CHANGES AT THE STATIONARY SOURCE AND ENSURE THAT EMPLOYEES ARE INFORMED OF CHANGES. 2765.2(A)(4)

BE ADVISED-THE EMERGENCY RESPONSE PLAN MUST INCLUDE PROCEDURES FOR THE USE OF EMERGENCY RESPONSE EQUIPMENT AND FOR ITS INSPECTION, TESTING, AND MAINTENANCE. 2765.2(A)(2). DOCUMENTATION OF INSPECTION, TESTING, AND MAINTENANCE SHOULD BE MAINTAINED ON SITE FOR REVIEW.

REMARK- THE HMD RECOMMENDS FOR GREATER COORDINATION WITH LOCAL EMERGENCY RESPONSE AGENCIES, ABOUT: ACCIDENTAL RELEASES, EMERGENCY PLANNING, AND EMERGENCY

RESPONSE THAT LOCAL FIRE DEPARTMENTS, AND THE HAZARDOUS MATERIALS INCIDENT RESPONSE TEAM (HIRT) BE NOTIFIED AND INVITED TO ATTEND FORMAL TRAINING EXERCISES. 2765 .2(A)(l )(A)
Signature of Business Representative
CJ?Iz-z-/o z.

Date Signed
ON 1\1
TitJe
COUNT,OF SAN DIEGO.
!·•••··•·· ? . •• •••·········· ff.l
BUSINESS NAME PG&E DISPERSED GENERATING LLC.

ADDRESS: 3497 MAIN STREET
CITY/ZIP CHULA VISTA. 91911 PHONE TITLE
Page J( of '{'""'
DATE 5-22-02
EST NO 139211

SPECIALIST LONG
BUS. CODE K52

TIMETART END
CONTACT:ED. GREGORY
CORRECTIVE ACTION- WITH IN 30 DAYS, SUBMIT TO MY ATIENTION, A LETIER

DESCRIBING THE CORRECTIVE ACTION TAKEN TO ADDRESS THE ABOVE SITED VIOLATIONS.

QUESTIONS AND/OR CORRESPONDENCE REGARDING THIS REPORT SHOULD BE DIRECTED TO BRAD L

DEPARTMENT OF ENVIRONMENTAL HEALTH
HAZARDOUS MATERIALS DIViSION
PO BOX 129261 MSD561
SAN DIEGO, CA 92112-9261
(619) 338-2453 FAX (619)338-2139
[email protected]
Signature of Business Representative Date Signed

COUN- OF SAN DIEGO
#
________________ __
VIOUTION REPORT: The items checked below refer to specific section numbers of rt/es 19 & 22 of the California Code o Regulations (CCR), Chapters 6.5, 6.95 of the Health and Safety Code (HSC), and/or the Sm Diego County Code (SDCC).

All violations must be corrected. Submit documentation of return to compliance to your Specialist. You may use the Corrective Action Form to document your return to compliance. Your Specialist can provide these forms. Please call (619) 338-2222 or your Specialist if you have any questions.

HAZARDOUS WASTE REQUIREMENTS

RECORD KEEPING

VIOL VIOLATION DESCRIPTION
D V0131 UFP Pennit not obtained SDCC. 68.905
D ·V0132 No EPA Identification Number. 66262.12
D V0133 Manifest copy not sent to DTSC. 66262.23
D V0134 Exception Rpt. not filed with DTSC. 66262.42
D VOIJS Waste Manifests/Receipts not on-site for 3
years. 66262.40
D V0136 No records of battery disposal. 66262.81
D V0137 Manifest not properly completed. 66262.23
D V0138 TSDF signed-manifest not on-site. 66262.40
D V0139 Biennial report not sent to DTSC. 66262.41
D V0140 LDR Documentation not available. 66268.7
D V0141 Operating TSDF without authorization. 2520 I
D V0142 Failed to notifY local CUPA of onsite treatment of hazardous waste. 2520 I
D V0143 Tiered Pennitting notification has incomplete or incorrect infonnation. 25201
D V0144 SB14 compliance doc. not available. 25244.19
D V0145 Excluded recyclable materials report not
submitted to HMD. 25143.10

STORAGE AND HANDLING
0 V0201 Waste container not kept closed. 66265.173
0 V0202 Waste container missing/improperly labeled.
66262.34,25143.9
0 V0203 Damaged container not repackaged. 66265.171
0 V0204 Waste container not properly managed. 66265.173 0 VOl OS Waste container in poor condition. 66265.171
0 V0206 Ignitable Waste< 50 feet of property line.
66265.176
0 V0207 Ignitable Waste not grounded. 66265.31
0 V0208 Storage area not inspected weekly. 66265. 17 4
0 V0209 Waste stored> 90, 180, or 270 days. 66262.34
0 V0210 Hazwaste not cleaned up off floor surface.
66262.10b
0 VOl II Incompatibles in the same container. 66265.177 0 V0212 Incompatibles not stored separately. 66265.177
0 V0213 Container incompatible with waste. 66265.172
0 V0214 Waste oil contaminated. 25250.7
0 VOltS Used oil filters improperly managed. 66266.130
0 V0216 Hazardous materials not properly labeled. 25124

DISPOSAL AND TRANSPORTATION
OgO V0301 V0302
V0303
V0304
Unauth. disposal of waste to: . 25189.5
Unlawful transportation of hazardous waste. 25163
Waste transported without a manifest. 66262.20
Waste detennination not made. 6262.11

TRAINING, CONTINGENCY PLAN & ER PROCEDURES

VIOL VIOLATION DESCRIPTION
Training records unavailable. 66265.16
V0402 Training program not adequate. 66265.16
V0403 Facility not designed to minimize release.
66265.31
V0404 Spill control equip not available. 66265.32
V0405 . Aisle space is obstructed. 66265.3 5
V0406 Contingency plan not prepared and/or on file.
66265.51, 66265.53

HAZARDOUS WASTE TANK SYSTEMS
0 Vl601 Hazwaste tanks w/o P.E. assessment. 66265.191 a, 66265.192a
0 Vl602 P.E. Assessment report not complete. 66265.19lg, 66265.192k
0 Vl603 Hazwste tank system: no secondary containment.
66265.193a
0 Vl604 Secondary containment not kept empty.
66265.196(b)(c), 66265.194(c)
0 VI 60S No daily tank inspection/inspect. log 66265.195 (b&c) 0 Vl606 Improper or absent spill/overfill protection.
66265.194b
0 Vl607 Improper corrosion protection. 66265.191, 66265.192 0 Vl608 Integrity assessment not done for 2ndary containment system. 66265.191
0 Vl609 Improper use of hazardous waste tank system.
66265.196
0 Vl610 NoPE assessment report for repairs/changes.
66265.196g
0 Vl611 Improper closure ofhaz waste tank unit. 67383.3, 66265.197

HAZARDOUS MATERIALS REQUIREMENTS

BUSINESS PLAN REQUIREMENTS
0 VIOOI UFP pennit not obtained for Haz. Materials. 68.905 0 VI002 Hazardous Materials Business Plan (HMBP) not
0 0
0 0
0 0
0 0
0 0
VI003
VI004
VIOOS
VI006
V1007
VI008
VI009
VIOIO
V2504
V2553
established/implemented. 25503.5
HMBP not to reflect changes25505
HMBP not submitted to HMD. 25505
Emergency Contacts not provided/current. 25509
Inventory is incomplete. 25504
Highly toxic gas (TLV:':IO ppm) not disclosed in
chemical inventory. 68. 1113
Annual carcinogen & reproductive toxin list not
submitted to HMD 68.1113
Site map is not sufficient. 25509
Failure to report a release/threatened release 25507
Owner or operator (0/0) Stationary Source (SS)
with >TPQ of a regulated substance (RS) did not
comply with Chapter 4.5 (CalARP process). 2745.1
0/0 of a new or modified SS with > TPQ of RS did
Not submit RMP. 2735.4, 25535 (d)
$·

SIGNATURE OF BUSINESS REPRESENTATIVE
t:><'h.ufo"L­

DATESIGNED
I\1AN"'4 u-

T TLE OF BUSINESS REPRESENTATIVE
DEH:HM-923 DEH:HM-9255 (Revised 04102) NCR DISTRffiUTION:WHITE-RETURN TO HMD; YELLOW-BUSINESS RETAINS

COUNTY OF DIEGO

COMPLIANCE INSPECTION REPORT

NUMBER H
DATE 5'- 1/2- I c-z PAGE OF .!2::::_.

VIm .AITON REPORT: The items checked below refer to specific section numbers of Titles 19 of the California Code of Regulations (CCR), Chapters 6.95 of the ealth and Safety Code (HSC), and/or the San Diego County Code (SDCC). [ 1-V2728 -Did not submit rev. OCA to AA. 2750. 7Cb)
[ )-V2730 OCA Dncnmentatjon 2750
[ ]-V2731 -Did not maintain WCS OCA docs 2750.8(a)
[ ]-V2732 -Did not maintain ACES OCA docs 2750.8(b)
______ , [ ]-V2733 -Did not maintain OCA docs of release. 2750.8(c) [ )-V2515 General Requirements [ ]-V2734 -Did not maintain OCA docs on methodology 2750.8(d) [ ]-V2516 -PI 0/0 did not cord. w local ER agencies. 2<Q5.5(d) [ J-V2735 -Did not maintain data, pop, enviro. 2750.8(e) [ ]-V2517 -P2 0/0 did not implement a mgnt sys. 2735.5(1.). [ ]-V2736 -Did not report ace. releases. 2750.9(a) [ ]-V2518 -P2 0/0 did not implement prevention steps. E 1-V2737 -Did not keep ace. release data. 2750.9Cb) [ ]-V2519 -P2 010 did not implement an ER program. 2535(e)t-\ [ ]-V2900 Emergency Response Program, 2765 2 [ ]-V2520 -P3 0/0 did not conducted a HAZ-Assmt 2535(£)(2) [ ]-V2901 -Did not developER Plan. 2765.2(a) [ ]-V2521 -P3 0/0 did not implement prev-req. 2535(£)(3) [ J-V2902 -Did not maintainER plan onsite 2765.2(a)(l) [ ]-V2903 -ER plan did not include procd. for Cord. 2765.2(a)(l)(A) [ )-V2530 Management System 2735 6 [ J-V2904 -ER plan did not inc. doc. ofmed treat. 2765.2(a)(l)(B) [ ]-V2531 -P2 or 3 did not develop a mgent sys. 2735.6(a) [ ]-V2905 -ER plan did not inc. postER action. 2765.2(a)(l )(C) gnm.Jp!Ji.er!:§SQOni!JillpOQJS>!)itwi l-V2906 -ER plan did not inc. ER equip info 2765 .2( a )(2) ( )-V2535 Begjstratjon 2740 1 -ER plan did not inc. emp train. 2765.2(a)(3) [ J-V2536 -0/0 did not submit registration-info Reg. 2740 _J(b) [ -ER plan did not inc. rev/update 2765.2(a)(4) _____ [ [ -ER plan did not inc. plan pursuant HSC25503.4 2765.2(b) [ J-V29J,O -ER plan not cord w plan Sec II 003 Ti42 USC. 2765.2(c) [ ]-V2551-0/0didnotsubmitRMP,(T1,2)RS2745.l(c) --[ ]-V2552 -0/0 did not submit RMP (T3) RS 2745.!(d) I J-V2739\Program 2 Prevention Program Article 5 J!.!SUJJ;bmmn.ituRM!SJY!ctP.J(J_TJ.3 ---I [ 1-V27 40 Safety Information 2155 1 [ J-V2565 RMP Reyjew Process 2745 2 [ J-V2741 main. up-to-date safety info. 2755.1 (b) [ ]-V2566 -0/0 did not certifY RMP complete. 2745.2(a)(J) -V2742 -Did ot u date safe! info m·r en . 2755.1 c [ ]-V2567 -0/0 failed, make corrections per Def. Ntc. 2745 .2(a)(3)(A) I ]-V2745 -Haza Program 2 2755.2 6o!f8!..:-:\,0"'/0!L!!d"-\idun"'o!!.t .!.Jre'!lat...· ;>.!3 ·"'2J.1( aw)f}3.l()(fjAJ.) --I [ ]-V2 7 46 -Did not Update haz-revw, evry 5 yr. 27 55.2-[ J-V2650 RMP Update 2745 1 o [ J-V2751 -Did not operating-proceed. 2755.3(a) [ ]-V2651 -0/0 did not update RMP. (T1,2). 2745.JO(a). [ J-V2752 -Did not updiue op-procedures 2755.3(c) [ ]-V2652 -Did not update w 5 yrs .submit (TI,Z). 274 S.JO(a)(l). t>4-V2761 -Did not train ksent/new emps on op-proced. 2755.4(a) [ ]-V2653 -Did not update w 3 yrs. of RS listing (TI ,2). 2745 _1 O(a)(2). [ ]-V2762 -Did not are skilled 2755.4(a) [ ]-V2654 -Did not update, prior toRS on site (TJ ,2). 2745 _1 O(a)(3). [ ]-V2763 -Did not do training, 3 yrs. Z755.4(b) [ ]-V2655 -Did not update w 6mo. of eng. Rev. PHA (TIZ) 2745 _1 O(a)(5) V2764 -Did not train emps. on up/new Proced. 2755.4(d) [ ]-V2656 -Did not update w 6mo. of eng req. rev OCA. (Tl,2) 745 .lO(a)( 6) [ ]-V2770 Maintenance Progiam 2, 2755 5 [ ]-V2657 -Did not update w 6 mo. ofPerrn eng. (TI ,2) 2745.10(a)(7) [ J-V2771 -Did not prepare integri . proced. 2755.5(a) [ ]- V2659 -Did not update w 5 yrs. of sub. (T3) 2745.1 O(b)(J) [ F V2772 -Did not train on integrity. raced. 2755.5(b) [-JN2661 -Did not update, prior toRS onsite (T3) 2745.10(b)(3) [ J-V2773 -Contractor, did not train e s. 2755.5(c) [ ]-V2662 -Did not update prior to RS onsite, new procs (T3) 274 5 .I O(b )( 4) 1 :=-:v:::2'::7-':74"-· .. il!!n;us ______ _ [ ]-V2663 -Did not update w 6mo. ofPHA eng req. rev. (T3) 2745.1 O(b )(5) I J-V2775 [ ]-V2664 -Did not update w 6mo. ofOCA eng. req. rev. (T3) 2745.JO(b)(6) [ J-V2776 -0/0 did not certify the audit. 2 5.6(a) [ ]-V2665 -Did not update w 6mo. of PERM eng. (T3) 2745.1 O(b)(7) [ ]-V2777 -Did not audit w 1 per, w knowled e. 2755.6(b) [ ]-V2666 -Did not notify n'1viD of a 0/0 eng (T3) 2745.1 O(f) [ ]-Y2778 -Did not develop a audit report. 275 .6( c) [ l-V2667 -Did not deterrn. if eng to RMP necessary (T3) 2745.JOCD [ ]-V2779 -Did not respond, audit findings. 27 .6(d) [ ]-V2675 Cpyered process Mpdificatjpn 2745 11 -V2780 -Did not kee 2 most recent audit re o 2755.6 e [ ]-V2676 -Did not notify AA 5 day. before mod. 2745.11(a)(l) [ ]-V2780 Incident lnyestjgatjpn Program 2, 27 5.7 [ ]-V2677 -Did not consult AA in RMP mod. 2745.11(a)(J) [ ]-V2781 -0/0 did not investigate an incident 2755. (a) [ ]-V2678 -Did not notifY AA w 48 hr of mod 2745.1l(a)(J) [ ]-V2782 -0/0 did not investigate within 48 hrs of an ·ncident. 2755.7(b) [ 1-V2679 -Did not revise docs w 60 days of mod. 2745.ll(b) [ ]-V2783 -0/0 did not prepare incident report. 2755.7 ) [ )-V2725 OCA Review and Update 1150 7 [ J-V2784 -0/0 did not resolve incident finding. 2755. ) [ ]-V2726 -Did not rev/update OCA every 5 years. 2750.7(a) [ J-V2785 -0/0 did not take action because of the incident 2755.7(d) [ ]-V2727 -Did not revise OCA w 6mo. of endpoint eng. 2750.7(b) [ J-V2786 -0/0 did not review incident findings with perso el. 2755.7(e) [ ]-V2787 -0/0 did not keep summaries, 5 yrs. 2755. 7(£)- ALL VIOLATIONS MUST BE CORRECTED. PLEASE CALL (619) 338-2222 OR YOUR INSPECTOR IF YOU HAVE ANY QUESTIONS.

DEH:HM-(Rev. 4/02)
.....
• •

SAN DIEGO COUNTY
DEPARTMENT OF ENVIRONMENTAL HEALTH· CUPA
HAZARDOUS MATERIALS DIVISION .RECEIVED P.O. BOX 129261, SAN DIEGO, CA 92112-9261 (619) 338-2222 FAX (619) 338-2377
1-800-253-9933 .200q FEB 26 Arl 10 13

BUSINESS OWNER/OPERATOR IDENTIFICATION
Certification: Based on my inquiry of those individuals responsible for obtaining the infonnation, I certify under penalty of law that I have personally examined and am familiar with the infonnation submitted and believe the infonnation is true, accurate, and complete.

DEH:HM-UPCF-BUSINESS OWNER/OPERATOR IDENTIFICATION (7/02) OES FORM 2730 (1199) - ···fA£' Ai- J.-:;. I -==z:/\-1
· -Nationai·Energy &
RECEIVED :..rf p ·
Gas Transmission-
?l}fiq H.B 26 AP\10 13
Dispersed Generating Company, LLC
D. E. H.

Mt.ILROOH
February 25, 2004
San Diego County
Department of Environmental health- CUP A
Hazardous Materials Division
PO Box 129261
San Diego, CA 92112-9261
RE: NEGT Dispersed Generating Company, LLC
Sites #101955 and #139211
Change in Inventory
To whom it may concern:
7 600 Wisconsin
Avenue
Bethesda, MD 20814
301.280.6800
Fax: 301.280.6900
www.nelrt.com
Enclosed please find Forms #2730, #953 and #2731 for the NEGT Dispersed Generating Company, LLC sites located in Chula Vista and Escondido. These forms reflect Hazardous Material inventory for these sites.

Due to business restraints, these sites have been temporarily inactivated for operational purposes. For safety reasons, a decision has been made to no longer maintain an inventory of the Aqueous ammonia 19% at either of these sites, while inactive. These sites are inspected on a regular weekly basis for security and other routine obligations.

When these sites become activated again, we will submit the appropriate paperwork.

If you have any questions or comments, please contact me at 508.769.5123.

Sincerely,
Susan D. Flash
Environmental Manager
An Affiliate of National Energy & Gas Transmission, Inc. (NEGT) - Debtor in Possession e· County of San Diego MAR 1 6 2005

COMPLIANCE INSPECTION REPORT
BUSINESS NAME: _____________ _
ADDRESS: __________ _
CITY/ZIP: CHULA VISTA, 91911 858-278-9170
On the above date, an inspection of your business/facility was conducted in order to determine with the California Health and Safety Code (HS) Chapters 6.5, 6.7, 6.95; Titles 19, 22 and 23 of the California Code of Regulations (CCR); and the San Diego County Code (SDCC).

The following remarks are intended to provide guidance to correct the violations noted on the attached violation report.

NOTE: Reinspection fees will be charged if additional inspections are required to determine compliance.

Y N/A Y N/A
D Unified Program Facility Pennit current & Available Pennit Expires on: 11130/2005 D Hazardous Materials Business Plan Available D D Contingency plan Available D Employee Training is adequate D D Employee Training Available D D Waste Disposal records available for review D Waste Containers kept closed D D Emergency contacts Current Updated Today D Waste Containers kept labeled D D Chemical Inventory current Updated Today D Waste containers in good condition D All violations noted on this compliance inspection report were corrected during this inspection 0 This is an annual certification that the H82llrdous Materials Business Plan (inventory, emergency contacts, emergency response plan, and employee training plan) is current and includes all the information required in the H & SC and is maintained at the site where hBZllrdous materials are stored.

Type of inspection(s) conducted this date:

Routine
General Comments/Remarks
Initials of
Business
Representative
* Facility in standby status, not operational but still has hazardous materials on site. Ammonia not on site, facility will be a Ca!ARP site when operational.
* NotifY DEH at the address below on change of owner I operational status. * No Waste on site, only material is oil. Change status ·to K 18.

Questions and/or corresoondence regarding this report should be diredcted to:

Jim Hendenon ·
Environmental Health Specialist P. 0. Box·l29261 MSD561 of Environmental Health San Diego , CA , 92112-9261
Phone: (619) 338-2458
Fax: (619) 338-2139
Hazardous Materials Division Email: [email protected] Website: http://www.sdcounty.cagov/dehlhmdl

GARY W ERBECK

DIRECTOR
May 5, 2006
Ms. Danelle Griffin
Environmental Consultant
7911 Blue Jay Place
San Diego, CA 92123-3311
Dear Ms. Griffin

DEPARTMENT OF ENVIRONMENTAL HEALTH

HAZARDOUS MATERIALS DIVISION
P 0 BOX 129261, SAN DIEGO, CA 92112-9261
(619) 338-2222 FAX (619) 338-2377
1-800-253-9933
SUBJECT: NOTIFICATION OF FACILITY INSPECTION- MMC CHULA VISTA, LLC, 3497 MAIN STREET, CHULA VISTA, CA 91911, PERMIT NUMBER 139211, DURING THE WEEK OF MAY 8, 2006.

The Hazardous Materials Division (HMO) inspects businesses or facilities, 1n order to determine compliance with the California Health and Safety Code (H&S) Chapters 6 5, 6.7, 6.95; Titles 19, 22 and 23 of the California Code of Regulations (CCR), and the San D1ego County Code (SDCC). This letter IS to notify you that the HMO will be conducting a rout1ne compliance and change of ownership inspection of your facility. The inspect1on will focus on these general areas:

Site Inspection: An 1nspect1on of the facility by a Hazardous Materials Specialist (including buildings, equipment, storage areas, work areas, etc.).

Observe hazardous materials and waste storage, handling, container labeling; and waste disposal procedures.

Review spill control procedures and spill report1ng.

Review and evaluate hazardous materials that are stored or handled on-site.

Review the Hazardous Materials Bus1ness Plan: (Site Map, Emergency Response Procedures, and Employee Training Plan). .

Rev1ew the hazardous materials trainmg program and documentation (written records).

Review hazardous waste disposal receipts and man1fests.

Additionally your facility is subject to the California Accidental Release Prevention (CaiARP) Program regulations under Title 19, Division 2, Chap 4 5, and has submitted a Risk Management Plan (RMP) for a Regulated Substance (anhydrous ammonia) in a Covered Process. For this port1on of the Inspection the following records will be rev1ewed:

RMP Public Document, and related Technical Documents
RMP Update Documentation: within 5 years of Initial subm1ss1on, change of owner/ operator, updated registration information, Program level change, (if any).

Revised/Updated Offs1te Consequence Analysis (OCA) - every 5 years, or 1f significant process modification.

Prevention Program 2 Documents: Safety Information, hazard review, operating procedures, train1ng, maintenance, compliance audits, and incident Investigations.

Emergency Response Program.

Accidental Release Records (if any).
"Envzronmental and publzc health through leadershzp, partnershzp and sczence" ,..

Ms. Gnff1n - 2 - May 8, 2006
This notification is intended to better prepare you for the inspection cntena pertam1ng to the CaiARP Program. I would like to schedule the inspection w1th you for the week of May 8, 2006.

The HMO also recommends you review your RMP public document for other documents referenced (Operational Procedures, Mamtenance Records, Tra1n1ng Programs, etc.) which will be reviewed during the Inspection. Depending on the s1ze and complexity of your facility the Inspection is expected to take 1-4 days. If you have any quest1ons please call me at (619) 338- 2453. Thank you for your cooperation
G. McCabe, MPH, REHS
Enwonmental Health Specialist Ill
Hazardous Materials Division
cc. John Kolb, Supervising Enwonmental Health Specialist Martin Quinn, Princ1pal, Chief Operat1ng Off1cer
Rick Bryant, Chula Vista Fire Department
HMO File#: 101955

CERTIFIED MAILIRRR
"Envzronmenta/ and publzc health through leadershzp, partnershzp and sczence" ..
. ..
•
Donelle Griffin
Environmental Consulting
7911 Blue Jay Place
San Diego, CA 92123-3311
. , /'" 1 ... 11111 7 12 32
January 17,2006

VIA HAND DELIVERY
Mark G. McCabe
County of San Diego
Hazardous Materials Division
1225 Imperial Ave.

P.O. Box 129261
San Diego, CA 92ll2-9261
Subject: Risk Management Plan Updates- Chula Vista Power Plant Facility ID#37-000-139211
Dear Mr. McCabe,
l'.

C1,.1 ;., ; · ·'
; ! I-'. i l- •, ,.., U J I
jJ,'f ZJ/
(Please /})e
fr!,
On Behalf ofNEGT Dispersed Generating Co., LLC, I am submitting the enclosed Cal-ARP Regulated Substance De-Registration Form. The Chula Vista Power Plant located at 3497 Main St., Chula Vista, CA 91911 has had a change of ownership effective January 9,2006. The ammonium hydroxide was removed from the site December 8th, 2003 and no ammonium hydroxide has been stored at the site since that date. ·.

Please feel free to contact me if you have any questions or concerns.

Sincerely,
M
Donelle Griffin
Environmental Consulting
858-354-4995
Enclosure
CC: Robert Moore, NEGT Dispersed Generating Co., LLC
I.

2. 3.

I.
• SAN DIEGO COUNTY

DEPARTMENT OF ENVIRONMENTAL - CUPA

HAZARDOUS MATERIALS DMSION
P.O. BOX 129261, SAN DIEGO, CA 92112-9261
(619) 338-2222 FAX (619) 338-2377
Cal-ARP REGULATED SUBSTANCE DE-REGISTRATION FORM
II. THE FOLLOWING REGULATED SUBSTANCES ARE NO LONGER HANDLED AT THE ABOVE SITE.

Name of Regulated Substance Reason for uts,con,nnueo
chemical
Ammonium 19%
Ill. THE FOLLOWING REGULATED SUBSTANCES ARE HANDLED BELOW THEIR Name of Regulated Substance* Total amount Units of largest stored on site? (in pounds) storage container?
,a-change Quantities to: !! in KJV A for these billing codes: 6HCUP AJ, 6HRMPI and 6HRMP2. 0 Delete items listed in Section IT above
C Add comment: "Verify Inventory or use of: ___________________ __...

Cai-ARP disclaimer submitted on __ indicates below TPQ/ discontinued use". follow HIRT policy to indicate on the inventory make
.• ., . ..

July 10, 2006
Mr. Marlc McCabe
County of San Diego
Donelle Griffin
EnviroiUftellllll Consulting
7911 Blue Jay Pltu:e
San Diego, C4 92123-3311
Department of Environmental Health
Hazardous Materials Division
P.O. Box 129261
San Diego, CA 92112-9261
2t!J6-&J
//ease ;::;/e
t7ECEIIIED
20DS JUL 12 Am 4
I I 10 23
D. t. H
.'iAILROOH
SUBJECT: UPDATED RISK MANAGEMENT PLAN (RMP)- PUBLIC NOTIFICATION ESTABLISHMENT #206738, MMC CHULA VISTA, LLC AND ESTABLISHMENT #206739, MMC ESCONDIDO, LLC
Dear Mr. McCabe;
On the behalf ofMMC Energy North America, LLC, I am submitting a copy of the Certificate of Publication for the above mentioned sites. This notice was published in San Diego Transcript on July 6th, 2006.

Please feel ftee to contact me if you have any questions or concerns.

Sincerely,
Donelle Griffin
Environmental Consulting
858-354-4995
Cc: Martin V. Quinn, MMC Energy North America, LLC
Steve Cox, MMC Escondido, LLC
Marlc Wellard, MMC Chula Vista, LLC

CERTIFICATE OF PUBLICATION
Donella Griffin
7911 Blue Jay Place
SAN DIEGO CA 92123

IN THE MATIER OF
MMCNorth American
CASE NO.

I, Eboni N. Hines, am a citizen of the United States and a resident of the county aforesaid; I am over the age of
eighteen years, and not party to or interested in the above entitled matter. I am the principal clerk of the San Diego Transcript, a newspaper of general circulation, printed and published daily, except on Saturdays and Sundays, in the City of San Diego, County of San Diego and which
newspaper has been adjudged a newspaper of general
circulation by the Superior Court of the County of San
Diego, State of California, under the date of January 23, 1909, Decree No. 14894; and the
Health Notice
is a true and correct copy of which the annexed is a printed copy and was published in said newspaper on the following date(s), to wit:

July 6
I certify under penalty of perjury that the forgoing is true and correct.
• OF SAN DIEGO
BUSINESS NAME MMC Energy Chula Vista, LLC
ADDRESS 3497 Main Street
CITY/ZIP Chula Vista, CA 91911
On the above date, an inspection of your business/facility was conducted in order to determine compliance with the California Health and Safety Code (HSC) Chapters 6.5, 6.7, 6.95; Titles 19, 22 and 23 of the California Code of Regulations (CCR); and the San Diego County Code (SDCC). The following remarks are intended to provide guidance to correct the violations noted on the attached violation report.

NOTE: Reinspection fees will be charged if additional inspections are required to determine compliance.

Y N/A Y N/A
X D Unified Program Facility Permit current and available ·Permit Expires on:

X D Hazardous Materials Business Plan available X D Contingency Plan available X D Employee Training is adequate X D Employee Training records available X D Waste disposal records available for review X D Waste containers kept closed X D Emergency contacts current X Updated today X D Waste containers kept labeled X D Chemical inventory current D Updated today X D Waste containers in good condition D All violations noted on this compliance inspection report were corrected during this inspection.

Change of owner/Routine compliance inspection conducted today. Permission to conduct the ins.Pection give!}. b..Y. Mark Wellard and Donelle Griffin. RECEIVEU JUL 1 7 ZOUti
No violations observed today. This site has been inactive for quite a while and is preparing to come back on line as a Peaker power generating station. The new owner is MMC Energy North American, LLC, Comments: Recommend keeping cylinders chained and secured at all times to prevent falling over. Posting a sign in the area with words like "Always Secure Cylinders with the Chain" might help.

Employees have full face respirators to use during ammonia deliveries and any accidental releases. Assure that employees issued these respirators receive the required annual fit testing. Also assure that these respirators are inspected at least monthly to see that they are operational and ready for emergency use if needed. Document annual fit tests and monthly respirator inspections.

Changes in the uniform hazardous waste manifest beginning September 5, 2006, will require you to start mailing a copy of your manifests to the Department of Toxic Substances Control (DTSC). Blue manifest copies will no longer be provided.

More information is provided in the May 2005 Upcoming Manifest Changes Fact Sheet from DTSC.

The EPA Identification number for this site is CAL 000 303 061 D This is an annual certification that the Hazardous Materials Business Plan (inventory, emergency contac , emergency response plan, and employee training plan) is current and includes all the information requi ed · the H&SC and is m Initials of Business Representative _2._; l5_; 0 Ch i!N(fu, 111.JJ dw)u//J-
Date Signed Title of Business Representative
Department of Environmental Health, Hazardous Materials Division, P.O. Box 129261, San Diego, CA 92112-9261; (619) 338-2222; sdcdeh.org HM-924 (09/03) NCR DISTRIBUTION: WHITE- RETURN TO HMD YELLOW-BUSINESS RETAINS e • COUNTY OF SAN DIEGO
DATE: 05
PERMIT# 139211 (old)
I 11
SUPPLEMENTAL INSPECTION REPORT 2 2 __
BUSINESS ADDRESS: MMC Chula Vista, LLC 1968 Don Lee Place, Escondido ZIP CODE: ----"-9-'-'19,_.._1_,__1 __ The Chula Vista and Escondido sites share one four gas meter (Model 8800) between the two sites. Recommend keep a separate four gas meeter at both facilities. Assure that this meter is kept calibrated according to the manufacture's specification and kept charged and ready for use at all times. Also, the THC calibration gas sen on site today is not appropriate to calibrate the four gas meter. This gas was probably for calibrating total hydrocarbons emitted through exhaust monitored by the CEMS.

Obtain an appropriate calibration gas for this meter and keep the meter calibrated and charged ready for use at all times.

Hazardous wastes generated include waste oil, ocassionaly waste glycol coolant, oil contaminated soils (rags and absorbant), used oil filters, and lead acid battery cores.

An updated Hazardous Materials Business Plan was accepted in the field today.

Assure that mosquitos do not breed in the storm water detention basins. If you need any help with mosquito control, please call our Vector Control Division at 858-694-2888. Their services are paid for through an assesment already on your annual property tax.

Assure that all piping is clearly labeled with the contents and direction of flow. A copy of the American National Standards Institute (ANSI) piping standards is provided to help with this.

Strongly recommend developing a polyball maintenance program. The black plastic balls may deteriorate in the sun. Cracked or damaged polyballs may trap rain water or any leaked aqueous ammonia and make the clean up even more difficult.

Keep copies of hazardous waste manifests and bills oflading on site to document proper disposal of hazardous wastes and recyclable materials generated on site.
__s:_, /..{'" {) t.

Date Signed
Department of Environmental Health, Hazardous Materials Division, P.O. Box 129261, San Diego, CA 92112-9261; (619) 338-2222 DEH: HM-9110 (12-02) DISTRIBUTION: WHITE- RETURN TO HMO YELLOW-BUSINESS RETAINS '
I
I .

I
I '
e

COUNTY OF SAN DIEGO

COMPLIANCE INSPECTION REPORT
BUSINESS NAME m.tz7C Jd_(:zh7 LL..C
ADDRESS, '?£19-? .zrZ.Io , 97'.t??e6-
CITY/ZIP cAvA- d'r:&s U
_,LOFLDATE
O.SI_d_l o/
PERMIT#
TIMESTARTt78..?" END 1/ co
SPECIALIST /!2

INSPECTION CONTACT/TITLE
h?.::rk I
PHONE: (b/j)
RECEIVED JUL 1 I
0 This is an annual certification that the llazardous Materials Business Plan (inventory, emergency rgency response plan, and employee training plan) is current and includes all the required in the II&SC and ism Initials of Business Representative :!0 1/ 1Qb
Date Signed Title of Business Representative
Deoartment of Environmentalllcalth. Hazardous Materials Division. P.O. Box 129261, San Dieeo. CA 92112-9261: (619) 338-2222: sdcdeh.ore HM-924 (09/03) NCR DISTRIBUTION: WHITE- RETURN TO HMD YELLOW-BUSINESS RETAINS r.
/
COUN

COMPLIANCE INSPECTION CHECKLIST,
PERMIT# 2.0£
DATE "<$ _ _,/ 6 6
CalARP llrorun•<> PAGE OF __ ----____ _
BUSINESS ADDRESS: ll'Jrr'JC en . .t4 .. ;;;yq,7 dk/ac o!t-&4 c.-V ZIP: _2L</'--"''24!«'--------- VIOLA TION REPORT: The items checked below refer to specific section numbers of Title 19 of the California Code of Regulations (CCR), Chapter 6. 95 of the Health and Safety Code (HSC), and/or the San Diego County Code (SOC C).

All violations must be corrected. Submit documentation of return to compliance to your Specialist. You may use the Corrective Action Form to document your return to compliance. Your Specialist can provide these forms. Please call (619) 338-2222 or your Specialist if you have any questions.

The following abbreviations are used throughout this document: SS=Stationary Source; 0/0=0wner/Operator; C Viol VIOL VIOLATION DESCRIPTION Viol VIOL VIOLATION DESCRIPTION # General Requirements # Compliance Audits 2755.6
0 V250 I Stationary Source did not prepare RMP, RS(Tl ,2). 2735.4 BOD V2668 Owner/Operator did not meet audit requirements. 2755.6 0 V2502 General requirements not met by owner/operator. 2735.5 V2669 Owner/Operator did not certify the audit 2755.6(a) 0 V2503 P2-ER program not implemented by 0/0. 2535(e)(4) V2670 Owner/Operator did not respond to audit findings. 2755.6(d) 0 V2504 Hazard Assessment not done by O/O-P3. 2535(1)(2) V2671 Did not keep 2 most recent audit reports. 2755.6(e) 0 V2505 Prev. program requirements not implemented. 2535(1)(3) Incident Investigation 0 V2506 ER Program not implemented P3. 2535(1)(4) c:=J 0 V2672 0/0 did not meet incident investigation req. 2755.7 o
0 V2507 Management System not developed by 0/0. 2735.6 ARTICLE 6: Prevention Program 3 V2508 Registration information not submitted. 2740.1 c:=J DO V2701 010 did not meet requirements for PSI Info. 2760.1 RMP Submission 2745.1 CJ V2702 Owner/Operator did not meet PHA req. 2760.2 V2509 RMP not submitted by owner/operator. 2745.1 Operating Procedures 2760.3 V2510 RMP not certified complete by 0/0. 2745.2(a) DBD V2703 0/0 did not meet Operating Procedure Requirem. 2760.3 V2511 Corrections on deficiency notice not done. 2745.2(a) V2704 0/0 did not prepare OP-procedures. 2760.3(a) V2512 30-day extension for corrections not requested. 2745.2(a) V2705 OP-procedures not accessible to employees. 2760.3(b) V2706 0/0 did not annually certify OP-procedures. 2760.3(c) RMP Updates 2745.10 Training Program 3. 276o.4
V2601 RMP not updated by Owner/Operator. 2745.10 DBD V2707 0/0 did not meet training program requirements. 2760.4 V2602 RMP not updated within 5 years of submittaL 2745.10 V2708 0/0 did not provide initial training. 2760.4(a)(1) V2603 RMP level not updated within 6 months of change. 2745.10 y 2709 O/O did not provide refresher training. 2760.4(b) V2604 RMP not updated prior to having RS onsite. 2745.10 V2710 0/0 did not maintain training documentation. 2760.4(c) V2605 RMP not updated w/i 30 days of0/0 change. 2745.10(1) Mechanical Integrity 2760.5 OCA-Offsite Consequence Analysis 2750.7-8 0 V2711 0/0 did not meet Mechanical Integrity requirements. 2760.5 V2609 Offsite Consequences not rev/updated e/5 yrs. 2750.7(a) 0 V2712 0/0 did not establish integrity procedure. 2760.5(b) V261 0 Offsite Cons. no rev/upd w/i 6 mo. of change. 2750.7(b) 0 V2713 0/0 did not train each employee on integrity proc.

V2611 Rev OCA not sent to HMD w/i 6 mo. of change. 2750.7(b) 0 V2714 Test frequency inadequate. 2760.5(d)(3) V2612 Offsite Consequences documents not kept by 0/0. 2750.8 0 V2715 Inadequate documentation of inspections/tests. 2760.S(d)(4) V2716 0/0 did not correct equipment deficiencies. 2760.5(e) Management of Change 2760.6 ARTICLE 5: Prevention Program 2 Safety Information 2755.1
c:=J 0
0 V2651 0/0 did not compile/maintam safety information. 2755.1 c:=J V2652 0/0 did not update safety info.-major changes. 2755.(c) Hazard Review 2755.2
V2653 0/0 did not meet all hazard review requirements. 2755.2 V2654 0/0 did not doc. & correct hazard review issues. 2755.2(e) V2655 0/0 id not complete/update hazard review e/5yrs. 2755.2(1) Operating Procedures 2755.3
V2656 0/0 did not meet operating procedure requirements. 2755.3 V2657 0/0 did not prepare operating procedures. 2755.3(a) V2658 0/0 did not update operating procedures. 2755.3(c) Training Program 2755.4
V2659 0/0 did not meet training program requirements. 2755.4 V2660
V2661
V2662
Present/new employees not trained-on op. proced. 27SS.4(a) Did not do refresher training every 3 years. 2755.4(b)
Employees not trained on updated/new procedures 2755.4(d) Maintenance 2755.5
V2663
V2664
V2665
V2666
V2667
010 did not meet maintenance program req. 2755.5
0/0 did not prepare integrity procedures. 2755.5(a)
010 did not train on integrity procedures. 2755.5(b)
Contractor did not train employees. 2755.5(c)
Did not inspect and test equipment 2755.5(d)

SIGNATURE OF BUSINESS REPRESENTATIVE
DEH:HM-922 (Revised 07/03) NCR
0 c:=JO
V2717 0/0 did not meet management change requirements. 2760.6 V2718 Did not establish procedures for manag. Changes. 2760.6(a) Pre-Startup Review 2760.7
V2719 0/0 did not meet pre-startup safety review Req. 2760.7 V2720 0/0 did not do PHA prior to startup. 2760.7(b)(3) V2721 S-review did not include employee training. 2760.7(b)(4) Compliance Audits 2760.8
V2722 Did not meet audit requirements. 2760.8
Incident Investigation 2760.9
V2723 0/0 did not meet incident investigation requirem. 2760.9 V2724 0/0 id not retain investigation reports for 5 yrs. 2760.9(g) Employee Participation. 2760.10
V2725 Employee participatiOn plan requirements not met 2760.10 Hot Work (HW) Permit. 2760.11
V2726 0/0 did not meet work permit requirements. 2760.11 Contractors 2760.12
D 0 V2727 Did not meet contractor safety requirements. 2760.12(b)(1) Contract Owner (CO)/Operator Responsibilities. 1260.12(c) c:=J 0 V2728 CO did not meet contract operator responsibility 2760.12(c) D 0 V2729 CO training documentation not maintained. 2760.12(c)(3) ARTICLE 7: Emergency Response Program
c:=J 0 V2801 0/0 did not implement Emerg. Response Plan. 2765.1(a) D 0 V2802 ER plan not cord w plan, Sec 11003 Ti42 USC 2765.2(c)

DATE SIGNED TITLE OF BUSINESS REPRESENTATIVE
DISTRIBUTION: WHITE-RETURN TO HMO; YELLOW-BUSINESS RETAINS

SAN DIEGO COUNTY

DEPARTMENT OF ENVIRONMENTAL HEALTH- CUPA

HAZARDOUS MATERIALS DIVISION
P.O. BOX 129261, SAN DIEGO, CA 92112-9261
(619) 338-n22 FAX (619) 338-2377
1-800-253-9933
' j)" 2'7 BUSINESS ACTMTIES .. ,c·U c.hN
1 2 16
MMC Chula Vista, LLC
Have on site (for any purpose) hazardous materials at or above 55 gallons for liquids, 500 pounds for solids, or 200 cubic feet for compressed gases (include liquids in ASTs and USTs); or the applicable Federal threshold quantity for an extremely hazardous substance specified in 40 CFR Part 355, Appendix A or B; or handle radiological materials in quantities for which an emergency plan to I 0 CFR Parts 40 or 70?
B. UNDERGROUND STORAGE TANKS (USTs)
• Own or operate underground storage tanks?
• Intend to upgrade existing or install new USTs?
181 YES DNO
DYES 181NO
DYES 181NO
4 5
6 HAZARDOUS MATERIALS INVENTORY­
CHEMICAL DESCRIPTION (OES 2731)
UST (Formerly SWRCB Fonn A)
UST TANK (one page penank) (Fonnerly Fonn B)

UST FACILITY
UST TANK (ooe"" tank)

UST INSTALLATION -CERTIFICATE OF
COMPLIANCE (one 1"8" ""tank) (Fonnerly Fonn q
NO 7 UST TANK (closure pon;oo """'page"" lank)
D YES 181 NO 8 NO FORM REQUIRED TO CUP As
• Generate hazardous waste? 181 YES DNO 9 EPA ID NUMBER - provide at the top of this page
•
•
Recycle more than I 00 kgfmonth of excluded or exempted recyclable materials (per HSC 25143.2)?
Treat hazardous waste on site?
• Treatment subject to financial assurance requirements (for Permit by Rule DYES 181NO
DYES 181NO
and Conditional Authorization)? D YES 181 NO
• Consolidate hazardous waste generated at a remote site? D YES 181 NO • Need to report the closure/removal of a tank that was classified as and cleaned onsite? D YES 181 NO
E. LOCAL REQUIREMENTS
• MEDICAL WASTE
Generate <200 lbs/month ofMedical!Biohazardous Waste?
Generate 2:200 lbs/month ofMedical!Biohazardous Waste?
RECYCLABLE MATERIALS REPORT (one""
10 recycler)

ONSITE HAZARDOUS WASTE
II TREATMENT-FACILITY (Fonnorly DTSC Fonm
1772)

ONSITE HAZARDOUS WASTE
TREATMENT-UNIT (ooe page"" unn) (Fonnorly
DTSC Forms 1772 A, 8, C, D and L)

CERTIFICATION OF FINANCIAL
12 ASSURANCE (Fonnorly DTSC Fonn 1232)

REMOTE WASTE I CONSOLIDATION SITE
13 ANNUAL NOT! FICA TION (Fonnorly DTSC Fonn
1196)

HAZARDOUS WASTE TANK CLOSURE
14 CERTIFICATION (FonnerlyDTSCFonn 1249)
Generate 2:200 lbs/month ofMedical!Biohazardous Waste and treat any amount of medical waste 0 YES [8lNO
0 YES [8lNO
0 YES [8l NO
0 YES [8lNO • Handle Toxic gases with threshold limit concentration (TLV) # 10 ppm in any quantity? UPF 2aG r.3B
DATEINSPECTED: $ I 1/ td_

UNIFIED PROGRAM FACILITY PERMIT

APPLICATION
This business or service is required to obtain a Unified Program Facility Permit from the San Diego County Department of Environmental Health. I answered "yes" to one or more of the questions on the "Business Activities" form.

Date assumed business ownership at this location: 6/ I 6 2 I c:2oo (... 0 I have determined.that this business or service does not require a Unified Program Facility Permit from the San Diego County Department of Environmental Health.

I declare under penalty of peijury that to the best of my knowledge and belief the statements made herein are correct and true. I consent to all necessary inspections allowed by law and incidental to the issuance of required permit(s) and the operation of this business.
• Title: Pribc.!paJ j Ch;e£ Opetztbvj 6WceC
Printed Name: --1-[VJ.L.../..l<a ..... c_.-h...._XJ.L...L..-..._V_,_. Date: %1 lo" I Phone#: (d.;;;._ ) _ _.9'-'l'--'-t--=0....:...9--=.0-::0 ___ _ Area Code Type of
ow e..r
Please complete the business information on tbe following page and return tbis application to tbe San Diego County Department of Environmental Health at:

SAN DIEGO COUNTY

DEPARTMENT OF ENVIRONMENTAL HEALTH

HAZARDOUS MATERIALS DNISION
P.O. BOX 129261
SAN DIEGO CA 92112-9261
If a San Diego County Unified Program Facility Permit is required for your business or service a representative of this Department will contact your business. Permit fees will be determined from the contact and a billing statement will be mailed.

NOTE: If you do not use hazardous materials, generate hazardous waste, or have underground storage tanks you are still required to return this form.

A representative of the San Diego County Department of Environmental Health may contact you to verify the information provided on this application.

DEH:HM-906 (08/02) 4
May 11,2006
Mr. Mark McCabe
County of San Diego
Donelle Griffin
Environmental Consulting
7911 Blue Jay Place
San Diego, CA 92123-3311
Department of Environmental Health
Hazardous Materials Division
P.O. Box 129261
San Diego, CA 92112-9261
Subject: Hazardous Material Business Plan Updates
Dear Ms. Mark,
f",
• tPkase .t?k
I'J?. m:LJ:zb e aij"z3/t'6
...

On behalf ofMMC Energy North America, LLS, I am submitting updated Hazardous Materials Business Plans for the following two sites:

MMC Escondido, LLC (101955)
1968 Don Lee Place
Escondido, CA 92029
MMC Chula Vista, LLC (139211)
3497 Main Street
Chula Vista, CA 91911
These sites were acquired by MMC Energy North America, LLC on January 9, 2006.

Chemicals were brought on site April 21st requiring an update of the plans. Please feel free to contact me if you have any questions or concerns. lk'
Donelle Griffin
Environmental Consul · g
858-354-4995
Enclosures
CC: Martin V. Quinn, MMC Energy North America, LLC
Denis Gagnon, MMC Energy North America, LLC
Martin V. Quinn

SAN DIEGO COUNTY

DEPARTMENT OF ENVIRONMENTAL HEALTH- CUPA

HAZARDOUS MATERIALS DIVISION
P.O. BOX 129261, SAN DIEGO, CA 92112-9261
(619) 338-2222 FAX (619) 338-2377
1-800-253-9933

BUSINESS OWNER/OPERATOR IDENTIFICATION
104 ZIPCODE
CA 91911-
106 SIC CODE (4
2212
Principal, Chief Operating Officer
135
GARY W. ERBECK

DIRECTOR
<tountp of iJBtego
June 20, 2006
Mr. Martin V. Quinn
Principal, CEO
MMC Chula Vista, LLC
26 Broadway, Suite 907
New York, NY 10004
Dear Mr. Quinn:

DEPARTMENT OF ENVIRONMENTAL HEALTH

HAZARDOUS MATERIALS DIVISION
P.O. BOX 129261, SAN DIEGO, CA 92112-9261
(619) 338·2222 FAX (619) 338-2377
1-800-253-9933
tP ,b;;.se /7:/e ·
.2o6 r$8
DAN D!:lAUR::NTIS

ASSISTANT DIRECTOR
SUBJECT: UPDATED RISK MANAGEMENT PLAN (RMP)-REQUEST FOR PUBLIC NOTIFICATION: ESTABLISHMENT #206738, MMC CHULA VISTA, LLC This letter is to notify you that the San Diego County Hazardous Materials Division (HMO) has received an updated RMP for the management of aqua ammonia at the MMC Chula Vista, LLC Facility, 3497 Main Street, Chula Vista, CA 91911. Pursuant to Section 25535, Article 2, Chapter

6.95 of the California Health & Safety Code, HMO will initiate the process for governmental and public review.

In an effort to reduce regulatory cost and to increase efficiency in the RMP review process, HMO requests that the owner/operator of the stationary source arrange for the publication of the required public notifications. Within 5 days, the MMC Chula Vista, LLC, permit #206738, is requested to publish a notice in a local newspaper of general circulation indicating that their RMP update has been submitted to HMO for completeness and technical review. This notice must run for one day and a copy of the Certificate of Publication must be provided to HMO. Attached is a draft copy of how the notice should be published.

HMO is committed to the completion of the RMP review in an expeditious manner. Thank you for your cooperation. If you have any questions please call me at (619) 338-2453. )
!/ '
__ /_./
ark cCabe, MPH, REHS,
Environmental Health Specialist Ill
Ec: John Kolb, Supervising Environmental Health Specialist cc: Danelle Griffin, Environmental Consultant
Rick Brand, Chula Vista Fire Department
Joy Williams, Environmental Health Coalition
File: 206738

CERTIFIED MAIURRR
- 2 - June 27, 2006

COUNTY OF SAN DIEGO DEPARTMENT OF ENVIRONMENTAL

HEALTH NOTICE OF SUBMISSION OF A RISK MANAGEMENT
. PLAN (RMP)
NOTICE IS HEREBY GIVEN that
in accordance with Section
2745.2 of Division 2, Chapter 4.5,
in Title 19 of the California Code
of Regulations, the County of San
Diego Department of
Environmental Health, Hazardous
Materials Division (HMO), has
received an updated certified
Risk Management Plan (RMP)
from the following site:

MMC Chula Vista, LLC
At:
3497 Main Street.

Chula Vista, GA 91911
HMO has initiated the process for"
government and public review.

Interested parties may be added
to a notification mailing list by
submitting . a written request to
the Risk Management Plan
Coordinator, County of San
Diego, Hazardous Materials
Division, P.O. Box 129261, San
Diego, CA 92112-9261.
.. /!#}) flt.r;-/' .2U/Ylsq
2-"D=lb-r-3<f'
ClCountp of 1!\iego
GARY W. ERBECK

DIRECTOR
September 28, 2006
Mr. Martin V. Quinn
Principal, CEO
MMC Chula Vista, LLC
26 Broadway, Suite 907
New York, NY 10004
Dear Mr. Quinn,

DEPARTMENT OF ENVIRONMENTAL HEALTH

HAZARDOUS MATERIALS DIVISION
P.O. BOX 129261, ·SAN DIEGO, CA 92112-9261
(619) 338-2222 FAX (619) 338-2377
1-800-253-9933
DANIEL DeLAURENTIS

ASSIST ANT DIRECTOR
SUBJECT: RISK MANAGEMENT PLAN (RMP) • PUBLIC DOCUMENT FOR AQUEOUS AMMONIA-MMC CHULA VISTA, PERMIT# 206738
The San Diego County Hazardous Materials Division (HMO) is the Administering Agency (AA) for the California Accidental Release Prevention (CaiARP) Program in San Diego County. The HMO has completed a review of the Risk Management Plan (RMP) Public Document update for your facility at 3497 Main Street, Chula Vista, 91911. The document was initially accepted as complete by the HMO soon after construction under the previous ownership. The current document is dated February 2006. As per section 2745.2 (a) (3) of Title 19 in the California Code of Regulations (19 CCR), the following items need to be further addressed, revised, or clarified within the RMP update.

I. RMP Executive Summary: .

Observation: The executive summary states that "The California Office of Emergency Services (OES) is currently undertaking Phase II rulemaking to exempt the use of less than 20% aqueous ammonia solution." Correspondence with OES indicates that they are not preceded with any changes to the current State Regulated Substance List.

Corrective Action: Remove this statement from the executive summary.

Observation: Section 1.4 of the executive summary has a description of the offsite consequence analysis. The requirement to include this in the executive summary was removed for security reasons at both Federally and State regulated stationary sources in 2004.

Corrective Action: Remove section 1.4 from the executive summary.

Observation: 19 CCR 2745.3. Emergency response program (ERP). The ERP is mentioned in the executive summary, but a more detailed summary of your ERP found in Section 9 needs to be included.

Corrective Action: Provide a separate, more detailed summary of your ERP in the executive summary.
"Environmental and public health through leadership, partnership, and science" Mr. Martin Quinn Page2 9/28/2006
II. Registration Information:
• Observation: 19 CCR 27 40.1 The registration information has been submitted in a letter dated January 27, 2006. The NAICS code provided, 2212, is for natural gas distribution.

Corrective Action: Provide a correct NAICS code for this stationary source.

Observation: The HMD has added latitude and longitude data to complete the Program 2 registration submission requirement.

Ill. RMP Offsite Consequence Analysis Component: (OCA)
Observation: The maps of the vulnerability zone, referred to as Figures F-1 and F-2 on page 4.2 are not included in the document. Also Appendices A, B, C, and D mentioned on page 4.2 have not been included. ·
Corrective Action: Provide copies of the vulnerability zones for the worst case and the alternative release and the Appendices mentioned on page 4.2.

Observation: 19 CCR 2745.4. Offsite Consequence Analysis (OCA). The distance to the toxic endpoint was determined to be 213.5 feet in the Chula Vista worst case scenario using the AFTOX method. The distance to the toxic endpoint for the Escondido facility was estimated at 528 feet.

Corrective Action: Provide an explanation on why the two distances are so different when the sources are essentially identical.

IV. RMP Five-year Accident History
Observation: 19 CCR 27 45.5. Assure that the post accident inspection mentioned on page 5-2 includes all the requirements included in 2750.9 (b). A copy of this is available upon request. Currently there is indication that weather conditions or process changes will be noted in the report ..

V. Program 2 Prevention Program
Observation: 19 CCR 27 45. 7(d). Safety information: The date of the most recent review or revision of the safety information has not been provided. Also, no Material Safety Data Sheet (MSDSs) is included in the safety information. This contains valuable safety, emergency response, and first aid information.

Corrective Actions: Provide the date of the most recent review or revision of the safety information and a current MSDS for ammonia hydroxide from your chemical supplier.

Observation: 19 CCR 2745.7 (e) (5). Monitoring and detection systems. Table 6.2 notes that final sensor arrangement and specific equipment are detailed in the RMP Technical Document. The HMD feels this information needs to be included in the RMP Public Document.

Corrective actions: Provide the monitoring and detection equipment information contained in your RMP Technical Document as part of your RMP Public Document.

Observation: 19CCR 2745.6 (h). Maintenance procedures. The date of the most recent review or revision of your maintenance procedures is not included.

Corrective Action: Provide the date of the most recent review or revision of your maintenance procedures.

VI. Emergency Response Program Component
Observation: 19 CCR 2745.8 (3). Informing local and public agencies. The emergency response flow chart on page 9.4 shows the HMO phone number as 619-338-222.

Corrective Action: Change this phone number to 619-338-2222.

Mr. Martin Quinn Page3 9/28/2006
Observation: No information on emergency health care is included in the emergency response plan.

Corrective action: First aid measures are included on an MSDS. Provide emergency health care information for an exposure to aqueous ammonia.

VI. RMP Certificatiqn.

Observation: The February 2006 RMP certification plan is not signed.

Corrective Action: Provide a single certification for the document that, to the best of the signer's knowledge, information, and belief formed after reasonable inquiry, the information submitted is true, accurate, and complete.

Should you need more than 60 days to make these changes, you may request in writing a one-time 30-calendar day extension to correct deficiencies. If you have any questions, please call me at (619) 338-2453.
. Sincerelyib

MPH, REHS
Environmental Health Specialist Ill
ec: John Kolb, REHS, Supervising Environmental Health Specialist cc: Donelle Griffin, Environmental Consulting
Mark Wellard, MMC Chula Vista
Rick Brand, Chula Vista Fire Department
HMO File #: 206738
CERTIFIED MAIURRR ·
GARY W. ERBECK

DIRECTOR
May 5, 2006
Ms. Danelle Griffin
Environmental Consultant
7911 Blue Jay Place
San Diego, CA 92123-3311
Dear Ms. Griffin:

DEPARTMENT OF ENVIRONMENTAL HEALTH

HAZARDOUS MATERIALS DIVISION
P.O. BOX 129261, SAN DIEGO, CA 92112-9261
(619) 338-2222 FAX (619) 338-2377
1-800-253-9933 .

SUBJECT: NOTIFICATION OF FACILITY INSPECTION- MMC CHULA VISTA, LLC, 3497 MAIN STREET, CHULA VISTA, CA 91911, PERMIT NUMBER 139211, DURING THE WEEK OF MAY 8, 2006.

The Hazardous Materials Division (HMO) inspects businesses or facilities, in order to determine compliance with the California Health and Safety Code (H&S) Chapters 6.5, 6.7, 6.95; Titles 19, 22 and 23 of the California Code of Regulations (CCR); and the San Diego County Code (SDCC). This letter is to notify you that the HMO will be conducting a routine compliance and change of ownership inspection of your facility. The inspection will focus on these gener('ll areas:

Site Inspection: An inspection of the facility by a Hazardous Materials Specialist ' (including buildings, equipment, storage areas, work areas, etc.).

Observe hazardous materials and waste storage; handling; container labeling; and waste disposal procedures. ·
Review spill control procedures and spill reporting.

Review and evaluate'hazardous materials that are stored or handled on-site.

Review the Hazardous Materials Business Plan: (Site Map, Emergency Response Procedures, and Employee Training Plan).

Review the hazardous materials training program and documentation (written records).

Review hazardous waste disposal receipts and manifests.

Additionally your facility is subject to the California Accidental Release Prevention (CaiARP) Program regulations under Title 19, Division 2, Chap 4.5, and has submitted a Risk Management Plan (RMP) for a Regulated Substance (anhydrous ammonia) in a Covered Process. For this portion of the inspection the following records will be reviewed:

RMP Public Document, and related Technical Documents
RMP Update Documentation: within 5 years of initial submission, change of owner/ operator, updated registration information, Program level change, (if any).

Revised/Updated Offsite Consequence Analysis (OCA) - every 5 years, or if significant process modification.

Prevention Program 2 Documents: Safety Information, hazard review, operating procedures, training, maintenance, compliance audits, and incident investigations.

Emergency Response Program. ·
Accidental Release Records (if any).
"Environmental and public health through leadership, partnership and science" Ms. Griffin - 2-. May 8, 2006
This notification is intended to better prepare you for the inspection criteria pertaining to the CaiARP Program. I would like to schedule the inspection with you for the week ofMay 8, 2006.

The HMO also recommends you review your RMP public document for other documents · referenced (Operational Procedures, Maintenance Records, Training Programs, etc.) which will be reviewed during the inspection. Depending on the size and complexity of your facility the inspection is expected to take 1-4 days. If you have any questions please call me at (619) 338- 2453. Thank you for your cooperation .

G. McCabe, MPH, REHS
Environmental Health Specialist Ill
Hazardous Materials Division
cc: John Kolb, Supervising Environ·mental Health Specialist Martin Quinn, Principal, Chief Operating Officer
Rick Bryant, Chula Vista Fire Department
HMO File#: 4G1955

CERTIFIED MAIURRR
"Environmental and public health through leadership, partnership and science" GARY W. ERBECK
DIRECTOR •
February 12, 2007
Mr. Martin V. Quinn
Principal, CEO
MMC Escondido
26 Broadway, Suite 907
New York, NY 10004
Dear Mr. Quinn:

Ctr.nuntu .nf c!fli.eg.n

DEPARTMENT OF ENVIRONMENTAL HEALTH

HAZARDOUS MATERIALS DIVISION
P.O. BOX 129261, SAN DIEGO,' CA 92112-9261
(619) 338-2222 FAX (619) 338-2377
1-800-253-9933

JACK MILLER

ASSISTANT DIRECTOR
SUBJECT: RISK MANAGEMENT PLAN (RMP) -LETTER OF COMPLETION FOR MMC ESCONDIDO, PERMIT #206739
This is to notify you that the San Diego County Hazardous Materials Division (HMO) has accepted the RMP for the MMC Escondido, LLC. Pursuant to Section 25535.2 in Article 2 of the California Health & Safety Code, Chapter 6.95, within 15 days your RMP must be made available for public review.

The MMC Escondido, LLC is required to publish a notice in a local newspaper of general circulation indicating that their RMP is available for the 45-day public review period. This notice must run for one day and a copy of the Certificate of Publication and published notice must be provided to HMO. Below is a draft copy of how the notice should be published. The 345-day public review period will begin upon publication of this notice.

COUNTY OF SAN DIEGO DEPARTMENT OF ENVIRONMENTAL HEALTH
(DEH)

NOTICE OF AVAILABILITY FOR REVIEW OFA RISK MANAGEMENT PLAN (RMP)
NOTICE IS HEREBY GIVEN that in accordance with Section 25535.2 of Article 2 in Chapter 6.95 of the California Health & Safety Code, DEH, Hazardous Materials Division (HMO), has determined that the RMP from the MMC Escondido, 1968 Don Lee Place, Escondido, CA 92029 for aqueous ammonia is complete and will be available for review and comment by interested persons and public groups for45 days after the publishing of this notice. For an appointment to review the RMP please call (619) 338-2268 at the HMO office, 1255 Imperial Ave., 3rd Floor, San Diego, California between the hours of 8:00 AM and 5:00 PM. All written comments shall be addressed to the Risk Management Plan Coordinator, County of San Diego, Hazardous Materials Division, P.O. Box 129261, San Diego, CA 92112-9261 no later than 45 days of the publication of this notice.
"Environmental and public health through leadership, partnership and science" * -2- January 26, 2007
The HMO will respond in writing to all comments submitted. The MMC Escondido, LLC, will be required to address appropriate concerns raised by public comment and revise the RMP accordingly.

Due to federal regulations and State concerns the off-site consequence analysis information may be reviewed but not duplicated during public review.

If you have any questions please call me at (619) 338-2453. Thank you for your cooperation. ark McCabe, MPH, REHS
Environmental Health Specialist Ill
ec: John Kolb, Supervising Environmental Health Specialist cc: Danelle Griffin. Environmental Consultant
Michael Lowry, Escondido Fire Dept.

Joy Williams, Environmental Health Coalition
HMO File #: 206738

CERTIFIED MAIURRR
"Environmental and public health through leadership, partnership and science" GARY W. ERBECK

DIRECTOR
February 12, 2007
Mr. Martin V. Quinn
Principal, CEO
MMC Chula Vista
26 Broadway, Suite 907
New York, NY 10004
Dear Mr. Quinn,
O!nuntu nf

DEPARTMENT OF ENVIRONMENTAL HEALTH

HAZARDOUS MATERIALS DIVISION
P.O. BOX 129261, SAN DIEGO, CA 92112·9261
(619) 338·2222 FAX (619) 338·2377
1·800·253-9933

JACK MILLER

ASSISTANT DIRECTOR
SUBJECT: RISK MANAGEMENT PLAN (RMP) -LETTER OF COMPLETION FOR MMC CHULA VISTA, PERMIT #206738
This is to notify you that the San Diego County Hazardous Materials Division (HMD) has accepted the RMP for the MMC Chula Vista, LLC. Pursuant to Section 25535.2 in Article 2 of the California Health & Safety Code, Chapter 6.95, within 15 days your RMP must be made available for public review.

The MMC Chula Vista LLC, is required to publish a notice in a local newspaper of general circulation indicating that their RMP is available for the 45-day public review period. This notice must run for one day and a copy of the Certificate of Publication and published notice must be provided to HMD. Below is a draft copy of how the notice should be published. The 45-day public review period will begin upon publication of this notice.

COUNTY OF SAN DIEGO DEPARTMENT OF ENVIRONMENTAL HEALTH
(DEH)

NOTICE OF AVAILABILITY FOR REVIEW OF A RISK MANAGEMENT PLAN (RMP)
NOTICE IS HEREBY GIVEN that in accordance with Section 25535.2 of Article 2 in Chapter 6.95 of the California Health & Safety Code, DEH, Hazardous Materials Division (HMD), has determined that the RMP from the MMC Chula Vista, LLC, 3497 Main Street, Chula Vista, CA 91911 for aqueous ammonia is complete and will be available for review and comment by interested persons and public groups for 45 days after the publishing of this notice. For an appointment to review the RMP please call (619) 338-2268 at the HMD office, 1255 Imperial Ave., 3rd Floor, San Diego, California between the hours of 8:00 AM and 5:00 PM. All written comments shall be addressed to the Risk Management Plan Coordinator, County of San Diego, Hazardous Materials Division, P.O. Box 129261, San Diego, CA 9211.2-9261 no later than 45 days of the publication of this notice.
"Environmental and public health through leadership, partnership and science" * - 2 - January 26, 2007
The HMD will respond in writing to all comments submitted. The MMC Chula Vista, LLC, will be required to address appropriate concerns raised by public comment and revise tlie RMP accordingly.

Due to federal regulations and State concerns the off-site consequence analysis information may be reviewed but not duplicated during public review.

If you have any questions please call me at (619) 338-2453. Thank you for your cooperation.

Ma e, MPH, REHS
Environmental Health Specialist Ill
ec: John Kolb, Supervising Environmental Health Specialist cc: Donelle Griffin, Environmental Consultant
Rick Brand, Chula Vista Fire
Joy Williams, Environmental Health Coalition
HMD File #: 206738

CERTIFIED MAIURRR
"Environmental and public health through leadership, partnership and science" -. .

GARY W. ERBECK

DIRECTOR
QCountp of SS,an Jltego

DEPARTMENT OF ENVIRONMENTAL HEALTH

HAZARDOUS MATERIALS DIVISION
P.O. BOX 129261, SAN DIEGO, CA 92112·9261
(619) 338·2222 FAX {619) 338·2377
1·800·253·9933

JACK MILLER
Assistant Director
Dec.28,2007
Mr. Mark Weller
Facility Operator
MMC Energy Chula Vista, LLC
3497 Main Street
Chula Vista, CA 91911
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:#zot138
SUBJECT: NOTIFICATION OF FACILITY INSPECTION- MC ENERGY CHULA VISTA, LLC PERMIT #206738 ON JANUARY 3, 2008.

Dear Mr. Weller,
The Hazardous Materials Division (HMO) inspects businesses or facilities, in order to determine compliance with the California Health and Safety Code (H&S) Chapters 6.5, 6.7, 6.95; Titles 19, 22 and 23 of the California Code of Regulations (CCR); and the San Diego County Code (SDCC).

The inspection will focus on these general areas:

Site Inspection: An inspection of the facility by a Hazardous Materials Specialist (including buildings, equipment, storage areas, work areas, etc.). o Observe hazardous materials and waste storage, handling, container labeling, and waste disposal procedures.
o Review spill control procedures and spill reporting.
o Review and evaluate hazardous materials that are stored or handled on-site.

Review the Hazardous Materials Business Plan: (Site Map, Emergency Response Procedures, and Employee Training Plan).

Review the hazardous materials training program and documentation (written records).

Review hazardous waste disposal receipts and manifests.

Additionally your facility is subject to the California Accidental Release Prevention (CaiARP) Program regulations under Title 19, Division 2, Chap 4.5, and has submitted a Risk Management Plan (RMP) for a Regulated Substance (aqueous ammonia) in a Covered Process. For this portion of the inspection the following records will be reviewed:

RMP Public Document, and related Technical Documents
RMP Update Documentation: within 5 years of initial submission, change of owner operator, updated registration information, and Program level change, (if any).

Revised/Updated Offsite Consequence Analysis (OCA) - every 5 years, or if significant process modification.

Prevention Program 2 Documents: Safety Information, Hazard Review, Operating Procedures, Training, Maintenance, Self-Compliance Audits, and Incident Investigation.
... - . -. ,
NOTIFICATION OF FACILITY INSPECTION - 2- December 28, 2007 This notification is intended to better prepare you for the inspection of your CaiARP and hazardous material management programs. I plan to be at your facility on January 3, 2008. also recommend you review your RMP public document for other documents referenced (Operational Procedures, Maintenance Records, Training Programs, etc.) which may be reviewed during the inspection. Depending on the size, and complexity of your facility the inspection is expected to take 1-2 days. If you have any questions please call me at (619) 338- 2453. Thank you for your cooperation.

Sincerely,
Cc: File 206738
•
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•
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' I
Risk Coordinator
County of San Diego HaV!rdous Materials Division
PO Box 129261
FEB 1 9 2008
San Diego, CA 92112-9261 LJf.e,... .- /), I / ..._..,.,. e r-; /If' RE: CVEUP, peaker at 3497 Main St., Chula Vista 91911 Facility 206738 n.

To Whom It May Conwtn: CJ8
Having reviewed these I have some comments that I would like to.be part of the public record. On page 4-3 Results (Zone of Vulnerability) I question the adequacy of the determination of the endpoints of the zone of vulnerability.

I. I was told that the polyballs were the reason for these short distances. It is my belief that MMC should not be given credit for the poly-balls since they are a "controversial technology" that has not been proven to actually contain spills in real life. If the county's intent is to actually protect sensitive receptors a worst-case spill, a worst-case spill must be modeled for. This would mean the poly-balls.

2. At one time this plant was surrounded by junkyards. This is no longer the case. To the •
west is Meat with 71 who are in and out of the parking lot all day loading and unloading trucks. Many of these people are within 213.5 feet of the ammonia tank. If the 1,000-foot distance that should be used were used there are 45-50 homes within this distance. To the east are new light industrial condos occupied by more commercial businesses that are within 213.5 feet of this tank. These employees, in order to escape in an emergency would need to enter the lot their vehicles are within these 213.5 feet. If 1,000 feet is used the entire building next door with all the employees would be within the danger zone. This simply is an unacceptable risk for too many people.

3. The MSCP preserve OVRP is to the south. It is within 213.5 feet from the tank. It is incon-ect to say are no ecOlogical receptors within this distance. There is also a plan to put a trail near here, so may at times be people as well. Only to the north is 213.5 feet within the fence line.

White line was measued in Google Earth as 211.6 feet. Picture in file is not accurate. Applicant should supply a current aerial photo showing current and conditions. The one in the
file is totally inadequate.

Sincerely,
eresa Acerro
POBox8697
Chula Vista, CA 91912
•
cc. CEC Christopher Myers, Project Manager
California Energy Commission
1516 9th
Sacramento, CA 95833
•
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,
tt
GARY W. ERBECK

DIRECTOR DEPARTMENT OF ENVIRONMENTAL HEALTH

HAZARDOUS MATERIALS DIVISION

JACK MILLER
Assistant Director
August 13, 2008
P.O. BOX 129261, SAN DIEGO, CA 92112·9261
(619) 338·2222 FAX (619) 336·2377
1·600·253·9933
•
Mr. Mark Weller
Facility Operator
MMC Energy Chula Vista, LLC
3497 Main Street
/?.1t!-­
Chula Vista, CA 91911
SUBJECT: NOTIFICATION OF FACILITY INSPECTION·
PERMIT #206738 ON AUGUST 21, 2008.

Dear Mr. Weller,
•

ENERGY CHULA VISTA, LLC
The Hazardous Materials Division (HMO) inspects businesses or facilities, in order to determine compliance with the California Health and Safety Code (H&S) Chapters 6.5, 6.7, 6.95; Titles 19, 22 and 23 of the California Code of Regulations (CCR); and the San Diego County Code (SDCC).

The inspection will focus on these general areas:

Site Inspection: An inspection of the facility by a Hazardous Materials Specialist (including buildings, equipment, storage areas, work areas, etc.). o Observe hazardous materials and waste storage, handling, container labeling, and waste disposal procedures.
o Review spill control procedures and spill reporting.
o Review and evaluate hazardous materials that are stored or handled on-site.

Review the Hazardous Materials Business Plan: (Site Map, Emergency Response . Procedures, and Employee Training Plan).

Review the hazardous materials training program and documentation (written records).

Review hazardous waste disposal receipts and manifests.

Additionally your is subject to the ia Accidental Release Prevention (CaiARP) Program regulations under Title 19, Division 2, Chap 4.5, and has submitted a Risk Management Plan (RMP) for a Regulated Substance (aqueous ammonia) in a Covered Process. For this portion of the inspection the following records will be reviewed:

RMP Public Document, and related Technical Documents
RMP Update Documentation: within 5 years of initial submission, change of owner operator, updated registration information, and Program level change, (if any).

Revised/Updated Offsite Consequence Analysis (OCA) - every 5 years, or if significant process modification.

Prevention Program 2 Documents: Safety Information, Hazard Review, Operating Procedures, Training, Maintenance, Self-Compliance Audits, and Incident Investigation.
•
•
'
NOTIFICATION OF FACILITY INSPECTION - 2- August13,2008
This notification is intended to better prepare you for the inspection of your CaiARP and hazardous material management programs. I plan to be at your on August 21, 2008. I '
also recommend you review your RMP public document for other documents referenced (Operational Procedures, Maintenance Records, Training Programs, etc.) which may be reviewed during the inspection. Depending on the size, and complexity of your facility the inspection is expected to take 1 days. If you have any questions please call me at (619) 338- 2453. Thank you for your cooperation.

Sincerely,
Mar G. McCabe, MPH, REHS
Environmental Health Specialist Ill
Hazardous Materials Division
Cc: Donelle Griffin, Environmental Consulting
File 206738
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COUNTY
E TEREO OCT 2 I 2008

F SAN DIEGO

BUSINESS NAME

ADDRESS

CITY/ZIP
• MMC Energy Chula Vista
Chula Vista, CA 91911
PAGE 1 ofl /of??
EST. NO. 206738
DATE 8/21/0&
TIME START 8:00 END 14:00
BUS. CODE K65
SPECIALIST M. McCabe
CONTACT Donelle Griffin
TITLE
PHONE 619-420-3291
On the above date, an inspection of your business/facility was conducted in order to dete1mine compliance with the California Health and Safety Code (HCS) Chapters 6.5, 6.7, 6.95; Titles 19, 22 and 23 of the California Code of Regulations (CCR); and the San Diego County Code (SDCC).

The following remarks are intended to provide guidance to correct the violations noted on the attached violation report.

NOTE:

Routine compliance inspection conducted today. Pennission to inspect granted by Donelle Griffin.

No violations were observed today.
•
A current site map and Hazardous Materials Business Plan certification received today.

The ownership change back in 2006 caused a new facility permit number to be generated for this site. Correspondence sent to the old permit number were not logged into your current facility probably was sent to the inactive file and not the current facility file. Please use facility permit number 206738 for all correspondence with this office.

A Spill Prevention Control and Counte1measure Plan was seen on site today.

Advanced Clean Up Technologies is the current hazardous waste hauler. RECEIVED SEP 1 6 2008 Employee training was conducted on June 12, 2008.

This facility has a current, approved Risk Management Plan on file with this office. Please your three year requirement for risk management training and compliance audits. Your hazard analysis and Risk Management Plan must be reviewed and updated as needed every five years. ·
Title of Business Representative
Department of Environmental Hazardous Materials Division, P.O. Box 129261, San Diego, CA 92112-9261; (619)338-2222 (11/03)
•
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COUNTY OF SAN DIEGO

BUSINESS NAME

ADDRESS
CITY/ZIP_
• .,
COMPLIANCE INSPECTION REPORT - . . . -
• •
PAGE _LoF L DATE
PERMIT# .213&
TIME START /eo END • .._? 47
I
BUS. CODE J ,._._.

SPECIALIST c:

INSPECTION CONTACTrriTLE
OoQt?eJ# _{}r/(>8';.;
PHONE: (&'>S$- ].5$-'- cf9<f5
On the above date, an inspection of your business/facility was conducted in order to determine compliance with the California Health and Safety Code (HSC) Chapters 6.5, 6.7, 6.95; Titles 19,22 and 23 of the California Code of Regulations (CCR); and the San Diego County Code (SDCC).

The following remarks are intended to provide guidance to correct the violations noted on the attached violation report. ..

NOTE:

Y N/A
D D
D D
D D
D D
D D
D D
Unified Program Facility Permit current and available
Hazardous Materials Business Plan available
Employee Training is adequate
Waste disposal records available for review
Emergency contacts current D Updated today
Chemical inventory current D Updated today
•
y
D
D
D
D
D
Date Signed
N/A
D
D
D
D
D
Permit Expires on: 0! I ?II D &
Contingency Plan available
Employee Training records available
Waste containers kept closed
Waste containers kept labeled
Waste containers in good condition
Initials of Business
Title of Business Representative
Department of Health, Hazardous Materials Division, P.O. Box 129261, San Diego, CA 92112-9261 L-------=-P:::ho::.:n:::e.:_: =<-== '-="=-..:..F=ax:.:..: 338-2377 HM-924 (12/06) NCR DISTRIBUTION: WHITE-RETURN TO HMO; YELLOW-BUSINESS RETAINS • •
'
COUNTY OF SAN DIEGO PERMIT# z.a6=t.sg
DATE R I .Z} !<?&
PAGE ( r OF I =
'
BUSINESS ADDRESS:

VIOLATION REPORT: The items checked below refer to specific section numbers of Title 19 of the California Code of Regulations (CCR), Chapter 6. 95 of the Health and Safety Code (HSC), and/or the San Diego County Code (SDCC).

All violations must be corrected. Submit documentation of return to compliance to your Specialist. You may use the Corrective Action Form to document your return to compliance. Your Specialist can provide these forms. Please call (619) 338-2222 or your Specialist if you have any questions.

The following abbreviations are used throughout this document: SS=Stationary Source; 0/0=0wner/Operator; C Viol VIOL VIOLATION DESCRIPTION · Viol VIOL VIOLATION DESCRIPTION # General Requirements # Compliance Audits 2755.6
D V2501 Stationary Source did not prepare RMP, RS(TI,2). 2735.4 D V2668 Owner/Operator did not meet audit requirements. 2755.6 1---l 0 V2502 General requirements not met by owner/operator. 2735.5 D V2669 Owner/Operator did not certify the audit 2755.6(a) 0 V2503 P2-ER program not implemented by 0/0. 2535(e)(4) D V2670 Owner/Operator did not respond to audit findings. 2755.6(d) 1---l 0 V2504 Hazard Assessment not done by O/O-P3. 2535(1)(2) D V2671 Did not keep 2 most recent audit reports. 2755.6(e) D V2505 Prev. program requirements not implemented. 2535(1)(3) Incident Investigation D V2506 ER Program not implemented P3. 2535(1)(4) I I 0 V2672 0/0 did not meet incident investigation req. 2755.7 0 V2507 Management System not developed by 0/0. 2735.6
D V2508 Registration information not submitted. 2740.1
RMP Submission 2745.1
D Y2509
------j D Y2510
RMP not submitted by owner/operator. 2745.1
RMP not certified complete by 0/0. 2745.2(a)
Corrections on deficiency notice not done. 2745.2(a) _ __, D V2511 __ 0 V2512 30-day extension for corrections not requested. 2745.2(a) RMP Updates 2745.10
1---1 0 Y2601 RMP not updated by Owner/Operator. 2745.10 1---l 0 V2602 RMP not updated within 5 years of submittal. 2745.10 0 V2603 RMP level not updated within 6 months of change. 2745.10 f---1 D V2604 RMP not updated prior to having RS onsite. 2745.10 RMP not updated w/i 30 days of0/0 change. 2745.10(1) L___J D V2605 OCA-Offsite Consequence Analysis 2750.7-8
1---l 0 V2609 Offsite Consequences not rev/updated e/5 yrs. 2750.7(a) 0 Y2610 Offsite Cons. no rev/upd w/i 6 mo. of change. 2750.7(b) 1---l 1----l 0 Y2611 Rev OCA not sent to HMD w/i 6 mo. of change. 2750.7(b) D Y2612 Offsite Consequences documents not kept by 0/0. 2750.8 ARTICLE 5: Prevention Program 2
Safety Information 2755.1
__ 0 V2651 0/0 did not compile/maintain safety information. 2755.1 __ 0 V2652 0/0 did not update safety info.-major changes. 2755.(c) Hazard Review 2755.2
0 V2653 0/0 did not meet all hazard review requirements. 2755.2 ---- 0 V2654 0/0 did not doc. & correct hazard review issues. 2755.2(e) __ 0 Y2655 0/0 id not complete/update hazard review el5yrs. 2755.2(1) Operating Procedures 2755.3
1------, D V2656 010 did not meet operating procedure requirements. 2755.3 1---l D V2657 0/0 did not prepare operating procedures .. 2755.3(a) '------' 0 V2658 0/0 did not update operating procedures. 2755.3(c) Training Program 2755.4
D V2659 0/0 did not meet training program requirements. 2755.4 D V2660 Present/new employees not trained-on op. proced. 2755.4(a) D V2661 Did not do refresher training every 3 years. 2755.4(b) D V2662 Employees not trained on updated/new procedures 2755.4(d) Maintenance 2755.5
D Y2663
D V2664
1---l D V2665
1---l D Y2666
'---' D V2667
010 did not meet maintenance program req. 2755.5
010 did not prepare integrity procedures. 2755.5(a)
010 did not train on integrity procedures. 2755.5(b)
Contractor did not train employees. 2755.5(c)
Did not inspect and test equipment. 2755.5(d)
de 0' ·

SIGNATURE OF B SINESS REPRESENTATTVE
ARTICLE 6: Prevention Program 3
1---l 0 V2701 0/0 did not meet requirements for PSI Info. 2760.1 '---' 0 Y2702 Owner/Operator did not meet PHA req. 2760.2 Operating Procedures 2760.3
1---l 0 Y2703 0/0 did not meet Operating Procedure Requirem. 2760.3 1---l 0 Y2704 0/0 did not prepare OF-procedures. 2760.3(a) 0 V2705 OP-procedures not accessible to employees. 2760.3(b) r----1 '----' 0 V2706 0/0 did not annually certify OF-procedures. 2760.3(c) '
Training Program 3. 2760.4
0 Y2707 0/0 did not meet training program requirements. 2760.4 '
0 V2708 0/0 did not provide initial training. 2760.4(a)(l) 0 Y2709 0/0 did not provide refresher training. 2760.4(b) . 0 V2710 0/0 did not maintain training documentation. 2760.4(c) Mechanical Integrity 2760.5
0 Y2711 0/0 did not meet Mechanical Integrity requirements. 2760.5 0 Y2712 0/0 did not establish integrity procedure. 2760.5(b) 0 V2713 0/0 did not train each employee on integrity proc. 0 V2714 Test frequency inadequate. 2760.5(d)(3)
D
D
Y2715 Inadequate documentation of inspections/tests. 2760.5(d)(4) V2716 0/0 did not correct equipment deficiencies. 2760.5(e) Management of Change 2760.6
0 V2717 0/0 did not meet management change requirements. 276o.6 __ D Y2718 Did not establish procedures for manag. Changes. 2760.6(a) Pre-Startup Review 2760.7
•
t-- 0 V2719 0/0 did not meet pre-startup safety review Req. 2760.7 D V2720 0/0 did not do PHA prior to startup. 2760.7(b)(3) !--.., D Y2721 S-review did not include employee training. 2760.7(b)(4) Compliance Audits 2760.8
1---l 0 V2722 Did not meet audit requirements. 2760.8
1---1 D Incident Investigation 2760.9
1---l 0 V2723 0/0 did not meet incident investigation requirem. 2760.9 '----' 0 V2724 0/0 id not retain investigation reports for 5 yrs. 2760.9(g) ['-_,I D
1'------'1 D
Employee Participation. 2760.10
Y2725 Employee participation plan requirements not met. 2760.10 '
Hot Work (HW) Permit. 2760.11
Y2726 0/0 d1d not meet work pel mit requirements. 2760.11 Contractors 2760.12
I I 0 V2727 Did not meet contractor safety requirements. 2760.12(b)(l) Contract Owner (CO)/Operator Responsibilities.1260.12(c) 1---l 0 Y2728 CO did not meet contract operator responsibility 2760.12(c) '---' 0 V2729 CO training documentation not maintained. 2760.12(c)(3) ARTICLE 7: Emergency Response Program
D V2801 0/0 did not implement Emerg. Response Plan. 2765.1(a) L.,___j 0 V2802 ERplan not cord wplan, Sec 11003 Ti42 USC. 2765.2(c) '
DATE SIGNED TITLE OF BUSINESS REPRESENTATIVE •
DEH:HM-922 (Revised 07103) NCR DISTRJBUT!ON: WlllTE·RETIJRN TO !!MD: YELLOW-BUSINESS RETAINS (
' '
20 08 02:41a
0 JNS'l'KVc'I'IONS
TO cY.'&R'rCAL
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Danelle Grif'f'in
3 7 0
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858-278-9170 p.3
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dNit a complete BMBP,
pleD, and cmpiii,Y\IC
......

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S/1512008
--- -·- _ .... _ .-·-£u uo UUite .&. .1. e' Ull .1. I I ..1. I I ' ' .
•
May 15,2008
Mark McCabe
County of San
Deparlmeot
Hanudons Mata1als
PO Box 129261
San Diego, CA 92112-9261
7')11 m.e Jay
San CA 92121-JJJJ
Health
Division
• • • • •• • .. -- . . . .. . "• . . . . . . . . -- ' . . . . . . ' •. . ' . . • • ; -' . : ' ' • • •
•
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Subject: MMC Chula Vista, LLC (139211) and MMC Escondido. LLC (101955) •
•
The MMC Cbula Vista, I .I.C and MMC ElK:ondido, I .I C Hazardous Business Plans have and updated. On behalf ofMMCl am submittiog two Chemical Inventory Forms additional a& Lhe Chula Vista Facility. The annual HMBP fur sires. is also feel to me if you have any
Consulting
858-354 4995
Cc: Harry MMC I I C
Mark Wellard. MMC Chula Vista. I I C
Ryan LLC
•
•
•
• •
•

SAN DIEGO COUNTY
NTEREO :.J'i 0 7
OF ENVIRONMENTAL BEAL'ffi-CUPA

MATERIALS DIVISION
.0. BOX 129261, SAN DIEGO, CA 92112-9261
1-800-253-9933 (619) 338-2222 FAX (619) 338-2377
PLAN
The San • as the administering agency,
requires a business that handles hazardous materials to submit the hazardous materials inventory, a list of emergency contacts, and a site plan, in lieu of a complete Hazardous Materials Business Plan (HMBP), only after the initial submittal of a complete HMBP, The business must certify that a complete HMBP has been prepared and is maintained at the site where the hazardous materials are stored. A complete HMBP includes the items to be submitted to the HMO and an Emergency Response Plan and Employee Training Plan, as established in H&SC Section 25504. The business must also annually certify that the HMBP is current and maintained on site. See Back for instmctions and tlirther clarilication.

I FACIUTYID# 3 7 0 0 0 1
BUSINESS NAME (Same" FACILITY NAME or DBA- D<q Business As) MMC Chula Vista, LLC

BUSINESS ' ----------------------------------------------------------------------------- 3497 Main Street
CA
II. CERTIFICATION STATEMENT

ZIP CODE
0 CARCINOGEN/REPRODUCTIVE TOXIN ANNUAL RENEWAL WflBOUT CHANGES: This is an annual renewal to certizy that the list of carcinogens and/or reproductive toxins last provided is a current list as specified in the San Diego County Code of Ordinances Section 68.1113.

Check only one of the foUowing boxes:
0 INITIAL CERTIFICATION: This is to certify (H&SC Section 25505(e)(l)) that a complete HMBP, which includes the hazardous materials im·entory, a list of emergency contacts, a site plan, emergency response plan, and employee training plan, has been prepared and is maintained at the site where the hazardous materials are stored. 0 ANNUAL CERTIFICATION WITHOUT CHANGES: This is an annual certification (H&SC Section 25505(d)&(e)(2)) that the Hl\IBP, which includes the hazardous materials im·entory, a list of emergency contacts, a site plan, response plan, and employee training plan, is current and includes all the information required in H&SC Section 25504, and 25509, and-is maintained at the site where the hazardous materials are stored.
[81 CERTIFICATION OF CHANGES/REVISIONS: This is to certit)' that the mmP has been m·iewed (H&SC Section 25505(c) & 2551 0) and all necessary changeslre\'isions han been made. The Hl\IBP is current and is maintained at the site where the hazardous materinls are stored. Attached are changes to the hazardous materials im·entory· and/or list of emel'llency contacts. For site map re,·isions, submit only the pages that ha\'e a or re\'ision and attach to this certification. This submittal satisfies annual certification requirements specified in H&SC Section
As an Authorized Representotil·e, I certitY under the penalty of law, that I haw examined and am familiar \\ith the infounation submitted and beliew the information is true, accurate, and complete. By checking of the boxes abow I also that : a) The information contained in the hazardous materinls inventory most recently submitted to the CUP A or Administratil·e is complete, accurate, and up to date; b) There has been no change in the quantity of hazardous materials reported in the most recently submitted innntory·; and c) AU hazardous materinls subject to innntory· are listed on the most submitted

SIGNATURE
NAME
Harry
0 F
F
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INSTRUCTIONS

TO CLERICAL
STAFFFORimmP

ACCEPTANCE
SHE
FIRE DIST. __

REPRESENTATIVE
D SiteMap
D *Emergency Contacts
&Chemical Inventory
DATE
5/1512008
TI1LE OF SIGNER
Vice President Business Development
__ ! _ ___, __ •Noee: Imi<>de lhe date that the invenlnty and/or ER ooola<t infurmation in the KIVA database was reviewed and clvmges \\\Je ,.,bmi111ld fur fJIOOffl.sing. If the inventory and ER coo1l!d infurmation aie cxadly the same as it is reconllld in KIVA, no changes need to be submilh J.

Hazardous Materials Business Plan acceptance date will be changed to the acceptance date on new site map.

A letter will be mailed to business after processing of site map updates.

Specialist's Signature: (only required for new plans or for changes to site maps, chemical inventory and/or emergency cootacts) REMARKS: ----------------------------------------------------- • • •< '
GARY W. ERBECK

DIRECTOR
March 11, 2008
Mr. Harry Scarborough
an • J:;: • t.egn

DEPARTMENT OF ENVIRONMENTAL HEALTH

HAZARDOUS MATERIALS DIVISION
P.O. BOX 129261, SAN DIEGO, CA 92112·9261
(619) 338·2222 FAX (619) 338·2377
1·800·253-9933
Vice President, Business Development
MMC Energy North America, LLC
26 Broadway, Suite 960
New York, NY 10004
Dear Mr. Scarborough:

JACK MillER
Deputy Director
SUBJECT: RISK MANAGEMENT PLAN PUBLIC DOCUMENT FOR AQUEOUS AMMONIA, MMC ENERGY CHULA VISTA, PERMIT #206738
This letter is to inform you that the Department of Environmental Health, Hazardous Materials Division (HMO) has completed the Formal Public Review period of the Risk Management Plan (RMP) Public Document for the MMC Energy, Chula Vista, at 3497 Main Street, Chula Vista, CA 91911. There were no public comments received by this department during the Formal Public Review; however, the RMP will remain available for public information requests and HMO will consider all public comments.

The RMP is now in the Evaluation Review period of the RMP Review Process. During the Evaluation Review period, any public comments which may be received will be reviewed and addressed and a facility inspection or audit will be conducted to verify the level of implementation and accuracy of the RMP.

If you have any questions I can be reached at (619) 338-2453. ark McCabe, M H REHS
Hazardous Materials Division
cc: Rick Brand, Chula Vista Fire Department
Danelle Griffin, Environmental Consulting
Joy Environmental Health Coalition
File: 206738

CERTIFIED MAIL//RRR
"Environmental and public health through leadership, partnership and science"

SAN DIEGO COUNTY

DEPARTMENT OF ENVIRONMENTAL HEALTH-CUP A
APR 1 6 2009 OUS MATERIALS DMSION
P.O. BOX 129261, SAN DIEGO, CA 92112-9261
1-800-253-9933 (619) 338-2222 FAX (619) 338-2377 NMENTAL HEAL The California Health & Safety Code (H&SC), Division 20, Chapter 6.95, Section 25505 provides for the followjng:

The San Diego County, Department of Environmental Health, Hazardous Materials Division (HMD), as the administering agency, requires a business that handles hazardous materials to submit the hazardous materials inventory, a list of emergency contacts, and a site plan, in lieu of a complete Hazardous Materials Business Plan (HMBP), only after the initial submittal of a complete HMBP. The business must certify that a complete HMBP has been prepared and is maintained at the site where the hazardous materials are stored. A complete HMBP includes the items to be submitted to the HMO and an Emergency Response Plan and Employee Training Plan, as established in H&SC Section 25504. The business must also annually certify that the HMBP is current and maintained on site. See Back for instructions and filrther clarification.
-------- --r-- _ --r-- --,--_.:.;..I. __ -----------1
FACILITY ID# 3 7 0 0 0 2 0 6 7 3 8
(Sarno u FACILITY NAME or DBA- Doing Business A<)
MMC Chula Vista, LLC
------------------------------------------------------------- CA ZIP
II. CERTIFICATION STATEMENT
0 CARCINOGEN/REPRODUCTIVE TOXIN ANNUAL RENEWAL WITHOUT CHANGES: This is an annual renewal to certify that the list of carcinogens and/or reproductive toxins last provided is a cunent list as specified in the San Diego County Code of Regulatory Ordinances Section 68.1113.

Check only one of the following boxes: ·
0 INITIAL CERTIFICATION: This is to certify (H&SC Section 25505{e){l)) that a complete HMBP, which includes the hazardous materials im·entory, a list of emergency contacts, a site plan, emergency response plan, and employee training plan, has been prepared and is maintained at the site where the hazardous materials are stored. [8l ANNUAL CERTIFICATION WITHOUT CHANGES: This is an annual certification {H&SC Section 25505(d)&(e)(2)) that the HMBP, which includes the hazardous materials in\'entory, a list of emergency contacts, a site plan, emergency response plan, and emplone training plan, is current and includes all the information required in H&SC Section 25504, and 25509, and is maintained at the site where the hazardous materials are stored.
0 CERTIFICATION OF CHANGES/REVISIONS: This Is to certif)· that the HMBP has been re,·iewed (H&SC Section 25505(c) & 25510) and all necessary changes/revisions ha\'e been made. The HMBP is current and is maintained at the site where the hazardous materials are stored. Attached are changes to the hazardous materials im•entory and/or list of eme11ency contacts. For site map re\'isions, submit only the pages that ha\'e a or re,·ision and attach to this certification. This submittal satisfies annual certification requirements specified in H&SC Section
As an Authorized I ce1 til)' under the penal!)· of law, that I have personally examined and am familiar \\ith the information submitted and belie\'e the information is true, accurate, and complete. checking any of the boxes abon I also that : a)The information contained in the hazardous materials innntory· most recently submitted to the CUPA or Administrati\'e Agency is complete, accurate, and up to date; b) There has been no change in the quanti!)' of hazardous materials reported in the most recently submitted ianntory·; and c) All hazardous materials subject to ia\·entory· are listed on the most submitted
Donelle W. Griffin
0 F
F
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••

INSTRUCTIONS

TO CLERICAL

STAFF FOR HMBP

ACCEPTANCE
lllRT SI'IE1l!*
FIRE DIST. fZ (

REPRESENTATIVE
Et SiteMap
B'*Emergency Contacts
B""Chemical Inventory
DATE
4/16/2009
TI1LE OF SIGNER
Environmental Consultant
•Nore: Indicate the dale that the inventory and/or ER CO!Jiart infunna1ion in the KIVA da1Bhase was reviewed and changes v.ue submittlld forpoces'ling. If the inventory and ERcontart infunnalion are exactly the Sllllle as it is recorded in KIVA, no changes need to be submittlld.

Hazardous Materials Business Plan acceptance date will be changed to the acceptance date on new site map.

A letter will be mailed to business after processing of site map updates.

Specialist's Signature: (only required for new plans or for changes to site maps, chemical inventory and! or emergency conlacts) r\1 tn
•

FACILITY

ADDRESS

CITY/ZIP

COUNTY OF SAN DIEGO

I COMPLIANCE INSPECTION REPORT I
NAME Chula Vista Energy Center
3497 Main Street
Chula Vista /92029
PAGE 1 OF 3 DATE 6/6/2014 - --
RECORDID# DEH2011-HUPFP-214305

TIME START END
SPECIALIST M. Maschue

INSPECTION CONTACT
Genevieve Huffman
TITLE Environmental Specialist
PHONE (530) 755-3280
On tbe above date, the ,mmty inspected your fucility under the aulhodly of the CalifomiaJieallh and Safety Code (l-1& C), to dctcnninecompliancewiUJ applicable provisio11S oftlle H&SC, the Califomia COde of Regulations (CCR), and tlte Sru1Diego Cmmty Code of Regulatory Ordimmces ( DCC). Th is report serves 11s a Notice to Comply (fl& C 25187.8 & 25404 .1.2) for any minor viohttions as defined in H&SC 25404 and 25117.6. This repo1t may contain boU1 minor and more sigttificanl (Class U) violations. Minor violations do not include repeat violations or violations remaining uncorrected for more Utrut 30 days (or as specified below). Minor violations do not include knowillg, wi ll ful intentional or chronic violations; nor do they in.clude violations a pattern of neglect or disregard. The l'elllarks below are intended to provide guidwtce to con·eot any violations indicated on Ute attEtched violation report. You must submit a written response to this rcp(Jrt within 30 days (or as speoi tied below) demonstraling that all violations hove been corrected or include a written notice of d isagreemenL Utat clearly slates the reason for uny disputed violations. Prompt correction can protect you from penalties for a "n1inor violation". Penalties can be imposed for each day in violation tor all other violations cvc11 if they are corrected promptly. However, correction within 30 clays (or as specified below) wiU make a penalty less likely. y· N/A' NOTE: Reinspectioo fees will be charged if additional inspections are required to determine compliance.

IZJ D Unified Program Facility Permit current y· N/A' Permit Expires on: 8/31/2014 D D Hazardous Materials Business Plan available IZJ D Contingency Plan available OLQG IZJSQG IZJ D Employee Training is adequate IZJ D Employee Training records available IZJ D Waste disposal records available for review [gJ D Universal waste managed properly IZJ D Emergency contacts current OUpdated today IZJ D Waste containers IZJ closed IZ!labeled IZJ D Chemical inventory/map current 0 Updated today IZJ D Waste containers in good condition Consent to inspect granted by: IZJ Inspection Contact 0 Other: __ A routine compliance inspection was conducted with Genevieve Huffman, Environmental Specialist, and Robert Cross, Plant Manager on June 6, 2014 to assess compliance with the following Unified Program elements:

California Accidental Release Prevention Program (CalARP) (HSC Div 20 Ch 6.95 Art 2 & 19 CCR Div 2 Ch 4.5) Hazardous Materials Chemical Inventory & Business Plan (HMBP) (HSC Div 20 Ch 6.95 Art 2 & 19 CCR Div 2 Ch 4) Hazardous Waste Management (HSC Div 20 Ch 6.5 & 22 CCR Div 4.5 Ch 10) Spill Prevention Control & Countermeasures Plan* (SPCC) (40 CFR Sec 112 & HSC Ch 6.67) CalARP:

Chula Vista Energy Center submitted an RMP update to the CUPA March 2014. An update to the CUPA is required every 5 years. Additionally the new RMP on file at the CUPA for Chula Vista Energy Center shows it as a Program 2 facility due to the change in passive mitigation. This facility uses poly-balls for the ammonium hydroxide tank's passive mitigation for the secondary containment.

There are 8 ammonia sensors which are, according to operating procedures, set at 25 ppm high level and 75 ppm for high­ high level alarms. The NIOSH recommended exposure limit is 25 ppm. Be advised the short term exposure limit (STEL) for ammonia is 35 ppm for a IS-minutes. The OSHA PEL (permissible exposure limit) is 50 ppm. Consider why the high­ high alarm was set at 75 ppm and consider lowering it to 50 ppm. The alarms are read through the Data Control System (DCS) and can cause auto shut off if the right number of alarms are set off on the vaporizer skid. The sensors are tested and calibrated semi-annually. The last sensor calibration and test was December 26,2013. There is annual non-destructive ultrasonic corrosion testing done on the ammonia tank which just started last month at the Escondido Energy Center and is scheduled to take place in June 2014 at Chula Vista Energy Center.

The Hazardous Materials Business Plan (inventory & site map, emergency contacts, emergency response plan, and employee training plan) is required by law to be certified online through the California Environmental Reporting System (CERS). For additional information about hazardous materials business plan s and CERS go to: http://www. sdcount y.cn.gov/dcb fhazmaUbmd -ccrs-info.html I' I\ ffll 'ED NAME OF FACILITY REI'RE.SilNI'A TIVE DATE SIGNED l2t'4ev1QJe... 1 &, 1 I Lf
HM-924-E (08113) '(Y= Yes; N/A =Not Applicable)

COUNTY OF SAN DIEGO

SUPPLEMENTAL COMPLIANCE INSPECTION REPORT
FACILITY ADDRESS: 3497 Main Street
----------------------------------------
RECORD ID # DEH2011-HUPFP-214305
DATE 6/6/2014
PAGE 2 OF 3
ZIP CODE: 92029 -------- ------ ---
The tank has a pressure relief valve on top. There has been no testing of the PRV since Chula Vista Energy Center bought this plant from MMC Energy in late 2009. The staff here is not aware of the Original Equipment Manufacturers (OEM) recommendations for testing and rebuilding or replacing the PRV for this tank. Determine the OEM recommendation, follow it and document that you have followed it. Today it was made a PM in the CMMS (computerized maintenance management system) and will be removed, tested and either rebuilt or replaced in October 2014.

At this time, CalARP-specific information is not submitted through CERS. Submit any CalARP responsible party or other changes in writing within required regulatory time frames directly to the CUPA, not through CERS. For the HMBP Program when the emergency contacts for your facility change, you must document those changes through CERS within 30 days ofwhen the change occurred.

HMBP:

This facility has updated its Facility Information, Chemical Inventory, Site Map and Emergency Plan!fraining Plan for the HMBP requirements in CERS. CERS ID: 10359508. The lastER Plan and Facility Information submittal was accepted on June 6, 2014, however, the chemical inventory and site map elements were not accepted until changes are made. Several chemical inventory items discussed during the inspection that are not required to be reported due to exemptions are exclusions from reporting requirements. Those inventory items include: closed-loop fire suppression systems (carbon dioxide, nitrogen or FM 200) per San Diego County Code SEC. 68.1119., on premise use or storage of propane in an amount not to exceed 500 gallons that is for the sole purpose of cooking, heating the employee work areas, and heating water per HSC Division 20, Chapter 6.95, Article 1, Section 25503.5, and up to 1,000 cubic feet of each type of compressed gas for which the only health and physical hazards are simple asphyxiation and the release of pressure.

Examples are argon, nitrogen, helium, neon, and air, also per HSC Division 20, Chapter 6.95, Article 1, Section 25503.5.

Finally, it is not required to remove these items, but they will be billed a separate annual permit fee ifleft in place. Also, for lube oils that have similar hazardous properties , it is permissible to Jump them into a single inventory item. This is also optional; it reduces Chula Vista Energy Center's annual permit fees. There is a comments section of the bottom of each "chemical inventory item" where you can make a note about where each item is located if you choose.

Hazardous Waste:

Used oil and oily solid wastes are generated on a regular basis. These wastes are reported in CERS. If you have "episodic generation of wastes," for example lab packs created as a result of collecting contractor hazardous materials that are deemed hazardous waste and then lab packed, if it is stored on site for 30 days or fewer, is NOT REQUIRED to be added to the chemical inventory in CERS because each year the types and quantities of chemicals vary widely. If stored on site for more than 30 days add it to the chemical inventory for as long as it is on site, and then remove it from the inventory within 30 days of removing the materials from the facility.

This is a reminder that, in California, a complete hazardous waste label includes the physical state (the words either liquid or solid), the hazardous properties of the waste (mark all that apply: reactive, flammable, toxic, corrosive or "other" __ ) in addition to the contents/composition of the waste, the accumulation start date and the generator information (Business Name, Address and phone number, for waste storage). Additional items must be on the label for transport.

SPCC:

This facility has 6,510 gallons of petroleum stored mostly in oil-filled electrical equipment 5,500 gallons of which is exempt from APSA-regulation by definition in HSC 25270.2. "Aboveground storage tank" does not include Oil-filled electrical equipment, including, but not limited to, transformers, circuit breakers, or capacitors, if the oil-filled electrical equipment when the equipment contains less than 10,000 gallons of dielectric fluid. There are other exclusions in the law, but this is the one that applies right now for your facility. Those exclusions were provided in writing to the inspection co ·act during the inspection . In fact, only 1,100 gallons of the 6,510 gallons of oil stored on site are subject to APSA at (p I L, I /Y
N J'URE OF FACILI . 1 REPRESENTATIVE DATE SIGNED TITLE OF FACILITY REf'RESE TA: lVI'. -9110-E (08/13) DEB-Hazardous Materials Division, P.O. Box 129261, San Diego, CA 92112-9261

COUNTY OF SAN DIEGO

SUPPLEMENTAL COMPLIANCE INSPECTION REPORT
FACILITY ADDRESS: 3497 Main Street ---------------------------------------- RECORD ID # DEH2011-HUPFP-214305
DATE 6/6/2014
PAGE 3 OF 3
ZIP CODE: 92029
---------- -------
this time. Until such time this facility stores 1,320 gallons of APSA-regulated petroleum on site or more, Chula Vista Energy Center is not subject to APSA. This is important for 2 reasons, 1) the CUPA regulates APSA-requirements but is not permitted to regulate Federal SPCC requirements and 2) there is no additional annual permit fee for APSA if your APSA-regulated petroleum is under 1,320 gallons. Maintain your SPCC for the federal requirement as Chula Vista Energy Center is subject to Federal SPCC. Recommend that you include a table of applicability for the oils you have on site so that in the future, regulators are clear that Chula Vista Energy Center is not subject to APSA.

MISC:

There is a below grade "pond" that in the event of an emergency could be used to divert collected spilled materials from various secondary containment systems including that of the ammonium hydroxide tank and the oil-filled electrical equipment. This pond has not been used for this purpose yet. There is an NPDES permit from the waste water authority.

Rain water is collected, tested and released from this "pond." Pond discharge logs are maintained on site. All diversions into the pond from secondary containment are by manually operated valves. No automatic releases are permitted. The valves are maintained closed.

Direct QUESTIONS and/or CORRESPONDENCE regarding this report to:

Manon Maschue, REHS
Department of Environmental Health
Hazardous Materials Division
PO Box 129261, San Diego, CA 92112-9261
(858) 518-7390
[email protected]
{.p ;____,(p.,__' ---'/ I L/
-file oerzou-ttvfFt1-zt'13oS

COUNTY OF SAN DIEGO

I COMPLIANCE INSPECTION REPORT I
BUSINESS NAME Chula Vista Energy Center, LLC
PAGE 1 OF 1 DATE 12/3/2009 - --
PERMIT# BUS. CODE K5
TIME START 9:00 END 12:00
SPECIALIST Mark
McCabe
ADDRESS 3497 Main Street INSPECTION CONTACT
Genny Huffman
CITY/ZIP Chula Vista, CA 91911 TITLE Environmental Coordinator PHONE 530-755-3280
On the above date, the County inspected your business 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 ofRegulations (CCR), and the San Diego County Code ofRegulatory 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 251 .17.6. This report may contain both minor and more slgnHicnnl (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 arc intended to provide guidance to correct any violations indicated on the attached violation report. You must submit a written response to this report within30 days (or as specified below) demonstrating that all violations have been corrected or include a written notice of disugreemt:nt th:<H clearly states lhe 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 ail other violations even if they are corrected promptly. However, correction within 30 days (or as specified below) will make a penalty less likely. y N/A NOTE: Reinspection fees will be charg ed if additional inspections are requir ed to determine compliance.

C8J D Unified Program Facility Permit current Y N/A Permit Expires on: 11/19/2012 C8J D Hazardous Materials Business Plan available [8] D Contingency Plan available OLQG [8]SQG C8J 0 Employee Training is adequate [8] D Employee Training records available C8J D Waste disposal records available for review [8] D Universal waste managed prope•·ly C8J 0 Emergency contacts currentDUpdated today [8] D Waste containersD closed D labeled C8J 0 Chemical inventory/map current D Updated today [8] D Waste containers in good condition Consent to inspect granted by: [8] Inspection Contact D Other: __ Routine compliance inspection conducted today. Permission to inspect given by Genny Huffman.

No violations noted.

This site has recently changed ownership from MMC Energy to Wellhead Services, LLC. )j>plications to change the facility permit to the new owner has been submitted.

New Risk Management Plan registration information has been received. Update your Hazardous Materials Business Plan within 30 days to get this document current. Assure that emergency contacts and inventory have been updated as needed. If any changes with the physical facility, you will need to update the site map as well.

D This is an annual certification that the Hazardous Materials Business Plan (inventorr & site map, emergency contacts, emergency response plan, and employee trainin g plan) is current and mcludestll tlie information re uired in the H&SC and is maintained at the site where hazardous materials are stored. Initials of Business Representative

PRJNTEQ NAME OF BUSINESS REPRESENTATIVE DATE SIGNED
G "neu, e t.J-e L' ·f..kJ [-6:-nan J Z.. 1 I D 1 z..oo 1

SIGNA TITLE OF BUSINESS REPRESENTATIVE
Department of • Jvironmental Health, Hazardous Material s Division P.O. Box 129261, San Diego, CA 921119261 Phone: 61 9 3 38-2222 Toll F ree: 800 253-9933 httl: //www.sdcdeh.or HM-924-E ( 11 /08) '(Y= Yes; N/A =Not Applicable) DISTRIBUTION: WHITE RETURN TO HMO; YELLOWBUSJNESS RETAINS

SAN DIEGO COUNTY

DEPARTMENT OF ENVIRONMENTAL HEALTH-CUP A
(

HAZARDOUS MATERIALS DNISION
P.O. BOX 129261, SAN DIEGO, CA 92112-9261
1-800-253-9933 (619) 338-2222 FAX (619) 338-2377

HAZARDO US MATERIALS BUSINESS PLAN CERTIFICATION
The California Health & Safeb:' Code {H&SC), Division 20, Chagter 6.95, Section nrovides for the following:

The San Diego County, Department of Environmenta l Hea lth, Hazardous Mater ia.ls Division (HMO), as the adminis tering agency, requires a business that handles hazardous materia ls to submit the hazardous materials inventory, a list of emergency contacts , and a site plan, in lieu or a com plete Haza rdous Materials Business Plan (HMBP), only after the initial submittal of a comp lete HMBP . The business must certify that a complete RMBP has been prepared and is maintained at the site whe re the hazardous mater ials are stored. A complete FIMBP includes the items to be submitted to tlte HMD and an mergency Respons e Plan and Employee Training Plan, as esta blished in H&SC Section 25504. The business must also arumally certify that the HMBP is current and maintained on site. See Back for instructions and further clarification .

I. IDENTIFICATION
FACILITY ID#
317 1 I o I o I o I 11 1 3 19 12 11 I I
BUSINESS NAME (SoniC as FACILITY NAME or DBA - Doing Business As) l MMC Chula Vista, LLC
BUSINESS SITE ADDRESS 103
3497 Main St.

CITY 104

I CA I ZIP CODE
105
Chula Vista 91911
II. CERTIFICATION STATEMENT
0 CARCINOGENIREPRODUCTNE TOXIN ANNUAL RENEWAL WITHOUT CHANGES : This is an annual renewal to certify that the list of carcinogens and/or reproductive toxins last provided is a current list as specified in the San Diego County Code of Regulatory Ordinances Section 68.1113.

Check only one of the following boxes:
0 INITIAL CERTIFICATION: This is to certify (H&SC Section 2550S(e)(l)) that a complete HMBP, which includes the hazardous materials inventory, a list of emergency contacts, a site plan, emergency response plan, and employee training plan, has been prepared and is maintained at the site where the hazardous materials are stored. 0 ANNUAL CERTWICATION WITHOUT CHANGES: Thi is an annual certUicafioo (H&SC Section 25505(d)&(e)(2)) that the HMBP , which includes the hazardous materials Inventory, a Ust of emergency contacts, a site plan emergency response plan, and employee training plan, is current and includes aU the information required in H&SC Section 15504, and 25509, and is maintained at the site where the hazardous materials are stored.
181 CERTIFICATION OF CHANGES/REVISJONS: Thi is to certify that the HMBP has been reviewed (H&SC Section l5505(c) & 25510) and aU necenary changes/revisions have been IIUlde. The HMBP is current 11nd is maintained . at the site where tJ1e bazardou materials are stored. Attached are chan.ges to the hazardous materials inventory aDfVor lm of emergency contacts. For site map revisionli, submit only the pages that have a change or revision and attach to this certification. Thi submitta l sotisfies nnual certification requirement s specified in H&SC Section 25505(d)&(e)(2).

AS AN AUTHORIZED REPRESENTATIVE, I CERTIFY UNDER THE PENALTY OF LAW, THAT I HAVE PERSONALLY EXAMINED AND AM FAMILIAR WITH THE INFORMATION SUBMITfED AND BELIEVE THE INFORMATION IS TRUE, ACCURATE, AND COMPLETE.

REPRESENTATIVE DATE
51712007
...-... 00:: ./ \. ---c./\

NAME OF TITLE OF SIGNER
Harry Scarborough Vice President Business Development
0 0 Site Map _ _ 1 __ 1 __ •Note: IOOicate the date that the inventory and/or ER contact F INSTRUCTIONS 0 *Emergency Contacts __ 1 __ 1 __ infonnalioo in the KN A database \WS reviewed and changes F TO CLERICAL D *Chemical Inventory
were submitted fbr processing. lflhe inventory 8Jld IlR con1act I STAFF FOR HMBP I I intilnnationure exactly the same as it is rcoorded in KJV A. no ---- - - changes need to be submitted. c ACCEPTANCE
E Hazardous Materials Business Plan acceptance date will be changed to the acceptance date on new site map.

A letter will be mailed to business after processing of site map updates. u Specialist's Signature: (only required for new plans or for changes to site maps, chemical inventory and/or emergency contacts) s lllRT SITE C**
E
FIREDIST. REMARKS :
** IfHIRT box ts checked, follow HUH pohcy to mdtcate on the mventory forms whtch hazardous matettals make thlS a HIRT stte.

SAN DIEGO COUNTY

DEPARTMENT OF ENVIRONMENTAL HEALTH- CUPA

HAZARDOUS MATERIALS DIVISION
P.O. BOX 129261, SAN DIEGO, CA 92112-9261
(619) 338-2222 FAX (619) 338-2377
1-800-253-9933

BUSINESS OWNER/OPERATOR IDENTIFICATION
Pogo of
I. IDEN TIFJCATION
1 3
1 7
1 lolololl 1 13 19 12 11 1
11 1
I BEGINNING DATE tOO I ENDING DATE 101
FACILITY ID#
BUSINESS NAME (Same as FACILITY NAME orDBA-Doing Business As) 31 BUSINESS PHONE 102 MMC Chula Vista, LLC (619) 420-3291 X
BUSINESS SITE ADDRESS 103
3497 Main Street
CITY 1041 ZIP CODE 105
San Diego CA 91911-
DUN & BRADSTREET 106 SIC CODE (4 digit#) 107
363602033 2212
COUNTY 108
San Diego
BUSINESS OPERATOR NAME 109 BUSINESS OPERATOR Jll lONE 11 0 MMC Energy North America, LLC (2 12) 977-0900 X
IT. BUSINESS OWNER
OWNER NAME Ill OWNER PHONE 112
MMC Energy North America, LLC (212) 977-0900 X
OWNER MAILING ADDRESS ltJ
26 Broadway Suite 907
CITY 115 CODE 116
New York 10004-
Ill. ENVIRONMENTAL CONTACT
CONTACT NAME 117 CONTACT PHONE 118
Donelle W. Griffin (858) 354-4995 X
CONTACT MAILING ADDRESS 11 9
7911 Blue Jay Place
CITY 1201 STATE Il l I Zll' CODE 122
San Diego CA 92123-
-PRIMARY- Iv. EMERGENCY CONTACTS -sECONDARY-
NAME 123 NAME 128
Harry Scarborough Donelle W. Griffin
TITLE 124 TITLE 129
Vice President Business Development Environmental Consultant BUSINESS PHONE 125 BUSINESS PHONE 130
(661) 664-7152 X (858) 278-9170 X
24-HOUR l)HONE 126 24-HOURPHONE Il l
. ..... -·-
127 l'AGER # 132
ADDITIONAL LOCALLY COLLECTED INFORMATION:

E-MAIL: • E-MAIL: 10
hsr · - Ill .-'- -
1-c--
*Th1s infonnatl on Is OJ!tlonal and will remain confiden tial. Comp lete If you want to receive periodic oroaram updates from HMD.

ALWAYS SUBMIT A COPY OF THIS COMPLETED PAGE WITH SUBMITTAL OF ANY OTHER UNIFIED PROGRAM CONSOLIDATED FORM.

Certification: Based on my inquiry ofthose
1 responsible for obtaining the infonnation, I certifY under penalty oflaw that I have personally examined and am familiar with the infom1ation sub"lilted and ve the infonnation is true, accurate, and complete.

TED REI'R ESENIATIVE DATE 1341 NAME OF DOCUMENT PREPARER m r- ...... <:.: / 2007-05-07 Donelle W. Griffin
NAME Of - 136 TITLE OF SIGNER 137
Hany Scarborou Vice President Business Development
PAGE _j_ OF A_DATE ,£1 LO; /{_
PERMIT# ..< I <./,Sa£ BUS. CODE I(S-2...

COMPLIANCE INSPECTION REPORT TIME START 7wV END /_('/. '00

SPECIALIST

INSPECTION CONTACT
Cfe 1:1 Ji& .,C.,C WL4vt
TITLE £;-/.,;..

PHONE (6/..1-) ·-6/? L
On the above date. the County inspected your lacility under the authority ofthe California Healtl1 and Safety Code(H&SC), to determine compliance with applicable provisions of the H&SC. tl1e California Code of Regulations (CCR), and tl1c San Diego County Code of Regulatory Ordinances (SDCC). This report sen•es as a i\'otice to Comply (H&SC 25187.8 & 25404.1.2) for an)' minor violations as defined in H&SC 25404 and 25117.6. This report may contam both minor and more significant (Class 11) 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 arc corrected promptly. However, correction within 30 days (or as specified below) will make a penalty less likely. y· N/A' NOTE: Reinspection fees will be charged if additional inspections are required to determine compliance.

D D Unified Program Facility Permit current y· N/A' Permit Expires on: I I D D Hazardous Materials Business Plan available D D Contingency Plan available DLQG DSQG D D Employee training is adequate D D Employee training records available D D Waste disposal records available for review D D Universal waste managed properly D D Emergency contacts current D Updated today D D Waste containers D closed D labeled D D Chemical inventory/map current D Updated today D D Waste containers in good condition Consent to inspect granted by: D Inspection Contact D Other: ----..--...,------------------ (2,._ 'i-1</-:;totl 1.1« > Ctmdu.IC4
D This is an annual certification that the Hazardous Materials Business Plan (inventory & site map, emergency contacts, emergency response plan, and employee training plan) is current and includes all tile information re uired in the H&SC and is maintained at the site where hazardous materials are stored.

PRINTED NAME OF FACILITY REPRESENTATIVE DATE SiGNED
f?caa:t , r ,<.. s- I I 2.&>1 I
TITU: OF FACILITY REPRESENTATIVE
Initials of Facility Representative
ent of Environmental Health, Hazardous Materials Division, P.O. Box 129261, San Diego, CA 92112-9261 Phone: 858 505-6880 htt ://www.sdcdeh.or
HM-924 (03/11) NCR Yes; N/A Applicable) DISTRIBUTION: WHITE-HMO COPY: YELLOW-FACILITY COPY

COUNTY OF SAN DIEGO

SUPPLEMENTAL COMPLIANCE INSPECTION REPORT
........£...! .......1_L; t<? I I

DATE SIGNED
PERMIT# ;.?, I :1.:3 o:£
DATE ... S .. J .. Lfl_!-LL
PAGE 4- OF 2_
ZIP CODE: 9/ VI

TITLEOF BUSINESS REPRESENTATIVE
HM-9110 (11/08) NCR White: HMO Yellow: Business retains DEl-l-Hazardous Materials Division, P.O. Box 129261, San Diego. CA 92112-9261

COUNTY OF SAN DIEGO CUPA

DEPARTMENT OF ENVIRONMENTAL HEALTH

HAZARDOUS MATERIALS DIVISION
P.O. BOX ll9261, SAN DIEGO, CA 921ll-9261
(619) 338-1111 FAX (619) 338-1377
1-800-lSl-9933

BUSINESS ACTIVITIES
I I
Date Submitted
Pa e of
FACILITY ID # EPA 1D # (Hazanloos Waste Only)
CAL000346986
Chula Vista Energy Center, LLC

BUSINESS SITE ADDRESS
3497 Main Street

BUSINESS SITE CITY
Chula Vista

D ABOVE GROUND PETROLEUM STORAGE
Store greater than I ,320 gallons of petroleum products (new or used) in above ground tanks or containers?
E. !iAZARDOUS WASTE
Generate hazardous waste?
Recycle more than 100 kg/month of excluded or exempted recyclable materials (per HSC 25143.2)?
Treat hazardous waste on site?
Treatment subject to financial assurance requirements (for Permit by Rule and Conditional Authorization)?
Consolidate hazardous waste generated at a remote site? Need to report the closure/removal of a tank that was classified as hazardous waste and cleaned on site?
Generate in any single calendar month I ,000 kilograms (kg) (2,200 pounds) or more of federal RCRA hazardous waste, or generate in any single calendar month, or accumulate at any time, I kg (2.2 pounds) of RCRA acute hazardous waste; or generate or accumulate at any time more than 100 kg (220 pounds) of spill cleanup materials contaminated with RCRA acute hazardous waste?
Household Hazardous Waste (HHW) Collection site?
F. LOCAL REQUIREMENTS

MEDICAL WASTE
Genemte <200 lbs/month of Medicai/Biohazardous Waste?
Generate 2;200 lbs/month of Medicai!Biohazardous Waste? 104
[!)YES DNO 4
I!J YES D NO 4a
D YES ll!l NO 5
I!JYES DNO 8
[!)YES DNO 9
D YES ll!l NO to
DYES 0NO II
DYES lj)NO 12
DYES ll!l NO 13
DYES !KINO 14
DYEs 14a
DYES [] NO 14b
Generate =::_200 lbs/month of Medicai/Biohazardous Waste and treat any amount of medical waste? Handle Toxic gases with threshold limit concentration (TL V) # 10 ppm in any quantity? HM-906 (05-08) [HM-970 1-UPCF-Bminess !l.ctivitie> (05.108)1 103

ZIP CODE
91911
105

HAZARDOUS MATFRIALS INVENTORY -

CHEMICAL DESCRIPTION
Coonlinate with your local •B•ncy responsible
forCaiARP.

UST FACILITY (F""""'y SWRCB y..., A) HM-9715
UST TANK (one page per mlk-Formerly Form B) HM-9717
NO FORM REQUIRED TO CUP As
EPA ID NUMBER- provide at the top of page
-)

ONSITE HAZARDOUS WASTE

TREATMENT -FACILITY

ONSITE HAZARDOUS WASTE
TREATMENT- UNIT (<me,... pa mrit)

CFRTIFICA TION OF FINANCIAL

ASSURANCE

REMOTE WASTE I CONSOLIDATION SITE

ANNUAL NOTIFICATION

HAZARDOUS WASTE TANK CLOSURE

CFRTIFICA TION
Obtain federal EPA ID Number, file Biennial
Report (EPA Form 8700-BNB), and satisfy
requirements for RCRA Large Quantity
Gem:nltor.

See CUPA for required forms.

DYEs
DYES
DYES
DYEs
[!)NO
I!JNO
I!! NO
"
3 •
•
UPF Permit#: d./rj3o6
DATE

UNIFIED PROGRAM FACILITY PERMIT

APPLICA TJON
0 This business or service is required to obtain a Unified Program Facility Permit from the San Diego County Department of Environmental Health. I answered "yes" to one or more of the questions on the "Business Activities" form.

Dare assumed business ownership at this location: o9 I 23 I 2oo9 This permil does not ncll!le any owner or operator from complying with all applicable federal, stale, county or local laws, ordinances or regulations. The owuer or operator is required to determine if another permit or approval from any other agency or department is necessary. The County, by issuing this permit. does not relinquish iu right to enforce any violation of law. 0 I have determined that this business or service does not require a Unified Program Facility Permit from the San Diego County Department of Environmental Health.

I declare under penalty of perjury that to the best of my knowledge and belief the statements made herein are correct and true. I consent to all necessary inspections allowed by law and incidental to the issuance of required pemlil(S) and the operation of this business.

Sigrtllture: . I r / / /f " I ,,, ;!
.f 1 ;·.' .··,, ;.t/IJ: /J •, , , ·Ju.;c · ... ·. _ ...... - t ·.t-v.

Printed Name: Genn)' Huftman
Type of Business:

Pover Generation
Title: Environmental Coordlnator
Date:
u I 19 I 2oo9
Phone#:

Please complete the business information on the following page antJ return this application to the San Diego County Department of Environmental Health at:

SAN DIEGO COUNTY

DEPARTMENT OF ENVIRONMENTAL HEALTH

HAZARDOUS MATERIALS DIVISION
P.O. BOX 129261
SAN DIEGO CA 92112-9261
If a San Diego County Unified Program Facility Permit is required for your business or service a representative of this Department will contact your business. Permit fees will be determined from the contact and a billing statement will be mailed.

NOTE.: If you do not use hazardous materials, generate hazardous waste, or have underground storage tanks you are still required to return this form ..

A representative of the San Diego County Department of Environmental Health may contact you to veri f) the information provided on this application.

COUNTY Of' SA.'II DiEGO CUPA

DEPARTMENT OF ENVIRONMENTAL HEALTH

HAZARDOUS MATERIALS DIVISION
P.O. BOX 129261, SAN DIEGO, CA 9lll2·92M
(619)J38-2ll2 FAX (619) 338-2377
1·800-2!3-9933

BUSINESS OWNER/OPERATOR IDENTIFICATION
Pa f: 1 (If 18
rACILITY I[)# BEGI:-ININ() DATE ,;;:;·!. ENDING DATE JUJ I . 1 1 ' 1 1 2011 1 12 / 01 I 2011 , BUSINESS NAME (S4me ill' FACIUT"i NAME or DBA·- Dolnt;DU'!!MSS..U} .\I BUSINESS PliONE Chula Vista Energy Center, LLC 1 ( 619 ) 420-3291
BUSINESS SITE ADDRESS ------··- ------· .. ··--- ··-------------- "'-'I BL'SINESS FAX ··;c;;;-;1 3497 Main Street \ ( 619 ) 420-6972 I
BUSINESS-srrE CITY;--------- ""I i ZIP CODE m i COUNTY w;j Chula Vista . CA j 91911 j San Diego I
'"" l PRIMARY SIC 107 I PRIMARY NAICS ""'1 DUN & BRADSTREET 83-146-0535
BUSINESS MAILING ADDRESS;:;,,-------- ----· --- ....
650 Bercut Drive, Suite C
__ 1__ __ I 221112 ;·,,,,
4 BUSINESS MAILING CITY
sacramento
"""' I STATE '"""I ZIP CODE . '""" I I Cl\ I
=====:---------------·__J
BUSINESS OPERATOR NAME '""; BUSI:-IESS OPERATOR PHONE "] r Ch_u_l_a_,:'ista Energy Center. LLC ,,,_II
rl1WNER NAME lllj OWNER PaONE
Chula. Vista Energy Center, LLC 'f916 'P47-Sl71 ) . ------ --- .. - --

OWNER MAIUNGADDRESS
650 Bercut Drive, Suite c
-=.;--· -CITY '"I STAfE '"I ZIP CODE
sacramento CA 95811
... .. III. ENVIRONMENTAL CONTACT
CONTACT NAME lli' CONTACT
Genevieve Huffman (530 ) 755-3280
CONTACT MAIUNG ADDRESS 119 CONTACT EMAIL•
650 Bercut Drive, Suite c
CITY ------------------. ----- c. '" I CODE
I CA Sacramento 95811
· -PRIMARY- IV. EMERGENCY CONTACTS
r·NAME IZJ NAME
I. 24 hr Desk Robert cross
TITLE '"' Tffi.E
, Plant Manager
BUSINESS PHONE -------;,_. BUSINESS PHONE -·--------
447-6323 619 ) 592-5140
. -- 12t> I ·J.t.l-U"lt ttl
"'I PAGER#
None I
None
-
/
ll)i
i ____ ..J
II/.!
i
... i,o,;-!

I ------,
-
'"·I '
I --------ut1
I
I E-M/.: --l
I "This Information wlll.romatn confidential. ..... --- · - ...... -- - · -· 1 J
J ALWAYS SUBMIT A COPY OF THIS COMPLETED PAGE WITH SUBMITTAL OF ANY OTHER UNIFIED PROGRAM CONSOLIDATED FORM. ! 1 1
Cerrilication: en my inquiry of !hose individunls rtSpunsibte for the mformarion. _l certify under penally of law thutl personally examined and am--1 ' rammar'wi1h the ·ln10rmution submitted and believe infonnation is true. accuta!e. and comJ)\tte. ' , EPRESfil:ITATIVE DATE . 13<! NM.tE OF DOCUMENT PREPARER '" 1 ,. ·, I >--..,... ,/\. .J .£{ j 7t 1 Genevieve Huffman _ ___:__..::..:____:_:__ _____________ j NAME! Of SIC.NF..R \Jnlr.t DO j TITLE.OF.StGNER 1171
Daniel Richa'rdson 1 Plant -Manager
HM-9702 (UJ/08) (h.·ncr/Operator Identification

COUNTY OF SAN DIEGO

DEPARTMENT OF ENVIRONMENTAL HEALTH-CUPA

HAZARDOUS MATERIALS DIVISION
P.O. BOX 129261, SAN DIEGO, CA 92112-9261
(858) 505-6700 FAX (858) 505-6848

HAZARDOUS MATERIALS BUSINESS PLAN CERTIFICATION
The Ca1i(i>rnia Health & Safety Code IH&SCl Djyjsjon 20 Chapter 6 95 Section 25505 moyjyes for the l(,llowjng:

The County of San Diego, Department of Environmental Health, Hazardous Materials Division (HMO), as the administering agency, requires a business that handles hazardous materials to submit the hazardous materials inventory, a list of emergency contacts, and a site plan, in lieu of a complete Hazardous Materials Business Plan (HMBP), only after the initial submittal of a complete HMBP.

A complete HMBP includes the items to be submitted to the HMO and an Emergency Response Plan and Employee Training Plan, as established in H&SC Section 25504. The business must annually certify that a complete HMBP has been prepared, is current and is maintained at the site where the hazardous materials are stored. Sec Back for instructions and further clarification FACILITY ID#

BUSINESS SITE ADDRESS
3497 Main Street
CITY
Chula Vista
104
II. CERTIFICATION STATEMENT

ZIP CODE
91911
J()J
0 CARCINOGEN/REPRODUCTIVE TOXIN ANNUAL RENEWAL WITHOUT CHANGES: an annual renewal to certif)' that the list of carcinogens and/or reproductive toxins last JlfOvided is a current list as specified in the San l)iego County Code of Regulatory Ordinances Section 68.1113.

Check only ONE of the following boxes:
0 INITIAL CERTIFICATION: This is to certify (H&SC Section 25505(e)(IJ) that a complete HMBP, which includes the hazardous materials inventory, 11 list of emergency contacts, a site plan, emergency response plan, and employee tr11ining plan, has been prepared and is maintained at the site where the hazardous materials arc stored.

IZJ ANNUAL CERTIFICATION WITHOUT CHANGES: This is an annual certification (II&SC Section 25505(d) & (c)(2)) that the HMBP, which includes the hazardous materials inventory, a list of emergency contacts, a site plan, emergency rcsponoc plan, and employee training plan, Is current and Includes all the information required in II&SC Section 25504, nnd 25509, and Is mnintnined at the site where the hazardous materials nrc stored. ·
0 CERTIFICATION OF CHANGES/REVISIONS: This is to certil)· that the HMJJP hns been reviewed (II&SC Section 25505(c) & 25510) and all necessary changes/revisions have been made. The II Mill' io current and Is maintained at the site where the hazardous materials are stored. Attached ure changes to the hazardous materials inventory und/or list of emergenC)' contacts. For site map re>·islons, submit only the pages that have a change or revision and attueh to this certification. This submittal satisfies annual certlflcution •·e•tulrements specified in li&SC Section 25505(d) & (c)(2).

As an Authori1.ed Representative, I certjfy. under the ncn•t!tl' of luw, that I have personally examined nm familiar with the Information submitted and believe the information Is true, accurate, und comtJlctc. JJy checking any ol'thc boxes above I also certify that: a) The Information contained In the hazardous materials inwntory most recently submitted to the Clll'A or Administering Agency Is complete, accurate, and up to date; b) There hns been no change In the quantity ofh111.ardous materials reported in the most recently submitted inventory; and c) All hiiZardous materials subject to inwntory requirements are listed on the most recently submitted Inventory.

OR DESIO:-IATED REPRESENTATIVE DATE
02/10/2012

TITLE OF SIGNER
Environmental Coordinator
· D Site Map __ / __ /__ *Note: Indicate the dale that the inventory an<Vor ER oonllK.1 · : D • Emergency Contacts __ ! __ !__ iedn KIY A wns rcvic"cd nndch!Ulgcs ;11 TO .C.LE.RICAL. ··.· were subnult ,or proccssmg. lftl1c inventory and ER cm1!act • 1• 'Sl'A"F FOR HMBP': D •Chemical Inventory __ / __ /__ infommtion on:cxactlythcsamcasitl< recorded in KIVA, no r Ch!U1gcs need to be submitted. C ACCEPTANCE . 1--------------------'---------------1 · Hazardous Materials 13usincss Plan acccpl!lncc date will be changed to the acceptance date on new site map. u, HIRT SITE C** s
•: FIRE DIST.

A lcucr will be mailed to business al\cr processing of site map updates.

Specialist's Signature: (only required for new plans or for changes to Sit\! maps, chemical inventory ftn<.Vor emergency contacts) _______________________________________________________ __ •• lf'HIRT box is checked. follow 1-IIRT policy to indicate on the inventory !brms which hazardous materials make this a HIRT site.

HM-953 (02/11)
j
-, ·;
ELIZABETH A. POZZEBON

ACTING DIRECTOR
May 22,2014
Ms. Genny Huffman
Wellhead Services
873 N. Walton Ave.

Yuba City, CA 95993
<tountp of &an Jlfego

DEPARTMENT OF ENVIRONMENTAL HEALTH

HAZARDOUS MATERIALS DIVISION
P.O. BOX 129261, SAN DIEGO, CA 92112-9261
Phone: (858) 505-6700 or (800) 253-9933 FAX: (858) 505-6786 www.sdcdeh.org
NOTIFICATION OF FACILITY INSPECTION FOR:

AMYHAREERT

ACTING ASSISTANT DIRECTOR
CHULA VISTA ENERGY CENTER, 3497 MAIN STREET, CHULA VISTA, CA 91911 PERMIT #DEH2011-HUPFP-214305 ON JUNE 6, 2014
The Hazardous Materials Division (HMD) inspects businesses or facilities in order to determine compliance with the California Health and Safety Code (H&S) Chapters 6.5, 6.7, 6.95; Titles 19,22 and 23 of the California Code of Regulations (CCR); and the San Diego County Code (SDCC).

The inspection will focus on these general areas:
• Site Inspection: An inspection of the facility by a Hazardous Materials Specialist (including buildings, equipment, storage areas, work areas, etc.). o Observe hazardous materials and waste storage, handling, container labeling, and waste disposal procedures.
o Review spill control procedures and spill reporting.
o Review and evaluate hazardous materials that are stored or handled on-site. • Review the Hazardous Materials Business Plan: (Site Map, Emergency Response Procedures, and Employee Training Plan).
• Review the hazardous materials training program and documentation (written records). • Review hazardous waste disposal receipts and manifests.

Additionally your facility is subject to the California Accidental Release Prevention (CalARP) Program regulations under Title 19, Division 2, Chap 4.5, and has submitted a Risk Management Plan (RMP) for a Regulated Substance (ammonium hydroxide) in a Covered Process. For this portion of the inspection the following records will be reviewed:
• RMP Public Document, and related Technical Documents
• RMP Update Documentation: within 5 years of initial submission, change of owner operator, updated registration information, and Program level change, (if any). • Revised/Updated Offsite Consequence Analysis (OCA) - every 5 years, or if significant process modification.
"Environmental and public health through leadership, partnership and science" Chula Vista Energy Center, LLC 2 May 22,2014
• Prevention Program 2 Documents: Safety Information, Hazard Review, Operating Procedures, Training, Maintenance, Compliance Audits, Incident Investigations, Employee Participation, Hot Work Permits, Contractors.
• Emergency Response Program.
• Accidental Release Records (if any).

This notification is intended to better prepare you for the inspection of your CalARP and hazardous material management programs. I plan to be at your facility by 8:00am on June 6, 2014. I also recommend you review your RMP public document for other documents referenced (Operational Procedures, Maintenance Records, Training Programs, etc.) which may be reviewed during the inspection. Depending on the size, and complexity of your facility the inspection is expected to take 1-4 days. If you have any questions please call me at (858) 518-7390. Thank you for your cooperation.
;;ndefL_
Manon Maschue, REHS
Environmental Health Specialist III
Hazardous Materials Division
Cc: File DEH2011-HUPFP-214305

COUNTY OF SAN DIEGO

UPFP INSPECTION CHECKLIST
FACILITY NAME: CHULA VISTA ENERGY CENTER, LLC
ADDRESS: 3497 MAIN ST
CITY/ZIP: CHULA VISTA /91911
INSPECTION DATE: 06/10/2016
RECORD ID #: DEH2011-HUPFP-214305
TIME START: 9:00 AM END: 2:00 PM
SPECIALIST: Manon Maschue
INSPECTION CONTACT: Susana Miramontes
TITLE: Administrative and EHS Specialist
PHONE:619-579-9002
E-MAIL:[email protected]
HM-9000(01/15) DEH CUPA Inspection eForm v38 Dated 11/2/2015 20:45

FACILITY REFERENCE DATA
ACCELA

CERS
RECORD STATUS: Permit Renewed
PERMIT EXPIRATION DATE: 08/31/2016
BALANCE DUE: $0.00
INSPECTOR: Manon Maschue
INSPECTION TYPE: Routine
INSPECTION STATUS: Pending Corrective Action
EPA ID NUMBER: CAL000346986
FACILITY CERS ID NUMBER:10359508
CERS LEAD USER: Susana Miramontes
LAST CERS SUBMITTAL DATE: 03/17/2016
ENVIRONMENTAL CONTACT EMAIL: [email protected]
ENVIRONMENTAL CONTACT PHONE: 6195799002

FACILITY INFORMATION

YES NO YES NO INACTIVATION INSPECTION: ✖
CHANGE OF OWNER: ✖
CHANGE IN BUSINESS TYPE: ✖
BUSINESS TYPE: Public Utilities-Not Fleet Fuel Facility ISSUE INITIAL INVOICE: ✖
ASSESS NON-NOTIFICATION FEE: ✖
ASSESS RE-INSPECTION FEE: ✖
FACILITY SUBJECT TO BASE FEE: ✖
FACILITY SUBJECT TO CUPA FEE: ✖
UPDATE FACILITY ADDRESS IN AA: ✖
HAZARDOUS MATERIALS: ✖
HAZARDOUS WASTE: ✖
ABOVEGROUND PETROLEUM STORAGE ACT:* ✖
TOTAL SHELL CAPACITY APSA: 0
UNDERGROUND STORAGE TANK: ✖
CALARP PROGRAM (CERS): ✖
CALARP PROGRAM LEVEL:

1 2 3 N/A
MEDICAL WASTE: ✖
MW FACILITY GENERATING OVER 200 LBS PER MONTH: ✖
EPIC PARTICIPANT: ✖
NUMBER OF TLV GASES AT THE FACILITY: 0
HW GENERATOR STATUS :

LQG SQG CESQG RCRA LQG N/A
TIERED PERMIT LEVEL(S) :

CESQT CESW CE-L CE-CL HHW PBR CA N/A

PRIMARY BILLING CODE
Not Applicable

SECONDARY BILLING CODE
Not Applicable

TERTIARY BILLING CODE
Not Applicable
INSPECTION SCOPE:

HAZARDOUS MATERIALS: GEN HAZMAT APSA UST
MEDICAL WASTE: SQG SQG - TREATS

LQG LQG - ABBREVIATED LQG - TREATS
HAZARDOUS WASTE: SQG LQG
CALARP: 1 2 3
TIERED PERMITTING: CESQT CESW CE-L CE-CL

CA PBR HHW
CONSENT TO CONDUCT INSPECTION GRANTED BY: INSPECTION CONTACT ✖ NAME: Susana Miramontes TITLE: Administrative and EHS Speci

REMOVE BLANK CHECKLISTS FROM FINAL INSPECTION REPORT REFUSED TO SIGN INSPECTION REPORT EMAILS:
[email protected],[email protected],[email protected] RECORD COMMENT:

HM-924(01/15)

COUNTY OF SAN DIEGO

COMPLIANCE INSPECTION REPORT
FACILITY NAME: CHULA VISTA ENERGY CENTER, LLC
ADDRESS: 3497 MAIN ST
CITY/ZIP: CHULA VISTA /91911
INSPECTION DATE: 06/10/2016 PAGE 1 OF 12
RECORD ID #: DEH2011-HUPFP-214305
TIME START: 9:00 AM END: 2:00 PM
SPECIALIST: Manon Maschue
INSPECTION CONTACT: Susana Miramontes
TITLE: Administrative and EHS Specialist
PHONE:619-579-9002
E-MAIL:[email protected]
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 N/A
✖ Unified Program Facility Permit Current
✖ Hazardous Materials Business Plan Available
✖ Employee Training is Adequate
✖ Waste Disposal Records Available for Review
Emergency Contacts Current Updated today
✖ Chemical Inventory/Map Current Updated today
Yes N/A
✖ Contingency Plan Available LQG SQG✖
✖ Employee Training Records Available
✖ Universal Waste Managed Properly
✖ Waste Containers Closed✖ Labeled✖
✖ Waste Containers in Good Condition
Permit Expires On 08/31/2016
CONSENT TO CONDUCT INSPECTION GRANTED BY: Susana Miramontes TITLE: Administrative and EHS Speciali INTRODUCTION:

A routine Certified Unified Program Agency (CUPA) compliance inspection was conducted with Susana Miramontes, Administrative and EHS Specialist, and Stephen Cobbe, Plant Manager on June 10, 2016 to assess compliance with the following Unified Program elements:

■ California Accidental Release Prevention Program (CalARP) (HSC Div 20 Ch 6.95 Art 2 & 19 CCR Div 2 Ch 4.5) ■ Hazardous Materials Chemical Inventory & Business Plan (HMBP) (HSC Div 20 Ch 6.95 Art 1 & 19 CCR Div 2 Ch 4) ■ Hazardous Waste Management (HSC Div 20 Ch 6.5 & 22 CCR Div 4.5 Ch 10) ■ Spill Prevention Control & Countermeasures Plan* (SPCC) (40 CFR Sec 112 & HSC Ch 6.67)

VIOLATION # 1
5010031 Failure to correct and submit the emergency contact information in the RMP required under section 2740.1(d)(6) within one month of any change. 19 CCR 2745.10.5(a)(2)
Classification: Class II
Observations:

The former plant manager and EH&S contact have not worked here for more than 30 days. Stephen Cobbe took over at Plant Manger May 2015 and Susana Miramontes took over as EHS Specialist October 29, 2015.

Corrective Action Due By:07/10/2016
By 7/10/2016 submit updated registration information including updated CalARP RMP Qualified Person and CalARP ER Contact to the CUPA.

VIOLATION # 2
5010029 Failure to contact the AA within 30 days of a change of owner or operator to update the registration information. 19 CCR 2745.10(f)
Classification: Class II
Observations:

HM-924(01/15)

COUNTY OF SAN DIEGO

SUPPLEMENTAL COMPLIANCE

INSPECTION REPORT
INSPECTION DATE: 06/10/2016 PAGE 2 OF 12
RECORD ID #: DEH2011-HUPFP-214305
The former plant manager and EH&S contact have not worked here for more than 30 days. Stephen Cobbe took over at Plant Manger May 2015 and Susana Miramontes took over as EHS Specialist October 29, 2015.

Corrective Action Due By:07/10/2016
By 7/10/2016 submit updated registration information including updated CalARP RMP Qualified Person and CalARP ER Contact to the CUPA.

VIOLATION # 3
5010049 Failure to prepare written operating procedures that provide clear instructions or steps for safely conducting activities associated with each covered process consistent with the safety information for that process and address the following: 1. Initial startup; 2. Normal operations; 3. Temporary operations; 4. Emergency shutdown and operations; 5.

Normal shutdown; 6. Startup following a normal or emergency shutdown or a major change that requires a hazard review; 7. Consequences of deviations and steps required to correct or avoid deviations; 8. Equipment inspections. 19 CCR 2755.3(a)(b)
Classification: Class II
Observations:

Written operating procedures are not available as required by 2755.3(a)(b).

Corrective Action Due By:07/10/2016
Not later than 7/10/2016, prepare written operating procedures as required by 2755.3. By July 15, 2016, provide to me a statement that they are developed and are on site.

VIOLATION # 4
5010051 Failure to prepare and implement written procedures to maintain the on-going mechanical integrity of the process equipment. 19 CCR 2755.5(a)
Classification: Class II
Observations:

There were no written procedures to maintain the on-going mechanical integrity of this CalARP covered process as required by 2755.5(a). The plant is "in between" computerized preventive maintenance systems and has no developed "paper" documents that provide procedures for maintaining the CalARP covered process components.

Corrective Action Due By:07/10/2016
Not later than 7/10/2016, ensure that there are written procedures available that specify how to maintain the on-going mechanical integrity of the CalARP covered process as required by 2755.5. By July 15, 2016, provide to me a statement that they are developed and are on site.

VIOLATION # 5
5030001 Failure to perform or cause to be performed inspections and tests on process equipment that: 1. Follow recognized and generally accepted good engineering practices; 2. The frequency of inspections & tests must be consistent with applicable manufacturer's recommendations, industry standards or codes, good engineering practices and prior operating experience (if longer intervals used). 19 CCR 2755.5(d) Classification: Class II
Observations:

Other than monthly visual inspections of the ammonia tank and its secondary containment, there are no other documented inspections or tests of the ammonia equipment. There are no records of pressure relief device inspection, none of the tank integrity testing that was supposed to start in June 2014 and no inspections or tests of the ammonia pumps, ammonia injectors or ammonia detection sensors.

HM-924(01/15)

COUNTY OF SAN DIEGO

SUPPLEMENTAL COMPLIANCE

INSPECTION REPORT
INSPECTION DATE: 06/10/2016 PAGE 3 OF 12
RECORD ID #: DEH2011-HUPFP-214305
Corrective Action Due By:07/10/2016
Not later than 7/10/2016, make a record of all of the ammonia equipment. Then refer to each original equipment manufacturer recommendations and also use industry standards to make a schedule for inspections and testing of all ammonia equipment.

Then stick to the schedule, documenting that the inspections and tests are performed on all of the required equipment. By July 15, 2016, provide to me a statement that they are developed and are on site.

VIOLATION # 6
5010056 Failure to retain the two most recent compliance audit reports. 19 CCR 2755.6(e) Classification: Class II
Observations:

According to the CalARP Registration document, a CalARP Triennial Compliance Audit was conducted 3/13/2014. The audit itself was not located during the inspection. A 2009 compliance audit was located in the RMP book for the former owners, MMC.

Corrective Action Due By:07/10/2016
Not later than 7/10/2016 locate the 2014 CalARP Compliance Audit. Review the audit for recommendations. Address all recommendations in writing including how the recommendation was addressed, when and by whom. Maintain a copy of the Audit report and the recommendations. By July 15, 2016, provide to me a statement that the 2014 Compliance Audit Report has been located and is being maintained.

INSPECTION REMARKS:

CalARP Remarks:

Chula Vista Energy Center is regulated by the CUPA for a CalARP Program 2 Risk Management Plan. The last RMP submittal to the CUPA was March 2014. In May 2015, the RMP Qualified Person, Emergency Contact and Plant Manager changed to Stephen Cobbe. You must send an updated RMP to the CUPA at least every 5 years or when major changes occur. For changes in Program Level, you must send an updated RMP within 6 months of the change. Additionally, updates are required within 30 days for changes in RMP Qualified Person or RMP Emergency Contact.

No routine sensor calibration schedule was located during the inspection. No preventive maintenance records were located during the inspection as the computer management system is being changed. There were no paper records to review for any ammonia system maintenance. There were two entries in the Control Room Log Book that showed staff received 2 replacement ammonia sensors (AE-03 and AE-01), then they calibrated the sensors after they were installed. Operating procedures, with the exception of "Black Shut Down" procedures, "Ammonia Delivery" and "Normal CVEC Start Up" were not on site. This is a remote start system, so I was assured that the control room in Sacramento has the appropriate operating procedures including all of the requirements in Section 2755.3. None of the 3 procedures reviewed on site addressed consequences of deviations and steps required to avoid or correct deviations. Operating Procedures also need to include equipment inspections which cannot be conducted remotely.

During the inspection records were located that show evidence of annual calibration of the Ammonia Flow Meters and of the Selective Catalytic Reduction (SCR) catalyst.

As I wrote in 2014 inspection report: There are 8 ammonia sensors which are, according to operating procedures, set at 25 ppm high level and 75 ppm for high-high level alarms. The NIOSH recommended exposure limit is 25 ppm. Be advised the short term exposure limit (STEL) for ammonia is 35 ppm for a 15-minutes. The OSHA PEL (permissible exposure limit) is 50 ppm. o Consider why the high-high alarm was set at 75 ppm and consider lowering it to 50 ppm. o Ammonia Detection Sensor ending in serial number 110033 on the north side of the ammonium hydroxide (AE-04) is currently in "Fault" -"Sensor fail" status.

A Hazard Review (HR) was conducted in October 2013. There is a summary of findings on site that includes nine (9) recommendations 1.6.1.1 through 4.5.3.1. The recommendations must be addressed in a timely manner. Typically this is within one year of the recommendation. Be sure to always include, in writing, how the recommendation was addressed, by whom and the date the recommendation was addressed. For HR conducted after 2015, recommendation must be addressed in no more HM-924(01/15)

COUNTY OF SAN DIEGO

SUPPLEMENTAL COMPLIANCE

INSPECTION REPORT
INSPECTION DATE: 06/10/2016 PAGE 4 OF 12
RECORD ID #: DEH2011-HUPFP-214305
than 2.5 years from the HR date.
o Recommend that you address each recommendation form the 2013 HR as soon as possible and before 2018.

At this time, CalARP-specific information is not submitted through CERS. Submit any CalARP responsible party or other changes in writing within required regulatory time frames directly to the CUPA, not through CERS. For the HMBP Program when the emergency contacts for your facility change, you must document those changes through CERS within 30 days of when the change occurred.

HMBP Remarks:

If you have items that are not on site every day, such as the oxygen and acetylene, you are able to indicate that in CERS using the "days on site" data element on the individual chemical inventory sheet. Recommend you revise the site map to include the location of the fire hydrant.
o The current map is not capable of being reproduced by copy machine, please simplify the map.

Hazardous Waste Remarks:

Used oily water and oily solid wastes are generated on a regular basis.

SPCC Remarks:

This facility has 1075 gallons of APSA-regulated oils on site so is not regulated under California's Aboveground Petroleum Storage Act. This facility has a Federal SPCC plan on site that was last reviewed and certified in 2009. This is a courtesy reminder that you Federal SPCC plan must be reviewed and re-certified every 5 years.

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 ,Manon Maschue ,858.518.7390 [email protected]

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
Stephen J. Cobbe

TITLE OF FACILITY REPRESENTATIVE
Plant Manager

SIGNATURE

DATE SIGNED
06/10/2016
Department of Environmental Health, Hazardous Materials Division, P.O. Box 129261, San Diego, CA 92112-9261 Phone: (858) 505-6880 http://www.sdcdeh.org

C O U N T Y O F S A N D I E G O

COMPLIANCE INSPECTION REPORT
Handlers of Hazardous Materials and Small and Large
Quantity Generators of Hazardous Waste
INSPECTION DATE: 06/10/2016 PAGE 5 OF 12
RECORD ID #: DEH2011-HUPFP-214305
FACILITY NAME: *CHULA VISTA ENERGY CENTER, LLC
ADDRESS: * 3497 MAIN ST CITY/ZIP: *CHULA VISTA 91911
Each violation checked below is for the section(s) of the California Health and Safety Code (HSC), 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 Hazardous Materials Requirements
# VIOLATION DESCRIPTION
1010001 HMBP not established/ implemented. HSC 25505(a) and 25507(a) 1010002 HMBP not submitted to the CUPA in CERS. HSC 25508(a)(1)(A); HSC 25404(e)(4); 27 CCR 15188(a), (d)
1010003 Business Activities and/or Business Owner/Operator Identification not completed in CERS. 19 CCR 2729.2(a)(1); HSC 25404(e)(4) 1010004 Chemical inventory incomplete or not submitted in CERS. HSC 25505(a) (1); 25506; 25507; and 25508(a)(1)(A)
1010005 Site map not submitted in CERS or not sufficient. HSC 25505(a)(2) and 25508(a)(1)(A)
1010006 HMBP not updated to reflect inventory changes or facility information.

HSC 25508.1(a-e)
1010007 HMBP not updated to reflect substantial change to the handler's operations. HSC 25508.1(f)
1010008 HMBP not certified annually as complete and accurate in CERS. HSC 25508.2
1010010 Emergency response procedures to mitigate a release or threatened release not adequate, not established or not submitted in CERS. HSC 25505(a)(3) and 25508(a)(1)(A)
1010011 Failure to notify property owner in writing that the business is subject to the HMBP program. HSC 25505.1
1010012 Failure to provide a copy of HMBP to the property owner within five working days upon request from property owner. HSC 25505.1 1010014 Failure to submit emergency response plan in CERS, when not meeting agricultural handler exemption. HSC 25507.1(a) and 25508(a)(1)(A) 1010015 Failure to submit employee training plan in CERS, when not meeting agricultural handler exemption. HSC 25507.1(a) and 25508(a)(1)(A) 1010016 HMBP not established or submitted in CERS, when not meeting the remote site exemption. HSC 25507.2 and 25508(a)(1)(A)
1020001 Employee training plan for hazardous materials management not adequate, not established or not submitted in CERS. HSC 25505(a)(4) and 25508(a)(1)(A)
1020002 Initial and/or annual employee training not conducted for hazardous materials management and/or employee training records not available or not maintained for 3 years. HSC 25505(a)(4)
1040001 Hazardous materials release or threatened release not reported to the CUPA and OES immediately upon discovery. HSC 25510(a)
4010001 Failed to prepare and implement a written Spill Prevention Control and Countermeasures (SPCC) Plan in accordance with 40 CFR 112 (sec. 112.3). HSC 25270.4.5(a)
HMD
1001
Unified Program Facility permit not obtained for hazardous materials.

SDCC 68.905
HMD
1005
Emergency contact not provided or current. HSC 25508.1(f) HMD
1007
Highly toxic gas (TLV<10 ppm) not disclosed. SDCC 68.1113(b) HMD
1008
Annual carcinogen/reproductive toxin list not submitted. SDCC

68.1113(c)
HMD
1013
HMBP not readily available for review. HSC 25505(c)
Hazardous Waste Requirements for SQGs ONLY
HMD
0226
Did not accumulate waste in a container or tank. (40 CFR 262.34(d)(2).) 22 CCR 66262.34(d)(2)
HMD
0412
Failed to have an emergency coordinator on call or available during an emergency. (40 CFR 262.34(d)(5)(i).) 22 CCR 66262.34(d)(2) HM-923 (03-15)
Hazardous Waste Requirements for SQGs ONLY (continued)
# VIOLATION DESCRIPTION
3030007 Failed to properly label/date hazardous waste container and/or tank. 22 CCR 66262.34(f)
3030010 Accumulated waste too long (>180 or 270 days) (>90 days for an acutely hazardous waste). (40 CFR 262.34(e) and (f).) HSC 25201(a); 22 CCR 66262.34(d)
3030013 Failed to accumulate hazardous waste in a container that is in good condition. (40 CFR 262.34(d)(2); 265.171.) 22 CCR 66262.34(d)(2) 3030015 Failed to accumulate or store hazardous waste in a lined/compatible container. (40 CFR 262.34(d)(2); 265.172) 22 CCR 66262.34(d)(2) 3030017 Failed to properly close hazardous waste container(s). (40 CFR 262.34(d)(2); 265.173.) 22 CCR 66262.34(d)(2)
3030019 Failed to inspect hazardous waste storage area at least weekly. (40 CFR 262.34(d)(2); 265.174.) 22 CCR 66262.34(d)(2)
3030022 Failed to properly separate incompatible waste. (40 CFR 262.34(d)(2); 265.177.) 22 CCR 66262.34(d)(2)
3030030 Failed to maintain and/or operate the facility to minimize the possibility of a fire, explosion, or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents. (40 CFR 262.34(d)(4), 265.31.) 22 CCR 66262.34(d)(2)
3030036 Failed to maintain adequate aisle space. (40 CFR 262.34(d)(4); 265.35.) 22 CCR 66262.34(d)(2)
3010022 Failed to post, next to the telephone, emergency information containing the location of emergency equipment, contact names, and numbers. (40 CFR 262.34(d)(5)(ii).) 22 CCR 66262.34(d)(2) 3020001 Failed to ensure employees are trained for hazardous waste handling, compliance with regulations, and emergency response procedures. (40 CFR 262.34(d)(5)(iii).) 22 CCR 66262.34(d)(2)
3030032 Failed to maintain or have emergency equipment, supplies, or equivalents. 1) An internal communication or alarm system; 2) A device, such as a telephone; 3) Portable fire extinguishers, fire control equipment, spill control equipment, and decontamination equipment; and 4) Water at adequate volume and pressure (40 CFR 262.34(d)(4); 265.32) 22 CCR 66262.34(d)(2)
3030039 Failed to implement contingency plan during an emergency, spill/ release. (40 CFR 262.34(d)(5)(iv).) 22 CCR 66262.34(d)(2) Hazardous Waste Tank Systems for SQGs ONLY
3030024 Failed to maintain sufficient freeboard of 2 ft in uncovered tanks 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. (40 CFR 62.34(d)(3); 265.201(b)(c).) 22 CCR 66262.34(d)(2) 3030025 Failed to provide an overfill protection device on continuously fed hazardous waste tank. (40 CFR 262.34(d)(3); 265.201(b)(4).) 22 CCR 66262.34(d)(2)
3030027 Failed to conduct daily tank inspection of the discharge system, monitoring equipment, and tank level. (40 CFR 265.201(c)(1), 265.201(c)(2), 265.201(c)(3), 262.34(d)(3).) 22 CCR 66262.34(d)(2) 3030028 Failed to conduct weekly inspections of the construction materials, fixtures, and surrounding areas of the hazardous waste tank. (40 CFR 265.201(c)(4); 265.201(c)(5); 262.34(d)(3).) 22 CCR 66262.34(d)(2) 3050007 Failed to properly decontaminate and document closure of a hazardous waste tank system. (40 CFR 265.201(f).) 22 CCR 67383.3 HMD
1612
Hazardous waste improperly stored in a tank system causing leaks, corrosion, or failure. (40 CFR 265.201(b).) 22 CCR 66262.34(d) HMD
1614
Failed to pre-notify the CUPA in writing prior to closing a hazardous waste tank system. 22 CCR 67383.3(a)(1)
HMD
1615
Failed to properly accumulate ignitable or reactive waste in a tank system. (40 CFR 265.201(g).) 22 CCR 66262.34(d)(2)

C O U N T Y O F S A N D I E G O

COMPLIANCE INSPECTION REPORT
Hazardous Materials and Hazardous Waste (continued)
INSPECTION DATE: 06/10/2016 PAGE 6 OF 12
RECORD ID #: DEH2011-HUPFP-214305
Hazardous Waste Requirements for SQGs and LQGs

RECORD KEEPING/OPERATIONAL REQUIREMENTS
# VIOLATION DESCRIPTION
3010001 Unified Program Facility (UPF) permit not obtained for the generation of hazardous waste. HSC 25404.1; SDCC 68.905
3010029 The facility has not submitted complete and accurate facility information in CERS. HSC 25404(e)(4); 27 CCR 15188(b)
3010002 Failed to obtain and/or maintain an active EPA ID. 22 CCR 66262.12 3010008 Failed to properly complete a uniform hazardous waste manifest. 22 CCR 66262.23(a)
3010009 Failed to complete the hazardous waste manifest Exception Requirement. 22 CCR 66262.42
3010010 Failed to maintain uniform hazardous waste manifest, consolidated manifest, or bills of lading copies for 3 years. HSC 25160.2(b)(3), 25185(a)(4); 22 CCR 66262.40(a)
3010011 Failed to send hazardous waste manifest copies to the Department of Toxic Substances Control (DTSC). 22 CCR 66262.23(a)(4)
3010013 Failed to meet the consolidated manifesting requirements for waste shipment. HSC 25160.2; 22 CCR 66262.40(a)
3010014 Failed to retain disposal records of spent lead batteries for 3 years. 22 CCR 66266.81(a)(4)(B)
3030006 Failed to determine if a hazardous waste is restricted or prohibited from land disposal. 22 CCR 66268.7(a)
3010016 Failure of recycler who recycles more than 100 kilograms per month of recyclable material under a claim that the material qualifies for exclusion or exemption to provide and submit in CERS the required information. HSC 25143.10(a), (c), and/or (d)
HMD
0149
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 HMD
0148
Failed to have copies of analytical records, waste analysis records, and/ or waste determination results for 3 years. 22 CCR 66262.40(c) HMD
0140
Failed to have Land Disposal Restriction documentation onsite for 3 years. 22 CCR 66268.7(a)(8)
3250005 Failed to obtain a Treatment, Storage and Disposal Facility (TSDF) permit or authorization to store/treat/dispose of hazardous waste.

HSC 25201(a)
3050005 Failed to have adequate records demonstrating claim of exemption for Excluded Recyclable Materials. HSC 25143.2(f); 22 CCR 66261.2(g) 3210001 Failed to notify the CUPA in CERS for onsite hazardous waste treatment/tiered permitting. HSC 25201(a)
HMD
0138
Manifest signed by the TSDF not available for inspection. 22 CCR 66262.40(a)
Hazardous Waste Requirements for SQGs and LQGs

DISPOSAL AND TRANSPORTATION
3010007 Failed to prepare a hazardous waste manifest for the transport of a waste for off-site transfer, treatment, storage, or disposal. HSC 25160(b)(1) or (2), 25160.2(b)(9); 22 CCR 66262.20(a)
3030005 Failed to make a proper waste determination. 22 CCR 66262.11, 66262.40(c)
3050001 Failed to use a California registered hazardous waste transporter to transport hazardous waste. HSC 25163(a); 22 CCR 66263.41 3050002 Failed to properly dispose of hazardous waste at an authorized facility.

HSC 25189.5(a); 25189(c),(d); 25189.2(c)
3130002 Impermissible dilution of hazardous waste. 22 CCR 66268.3(a) HMD
0305
Disposed of used oil illegally. HSC 25250.5(a); 25189.5(a); 25189(c),(d); 25189.2(c)
HMD
0306
Disposed of hazardous waste latex paint improperly. HSC 25217.1 HM-923 (03-15)
Hazardous Waste Requirements for SQGs and LQGs

STORAGE AND HANDLING
# VIOLATION DESCRIPTION
3030001 Failed to meet requirements, when handling, and storing spent lead acid batteries. 22 CCR 66266.81(a)(1)
3030003 Failed to properly manage 'damaged' spent lead acid batteries. 22 CCR 66266.81(b)
3030004 Failed to properly manage, store, label, and/or recycle used oil filters and/or used fuel filters. HSC 25250.22; 22 CCR 66266.130 3050004 Failed to properly manage contaminated used oil as a hazardous waste. HSC 25250.7(a), (c)
HMD
0222
Failed to properly label Excluded Recyclable Materials (ERM). HSC 25143.9(a).

HMD
0216
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)
HMD
0217
Failed to repackage damaged/deteriorated hazardous material container within 96 hours. HSC 25124(b)(3)(B); 22 CCR 66262.34(f) HMD
0219
Failed to properly segregate used oil &/or fuel drained from filters.

HSC 25250.22(b)(4); 22 CCR 66266.130(c)(6)
HMD
0221
Failed to comply with hazardous waste satellite container regulation. 22 CCR 66262.34(e)
HMD
0223
Failed to properly empty container, failed to manage non-empty container, or inner liner removed from a container. 22 CCR 66261.7(b), (d) and/or (r); 66262.34(f)
HMD
0224
Failed to mark date on empty container larger than 5 gallons and/or manage it within one year. 22 CCR 66261.7(e),(f)
Universal Waste Handler Requirements
3010004 Failed to obtain an EPA ID number from DTSC or US EPA prior to storing 5,000 kg or more of universal waste. 22 CCR 66273.32(a),(b) 3020002 Failed to maintain universal waste handler training records for 3 years. 22 CCR 66273.36(c),(d)
3020003 Failed to properly train handlers of universal waste in universal waste management and response procedures. 22 CCR 66273.36(a),(b) 3030008 Failed to properly label or mark a universal waste (non-Conditionally Exempt Small Quantity Universal Waste Generator). 22 CCR 66273.34 3030011 Failed to properly dispose of universal waste within one year. 22 CCR 66273.35(a) and/or (b)
3030046 Failed to keep records of offsite universal waste (UW) shipment(s) available for inspection for 3 years. HSC 25185(a); 22 CCR 66273.39(c), (d)(2)
3030051 Failed to meet the accumulation standards for universal waste aerosol containers and waste handling. HSC 25201.16(f)
3040004 Failed to manage universal waste in a manner to prevent release(s) to the environment. 22 CCR 66273.33; 66273.33.5
3050003 Disposal of universal waste (UW) to an unauthorized point. HSC 25189.5(a), 25189(c),(d); 25189.2(c); 22 CCR 66273.31(a)

C O U N T Y O F S A N D I E G O

COMPLIANCE INSPECTION REPORT
Aboveground Petroleum Storage Act (APSA) Program
INSPECTION DATE: 06/10/2016 PAGE 7 OF 12
RECORD ID #: DEH2011-HUPFP-214305
Each violation checked below is for the section(s) of the California Health and Safety Code (HSC) or 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 a DEH Corrective Action Form (HM-926) or other correspondence to document your return to compliance. Please call (858) 505-6880 or your Specialist if you have any questions.

GENERAL APSA FACILITY REQUIREMENT
(Chapters 6.67 and 6.11 of Division 20 of the HSC)
# VIOLATION DESCRIPTION
4010001 Failed to prepare and implement a written spill prevention control and countermeasures (SPCC) Plan in accordance with 40 CFR Part 112 (sec. 112.3). HSC 25270.4.5(a)
4010013 Plan does not conform to and/or facility is not fully implementing, the latest version of the regulations in 40 CFR Part 112. HSC 25270.4.5(a) (see detail below)
4010032 Failed to submit a tank facility statement or update/certify business plan annually. HSC 25270.6(a)(1) or (a)(2)
4010033 Failed to pay the APSA program fee or obtain Unified Program Facility Permit. HSC 25270.6(b), SDCC 68.905
4040001 Failed to immediately, upon discovery, report a one-barrel (42 gallons) or greater release of petroleum. HSC 25270.8
4010038 Failed to report required program data electronically. HSC 25404(e)(4), HSC 25270.6(b), SDCC 68.905
4010037 Failed to meet provisions of APSA exemption for oil-filled electrical equipment including containment and visual inspection. HSC 25270.2(a)(4)
REQUIREMENTS BASED ON 40 CFR 112.1-112.6
4010035 Failed to meet the conditions of a Qualified Facility. (40 CFR 112.3(a) (1), 112.3(g), 112.6.) HSC 25270.4.5(a)
4010003 Failed to have a professional engineer certify and review the SPCC Plan. (40 CFR 112.3(d).) HSC 25270.4.5(a)
4010008 Failed to maintain a copy of the Plan on site (applies if facility is manned at least 4 hours/day). (40 CFR 112.3(e)(1).) HSC 25270.4.5(a) 4010010 Failed to make SPCC plan technical amendment(s) when the facility has had a change in: design, construction, operation, or maintenance which affects the facility's discharge potential. (40 CFR 112.5(a).) HSC 25270.4.5(a)
4010009 Failed to perform a 5-year review of the SPCC Plan. (40 CFR 112.5(b).) HSC 25270.4.5(a)
4010011 Failed to have a professional engineer certify technical amendments. (40 CFR 112.5(c). HSC 25270.4.5(a)

GENERAL SPCC REQUIREMENTS
BASED UPON 40 CFR 112.7
4010012 Failed to prepare a SPCC plan that follows the sequence of rule and/or to cross-reference; failed to prepare plan in writing; failed to prepare a plan that addresses additional procedures/methods/equipment not fully operational. (40 CFR 112.7 and 112.7(a)(1).) HSC 25270.4.5(a) 4010002 Failed to obtain facility management approval to commit resources to fully implement the SPCC Plan. (40 CFR 112.7.) HSC 25270.4.5(a) 4010014 Failed to discuss alternative environmental protection to SPCC requirements within SPCC Plan. (40 CFR 112.7(a)(2).) HSC 25270.4.5(a) 4010015 Failed to have an adequate facility diagram, including location of oil storage/transfer areas and connecting pipes, or no facility diagram included in SPCC plan. (40 CFR 112.7(a)(3).) HSC 25270.4.5(a) 4010016 Failed to adequately describe the physical layout of facility, including location of oil storage/transfer areas/connecting pipes or no description of physical layout included in SPCC Plan. (40 CFR 112.7(a) (3), 112.7(a)(3)(i-vi).) HSC 25270.4.5(a)
HM-950 APSA (02-15)

GENERAL SPCC REQUIREMENTS
BASED UPON 40 CFR 112.7 (continued)
# VIOLATION DESCRIPTION
4010017 Plan does not contain procedures for reporting a discharge if facility has no Facility Response Plan. (40 CFR 112.7(a)(4).) HSC 25270.4.5(a) 4010018 Discharge procedures are not adequately addressed if facility has no Facility Response Plan. (40 CFR 112.7(a)(5).) HSC 25270.4.5(a) 4010019 Failed to include prediction of the direction, rate of flow, and total quantity of oil which could be discharged from facility as a result of each type of equipment failure in the SPCC Plan. (40 CFR 112.7(b).) HSC 25270.4.5(a)
4010020 General Containment: Failed to provide, or discuss within the plan, appropriate containment/diversionary structures/equipment designed to address the typical failure, so that any discharge will not escape containment before cleanup occurs. (40 CFR 112.7(c).) HSC 25270.4.5(a)
4010004 Failed to have a professional engineer clearly denote and demonstrate the impracticability of appropriate containment/diversionary structures. (40 CFR 112.7(d).) HSC 25270.4.5(a)
4010005 Failed to prepare an Oil Spill Contingency Plan following the provisions of 40 CFR Part 109 for impracticability claim. This is not required if facility has a Facility Response Plan. (40 CFR 112.7(d)(1).) HSC 25270.4.5(a)
4010006 Failed to provide a written commitment of manpower, equipment, materials for impracticability claim. (40 CFR 112.7(d)(2).) HSC 25270.4.5(a)
4010021 Failed to address in SPCC plan/maintain complete records of:
inspections, tests/procedures for 3 years. (40 CFR 112.7(e), 112.8(c) (6).) HSC 25270.4.5(a)
4020001 Failed to train oil-handling personnel on operation/maintenance of equipment to prevent discharges; discharge procedure protocols; applicable laws, rules, and regulations; general facility operations; AND the contents of the SPCC Plan. (40 CFR 112.7(f)(1).) HSC 25270.4.5(a) 4010022 Failed to designate person accountable for discharge prevention who reports to facility management. (40 CFR 112.7(f)(2).) HSC 25270.4.5(a) 4010023 Failed to conduct annual discharge prevention briefings to ensure understanding of SPCC plan. (40 CFR 112.7(f)(3).) HSC 25270.4.5(a) 4030001 Failed to address security of oil handling areas/valves, prevent unauthorized access to starter controls, cap/blank flange connections not in service and provide appropriate lighting to prevent vandalism and assist in discovery of discharges. (40 CFR 112.7(g).) HSC 25270.4.5(a)
4030002 Failure of the secondary containment, and/or rack drainage to flow to a catchment basin, treatment system, or quick drainage system and hold at least the maximum capacity of the largest single compartment of any tank car or tank truck. (40 CFR 112.7(h)(1).) HSC 25270.4.5(a) 4030003 Failed to provide system to prevent vehicular departure before disconnect from transfer lines. (40 CFR 112.7(h)(2).) HSC 25270.4.5(a) 4030004 Failed to inspect lowermost drains and outlets prior to filling and departure of tank car or tank truck. (40 CFR 112.7(h)(3).) HSC 25270.4.5(a)
4030016 Failed to evaluate field-constructed storage tank for brittle fracture and take appropriate action. (40 CFR 112.7(i).) HSC 25270.4.5(a) 4010007 Failed to include discussion of conformance with requirements listed in 40 CFR Part 112. (40 CFR 112.7(j).) HSC 25270.4.5(a)

C O U N T Y O F S A N D I E G O

COMPLIANCE INSPECTION REPORT
APSA Program (continued)
INSPECTION DATE: 06/10/2016 PAGE 8 OF 12
RECORD ID #: DEH2011-HUPFP-214305
SPCC REQUIREMENTS BASED UPON 40 CFR 112.8
Refer to APSA (HSC Chapter 6.67) for definition of “storage tank” # VIOLATION DESCRIPTION
4010027 Failure to restrain drainage from diked storage areas by valves to prevent discharge. (40 CFR 112.8(b)(1).) HSC 25270.4.5(a) 4030005 Failure to use valves of manual, open and closed design, for drainage of diked areas. (40 CFR 112.8(b)(2).) HSC 25270.4.5(a)
4030008 Facility drainage system from undiked areas not designed/equipped to retain oil or return to facility and/or failed to ensure catchment basin not in an area subject to flooding. (40 CFR 112.8(b)(3), 112.8(b)(4).) HSC 25270.4.5(a)
4030009 Failed to provide at least two lift pumps and permanently install one pump where drainage waters are treated in more than one treatment unit and such treatment is continuous. (40 CFR 112.8(b)(5).) HSC 25270.4.5(a)
4030012 Storage tanks not compatible with materials stored or conditions such as pressure/temperature. (40 CFR 112.8(c)(1).) HSC 25270.4.5(a) 4030010 (Sized Containment) Secondary containment not sized to contain the entire capacity of the largest single storage tank plus freeboard for precipitation. (40 CFR 112.8(c)(2).) HSC 25270.4.5(a)
4030013 Failure to ensure diked areas are sufficiently impervious to contain discharged oil. (40 CFR 112.8(c)(2).) HSC 25270.4.5(a)
4030011 Failed to keep containment bypass valves closed when not draining rainwater. (40 CFR 112.8(c)(3)(i).) HSC 25270.4.5(a)
4030006 Failed to inspect retained rainwater prior to discharge. (40 CFR 112.8(c)(3)(ii).) HSC 25270.4.5(a)
4030007 Failed to open and close bypass valve to drain rainwater under responsible supervision. (40 CFR 112.8(c)(3)(iii).) HSC 25270.4.5(a) 4010026 Failed to maintain adequate records (or NPDES permit records) of drainage from diked areas. (40 CFR 112.8(c)(3)(iv).) HSC 25270.4.5(a) 4030017 Failed to provide corrosion protection for partially buried storage tanks. (40 CFR 112.8(c)(5).) HSC 25270.4.5(a)
4030015 Failed to test or inspect each storage tank for integrity, in accordance with industry standards that take into account size, configuration, and design, on a regular schedule or after material repairs. (40 CFR 112.8(c) (6).) HSC 25270.4.5(a)
4030014 Failed to perform scheduled storage tank tests and inspections by appropriately qualified personnel. (40 CFR 112.8(c)(6).) HSC 25270.4.5(a)
4010028 Failed to frequently inspect the outside of each storage tank for signs of deterioration, discharges, accumulation of oil in diked areas, including supports/foundations; failed to keep records of inspections, tests and comparison records. (40 CFR 112.8(c)(6).) HSC 25270.4.5(a) 4030018 Failure of steam return/exhaust of internal heating coils, which discharge into an open water course, to be monitored, passed through a settling tank, skimmer, or other separation system. (40 CFR 112.8(c) (7).) HSC25270.4.5(a)
4030019 Failed to provide each storage tank with a high level monitoring device, or implement procedures to prevent discharges caused by overfills, in compliance with 40 CFR Part 112. (40 CFR 112.8(c)(8)(i-iv).) HSC 25270.4.5(a)
4030022 Failed to regularly test liquid level sensing devices to ensure proper operation. (40 CFR 112.8(c)(8)(v).) HSC 25270.4.5(a)
4030023 Failure to frequently observe effluent treatment facilities, which discharge directly to navigable waters, to detect oil spills. (40 CFR 112.8(c)(9).) HSC 25270.4.5(a)
4030021 Failed to promptly correct visible discharges and/or remove accumulations of oil in diked areas. (40 CFR 112.8(c)(10).) HSC 25270.4.5(a)
4030024 (For mobile or portable storage tanks AND mobile refuelers) Failed to locate mobile or portable containers to prevent discharge. (40 CFR 112.8(c)(11).) HSC 25270.4.5(a)
4030020 (For mobile or portable storage tanks EXCEPT mobile refuelers) Failed to provide secondary containment sufficient to contain the capacity of the largest single compartment or container with sufficient freeboard for precipitation. (40 CFR 112.8(c)(11).) HSC 25270.4.5(a) HM-950 APSA (02-15)
SPCC REQUIREMENTS BASED UPON 40 CFR 112.8 (continued)
Refer to APSA (HSC Chapter 6.67) for definition of “storage tank” # VIOLATION DESCRIPTION
4030025 Failed to inspect buried piping when exposed for any reason; failed to do additional examination or take corrective action if corrosion damage is identified. (40 CFR 112.8(d)(1).) HSC 25270.4.5(a) 4030027 Failed to provide corrosion protection for buried piping. (40 CFR 112.8(d)(1).) HSC 25270.4.5(a)
4030028 Failed to cap/blank-flange piping connection at transfer point and mark its origin if not in service. (40 CFR 112.8(d)(2).) HSC 25270.4.5(a) 4030029 Failed to design pipe supports to minimize abrasion/corrosion and to allow for expansion/contraction. (40 CFR 112.8(d)(3).) HSC 25270.4.5(a)
4030026 Failed to regularly inspect aboveground valves, piping, and appurtenances. (40 CFR 112.8(d)(4).) HSC 25270.4.5(a)
4030030 Failed to conduct integrity and leak test on buried piping at installation, modification, construction, relocation or replacement. (40 CFR 112.8(d)(4).) HSC 25270.4.5(a)
4030031 Failed to adequately warn vehicles entering facility to protect piping and other transfer operations. (40 CFR 112.8(d)(5).) HSC 25270.4.5(a)

C O U N T Y O F S A N D I E G O

COMPLIANCE INSPECTION REPORT
California Accidental Release Prevention (CalARP)Program INSPECTION DATE: 06/10/2016 PAGE 9 OF 12
RECORD ID #: DEH2011-HUPFP-214305
VIOLATION REPORT: Each violation checked below is for the section(s) of the California Health and Safety Code (HSC), 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) and Title 42 of the United States Code (USC) 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. Administering Agency (AA); process hazard analysis (PHA); process safety information (PSI); emergency response (ER); regulated substance (RS); stationary source (SS); threshold quantity (TQ) CalARP Program – General (All Program Levels)
# VIOLATION DESCRIPTION
5010001 Failure to comply with the provisions of this chapter pursuant to the time frames identified in section 2745.1(b) if a SS has a process with more than a TQ of a RS as listed in Tables 1 or 2 of section 2770.5. 19 CCR 2735.4(a)(1)
5010002 Failure to comply with the appropriate provisions of this chapter pursuant to the time frames identified in section 2745.1(d) or (e) if a SS has a process with more than a TQ of a RS as listed in Table 3 of section 2770.5. 19 CCR 2735.4(a)(2)
5010003 Failure to comply with the provisions of this chapter pursuant to the time frames identified in section 2745.1(b) if a ss has a process with more than a TQ of a RS as listed in Tables 1 or 2 and Table 3 of section 2770.5. 19 CCR 2735.4(a)(3)
5010004 Failure of the owner or operator of a ss to closely coordinate with the AA to implement the requirements of this chapter and to determine the appropriate level documentation required for a RMP to comply with sections 2745.3 through 2745.9. 19 CCR 2735.5(a)
5010008 Failure to include a registration in the RMP that reflects all covered processes. 19 CCR 2735.5(b)(2)
5010012 Failure to complete the registration information required in section 2740.1(d) and submit it with the RMP to the USEPA, with a copy provided to the AA. 19 CCR 2740.1(a)
5010013 Failure to complete the registration information required in section 2740.1(d) of this section and submit it with the RMP to the AA. 19 CCR 2740.1(b)
5010014 Failure to submit a registration to the AA prior to submittal of the RMP upon request. 19 CCR 2740.1(c)
5010015 Failure to include the data required in section 2740.1 (d)(1) through (d) (20) in the registration. 19 CCR 2740.1(d)
5010016 Failure to submit the RMP information required by the USEPA to the USEPA and the AA, per the schedule below: 1. Three years after the date on which a RS is first listed under 40 CFR 68.130; or 2. The date on which a RS is first present in a process, above the TQ, as listed on section 2770.5 Table 1 or 2. 19 CCR 2745.1(b)(2), 2745.1(b)(3) 5010017 Failure to submit a copy of the USEPA required RMP information according to the time frame set forth in section 2745.1(b) to the AA. 19 CCR 2745.1(c)
5010018 Failure of an existing SS to submit a RMP to the AA after the owner or operator has received a notice from the AA requesting submission of an RMP. The AA shall not require submission of the RMP earlier the 12 months or later than 3 years after the notice has been issued to the owner or operator. 19 CCR 2745.1(d)
5010019 Failure of a new or modified SS to submit a RMP to the AA prior to the date in which a RS is first present in a process above the listed TQ. 19 CCR 2745.1(e)
5010020 Failure to exclude classified information from the RMP. 19 CCR 2745.1(j)
5010021 Failure to ensure that the RMP is certified complete by a qualified person and the SS owner or operator. 19 CCR 2745.2(a)(1) 5010022 Failure to correct deficiencies within 60 calendar days from receipt of the notification of RMP deficiencies. 19 CCR 2745.2(a)(3)(A) 5010025 Failure to revise, update, and submit the RMP to the USEPA and the AA as follows: 1. At least once every five years from the date of its initial submission or most recent update required by section 2745.10(a)(2) through (7); 2. No later than three years after a newly RS is first listed by the USEPA; 3. No later than the date on which on which a new RS is first present in an already covered process above a TQ; 4. No later than the date on which a RS is first present above a TQ in a new process; 5.

Within six months of a change that requires a revised process hazard analysis or hazard review or 6. Within six months of a change that requires a revised offsite consequence analysis as provided in section 2750.7 or 7. Within six months of a change that alters the program level that applied to any covered process. 19 CCR 2745.10(a), 2745.10(b)
HM-972 CalARP ( 02-15)

# VIOLATION DESCRIPTION
5010026 Failure to revise, update, and submit the RMP to the AA as follows: 1.

At least once every five years from the date of its initial submission or most recent update required by section 2745.10(b)(2) through (7); 2.

No later than three years after a newly RS is first listed by the CalOES;

3. No later than the date on which on which a new RS is first present in an already covered process above a TQ; 4. No later than the date on which a RS is first present above a TQ in a new process; 5. Within six months of a change that requires a revised process hazard analysis or hazard review. 6. Within six months of a change that requires a revised offsite consequence analysis as provided in section 2750.7; 7. Within six months of a change that alters the program level that applied to any covered process. 19 CCR 2745.10(a), 2745.10(b)
5010027 Failure to submit a de-registration to the USEPA and the AA within six months indicating that the SS is no longer covered. 19 CCR 2745.10(c) 5010028 Failure to submit a de-registration to the AA within six months indicating that the SS is no longer covered. 19 CCR 2745.10(c) [Table 1 or 2] or 19 CCR 2745.10(d) [Table 3]
2 ✖5010029 Failure to contact the AA within 30 days of a change of owner or operator to update the registration information. 19 CCR 2745.10(f) 5010030 Failure to correct and submit the data required in the RMP under sections 2745.5, 2745.6(j), and 2745.7(l) with respect to that accident within six months of the release or by the time the RMP is updated under section 2745.10, whichever is earlier. 19 CCR 2745.10.5(a)(1) 1 ✖5010031 Failure to correct and submit the emergency contact information in the RMP required under section 2740.1(d)(6) within one month of any change. 19 CCR 2745.10.5(a)(2)
5010032 Failure to notify the AA in writing of the intent to modify the SS at least five calendar days before implementing any modifications. 19 CCR 2745.11(a)(1)
5010033 Failure to notify the AA in writing of the intent to modify the SS no later than 48 hours following the modification. 19 CCR 2745.11(a)(2) 5010034 Failure of a new or modified SS to comply with section 65850.2(b) of the Government Code prior to the issuance of a certificate of occupancy. 19 CCR 2745.12
5010119 Failure to maintain records supporting the implementation of this chapter for five years unless otherwise provided in Article 6 of this chapter. 19 CCR 2775.1
5010120 Failure to closely coordinate with the AA to ensure that appropriate technical standards are applied to the implementation of this chapter. 19 CCR 2775.1(a)
5010121 Failure to request assistance from the AA when necessary to address compliance with this chapter or safety issues regarding unfamiliar processes. 19 CCR 2775.1(b)
5010122 Failure to report program data electronically. HSC 25404(e)(4) CalARP Program Level 1
5010005 Failure to submit an RMP which includes all requirements described in section 2745.3 through 2745.5 and 2745.8 through 2745.9. 19 CCR 2735.5(b)(1), 2735.5(d), 2745.1(a)
5010006 Failure to ensure that response actions have been coordinated with local emergency planning and response agencies. 19 CCR 2735.5(d)(3) 5010023 Failure to submit in the RMP the certification statement provided in section 2735.5(d)(4). 19 CCR 2745.9(a)
5010035 Failure to prepare a worst-case release scenario analysis as provided in section 2750.3. 19 CCR 2750.1
5010036 Failure to complete the five-year accident history as provided in section 2750.9. 19 CCR 2750.1

C O U N T Y O F S A N D I E G O

COMPLIANCE INSPECTION REPORT
CalARP Program (continued)
INSPECTION DATE: 06/10/2016 PAGE 10 OF 12
RECORD ID #: DEH2011-HUPFP-214305
CalARP Program Levels 2 & 3
# VIOLATION DESCRIPTION
5010007 Failure to submit an RMP which includes all requirements described in sections 2745.3 through 2745.9. 19 CCR 2735.5(b)(1), 2745.1(a) 5010009 Failure to develop a management system to oversee the implementation of the risk management program elements. 19 CCR 2735.6(a)
5010010 Failure to assign a qualified person or position who has the overall responsibility for the development, implementation, and integration of the risk management program elements. 19 CCR 2735.6(b)
5010011 Failure to document the following when responsibility for implementing individual requirements of this chapter is assigned to persons other than the person identified under section (b): 1. Names or positions. 2. Lines of authority defined through an organization chart or similar document. 19 CCR 2735.6(c)
5010024 Failure to submit in the RMP a single certification that, to the best of the signer's knowledge, information, and belief formed after reasonable inquiry, the information submitted is true, accurate, and complete. 19 CCR 2745.9(b)
5010037 Failure to comply with sections 2750.2 through 2750.9 [Hazard Assessment]. 19 CCR 2750.1
CalARP Program Level 2
5010038 Failure to compile and maintain the following up-to-date safety information related to the RS, processes, and equipment: 1. MSDSs that meet the requirements of 8 CCR 5189; 2. Maximum intended inventory of equipment in which the RS are stored or processed; 3.

Safe upper & lower temperatures, pressures, flows and compositions;

4. Equipment specifications; 5. Codes & standards used to design, build & operate the process. 19 CCR 2755.1(a)
5010039 Failure to ensure that the process is designed in compliance with recognized and generally accepted good engineering practices. 19 CCR 2755.1(b)
5010040 Failure to update the safety information if a major change occurs that makes the information inaccurate. 19 CCR 2755.1(c)
5010041 Failure to conduct a review of the hazards associated with the RS, process, and procedures that identifies the following: 1. The hazards associated with the process and RS; 2. Opportunities for equipment malfunctions or human errors that could cause an accidental release;

3. The safeguards used or needed to control the hazards or prevent equipment malfunction or human error; 4. Any steps used or needed to detect or monitor releases. 19 CCR 2755.2(a)
5010042 Failure to consult with the AA to decide which hazard review methodology is best suited to determine and evaluate the hazards of the process being analyzed. 19 CCR 2755.2(b)
5010043 Failure to perform the hazard review with a team familiar with the process operations and include at least one employee who has experience and knowledge specific to the process being reviewed.

Failure to determine whether the process is designed, fabricated, and operated in accordance with applicable standards or rules. 19 CCR 2755.2(c)
5010044 Failure to include the consideration of external events, including seismic events. 19 CCR 2755.2(d)
5010045 Failure to document the results of the hazard review and ensure that problems identified are resolved as required by this section. 19 CCR 2755.2(e)
5010046 Failure to update the hazard review at least once every five years. 19 CCR 2755.2(f)
5010047 Failure to update the hazard review whenever a major change in the process occurs. 19 CCR 2755.2(f)
5010048 Failure to resolve all issues identified in the hazard review before startup of the changed process. 19 CCR 2755.2(f)
3 ✖5010049 Failure to prepare written operating procedures that provide clear instructions or steps for safely conducting activities associated with each covered process consistent with the safety information for that process and address the following: 1. Initial startup; 2. Normal operations; 3. Temporary operations; 4. Emergency shutdown and operations; 5. Normal shutdown; 6. Startup following a normal or emergency shutdown or a major change that requires a hazard review;

7. Consequences of deviations and steps required to correct or avoid deviations; 8. Equipment inspections. 19 CCR 2755.3(a)(b) 5010050 Failure to ensure that the operating procedures are developed or updated, as necessary to reflect current practice, or whenever the tasks or steps to perform on the covered process are inadequate or inaccurate. 19 CCR 2755.3(c)
4 ✖5010051 Failure to prepare and implement written procedures to maintain the on-going mechanical integrity of the process equipment. 19 CCR 2755.5(a)
5010052 Failure to certify that they have evaluated compliance with the provisions of this article at least every three years to verify that the procedures and practices developed under this chapter are adequate and are being followed. 19 CCR 2755.6(a)
5010053 Failure to conduct the compliance audit by at least one person knowledgeable in the process. 19 CCR 2755.6(b)
HM-972 CalARP ( 02-15)
CalARP Program Level 2 (continued)
# VIOLATION DESCRIPTION
5010054 Failure to develop a report of audit findings. 19 CCR 2755.6(c) 5010055 Failure to determine and document an appropriate response to each of the findings of the compliance audit and document that deficiencies have been corrected, including completion dates, according to timelines required by this section. 19 CCR 2755.6(d)
6 ✖5010056 Failure to retain the two most recent compliance audit reports. 19 CCR 2755.6(e)
5010057 Failure to investigate each incident which resulted in, or could reasonably have resulted in, a catastrophic release. 19 CCR 2755.7(a) 5010058 Failure to initiate an incident investigation, as promptly as possible, but within 48 hours of the incident. 19 CCR 2755.7(b)
5010059 Failure to prepare a summary of the investigation at the conclusion of the investigation that includes at a minimum: 1. Date the investigation began; 2. A description of incident including all of the data required under sections 2570.9(b) and, 3. Recommendations resulting from the investigation. 19 CCR 2755.7(c)
5010060 Failure to promptly address and resolve the investigation findings and recommendations. 19 CCR 2755.7(d)
5010061 Failure to document resolutions and corrective actions including actual completion dates according to the timelines required by this section. 19 CCR 2755.7(d)
5010062 Failure to review the findings with all affected personnel whose job tasks are affected by the findings. 19 CCR 2755.7(e)
5010063 Failure to retain investigation summaries for five years. 19 CCR 2755.7(f)
5010115 Failure of a SS whose employees will not respond to accidental releases of RS to meet the following: 1. Document inclusion in the community ER plan developed under 42 USC 11003, in the City or County Hazardous Materials Area Plans and/or in the hazardous materials business plan program pursuant to HSC 25507 for stationary sources with any regulated toxic substances held in a process above the TQ; 2. Document coordinated response actions with the local fire department and hazardous materials response agencies for stationary sources with only regulated flammable substances held in a process above the TQ; 3. Appropriate mechanisms and written procedures are in place to notify emergency responders when there is a need for a response. 19 CCR 2765.1(b)
5010116 Failure to develop, implement, and maintain at the SS an ER program that includes the following elements: 1. Procedures for informing and interfacing with the public and local ER agencies about accidental releases, emergency planning, and ER; 2. Documentation of proper first-aid and emergency medical treatment necessary to treat accidental human exposures; 3. Procedures and measures for ER after an accidental release of a RS; 4. Procedures for the use of ER equipment and for its inspection, testing, and maintenance are developed by the SS; 5. Training for all employees in relevant procedures and relevant aspects of the Incident Command System; 6.

Procedures to review and update the ER plan to reflect changes at the SS are developed and employees are informed of these changes. 19 CCR 2765.2(a)
5010117 Failure to coordinate the emergency response plan with the community emergency response plan developed under 42 USC 11003. 19 CCR 2765.2(b)
5010118 Failure to promptly provide to the Local Emergency Planning Committee (LEPC) or ER officials information necessary for developing and implementing the community emergency response plan upon request. 19 CCR 2765.2(c)
5020002 Failure to provide refresher training at least every three years, and more often if necessary, to each employee operating a process to ensure that the employee understands and adheres to the current operating procedures of the process. 19 CCR 2755.4(b)
5020003 Failure to ensure operators are trained in any updated or new procedures prior to startup of a process after a major change. 19 CCR 2755.4(d)
5020004 Failure to train or cause to be trained each employee involved in maintaining the on-going mechanical integrity of the process in: 1. The hazards of the process; 2. How to avoid or correct unsafe conditions; 3.

The procedures applicable to the employee's job tasks. 19 CCR 2755.5(b)
5020005 Failure of the SS owner/operator to ensure that each contractor can document their employees are trained to perform the maintenance and appropriate operation procedures developed under section 2755.5(a). 19 CCR 2755.5(c)
5 ✖5030001 Failure to perform or cause to be performed inspections and tests on process equipment that: 1. Follow recognized and generally accepted good engineering practices; 2. The frequency of inspections & tests must be consistent with applicable manufacturer's recommendations, industry standards or codes, good engineering practices and prior operating experience (if longer intervals used). 19 CCR 2755.5(d)

C O U N T Y O F S A N D I E G O

COMPLIANCE INSPECTION REPORT
CalARP Program (continued)
INSPECTION DATE: 06/10/2016 PAGE 11 OF 12
RECORD ID #: DEH2011-HUPFP-214305
CalARP Program Level 3
# VIOLATION DESCRIPTION
5010064 Failure to compile, maintain and keep up-to-date written process safety information pertaining to the hazards of the RS in the process that includes: 1. Toxicity information; 2. PELs; 3. Physical data; 4.

Reactivity data & chemical compatibility data during handling, use and application at the stationary source; 5. Corrosivity data; 6. Thermal & chemical stability data; &, 7. Hazardous effects of inadvertent mixing of different materials that could foreseeably occur. 19 CCR 2760.1(a), 2760.1(b)
5010065 Failure to compile, maintain and keep up-to-date written process safety information concerning the technology of the process that includes: 1. A block flow diagram or simplified process flow diagram; 2.

Process chemistry; 3. Maximum intended inventory; 4. Safe upper and lower limits for such items as temperatures, pressures, flows or compositions; and, 5. An evaluation of the consequences of deviations. 19 CCR 2760.1(a), 2760.1(c)
5010066 Failure to compile, maintain and keep up-to-date written process safety information pertaining to the equipment in the process that includes: 1. Materials of construction; 2. P&IDs; 3. Electrical classification; 4. Relief system design and design basis; 5. Ventilation system design; 6. Design codes and standards employed; 7. Material and energy balances for processes built after June 21, 1999; 8. Safety systems (e.g., interlocks, detection, or suppression systems). 19 CCR 2760.1(a), 2760.1(d)(1)
5010067 Failure to document that equipment complies with recognized and generally accepted good engineering practices. 19 CCR 2760.1(d)(2) 5010068 For existing equipment designed and constructed in accordance with codes, standards, or practices that are no longer in general use, the owner or operator has determined and documented that the equipment is designed, maintained, inspected, tested, and operating in a safe manner. 19 CCR 2760.1(d)(3)
5010069 Failure to conduct an initial PHA on the covered processes no later than the date of submittal of the RMP. 19 CCR 2760.2(a) 5010070 Failure to perform a PHA that is appropriate to the complexity of the process and identifies, evaluates, and controls the hazards involved in the process. 19 CCR 2760.2(a)
5010071 Failure to determine and document the priority order for conducting PHA based on a rationale which include such considerations as extent of the process hazards, number of potentially affected employees, age of the process, and operating history of the process. 19 CCR 2760.2(a) 5010072 Failure to work closely with the AA in deciding which PHA methodology is best suited to determine the hazards of the process being analyzed. 19 CCR 2760.2(b)
5010073 Failure to use one or more of the following methodologies that are appropriate to determine and evaluate the hazards of the process being analyzed: 1. What-If; 2. Checklist; 3. What-If/Checklist; 4. Hazard and Operability Study (HAZOP); 5. Failure Mode and Effects Analysis (FMEA); 6. Fault Tree Analysis; or, 7. An appropriate equivalent methodology. 19 CCR 2760.2(b)
5010074 Failure to address the following in the PHA: 1. The hazards of the process; 2. Identification of any previous incident with a likely potential for catastrophic consequences; 3. Engineering & administrative controls applicable to the hazards and their interrelationships such as appropriate application of detection methodologies to provide early warning of releases. (e.g., process monitoring and control instrumentation with alarms, and detection hardware such as hydrocarbon sensors.); 4. Consequences of failure of engineering & administrative controls; 5. SS siting; 6. Human factors; 7.

A qualitative evaluation of a range of the possible safety & health effects of failure of controls; and, 8. External events, including seismic events. 19 CCR 2760.2(c)
5010075 Failure to perform the PHA by a team with expertise in engineering and process operations, including at least one employee who has experience and knowledge specific to the process being evaluated, and one member who is knowledgeable in the specific PHA methodology being used. 19 CCR 2760.2(d)
5010076 Failure to address the following in the PHA: 1. Establish a system to address the team's findings & recommendations; 2. Assure that the recommendations are resolved & documented; 3. Document the actions to be taken; 4. Develop a written schedule to complete these actions; 5. Complete the actions according to the required timetables;

6. Document the final resolution taken to address each
recommendation and the actual completion date; 7. Communicate the actions to operating, maintenance and other employees whose work assignments are in the process and who may be affected by the recommendations or actions. 19 CCR 2760.2(e)
5010077 Failure to update and revalidate the PHA at least every five years after the completion of the initial PHA. 19 CCR 2760.2(f)
5010078 Failure to retain the PHA and updates or revalidations for each covered process & the documented resolution of recommendations for the life of the process. 19 CCR 2760.2(g)
HM-972 CalARP ( 02-15)

# VIOLATION DESCRIPTION
5010079 Failure to develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information. 19 CCR 2760.3(a)
5010080 Failure to develop and implement written operating procedures for each operating phase that address at least the following elements: 1.

Initial startup; 2. Normal operations; 3. Temporary operations; 4.

Emergency shutdown including the conditions under which emergency shutdown is required, and the assignment of shutdown responsibility to qualified operators to ensure that emergency shutdown is executed in a safe and timely manner; 5. Emergency operations; 6. Normal shutdown; 7. Startup following a turnaround, or after an emergency shutdown. 19 CCR 2760.3(a)(1)
5010081 Failure to develop and implement written operating procedures for operating limits that address at least the following elements: 1.

Consequences of deviation; 2. Steps required to correct or avoid deviation. 19 CCR 2760.3(a)(2)
5010082 Failure to develop and implement written operating procedures for safety and health considerations that address at least the following elements: 1. Properties of, and hazards presented by, the chemicals used in the process; 2. Precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment; 3. Control measures to be taken if physical contact or airborne exposure occurs; 4. Quality control for raw materials and control of hazardous chemical inventory levels, and; 5.

Any special or unique hazards. 19 CCR 2760.3(a)(3)
5010083 Failure to develop and implement written operating procedures for safety systems and their functions. 19 CCR 2760.3(a)(4) 5010084 Failure to make operating procedures readily accessible to employees who work in or maintain a process. 19 CCR 2760.3(b)
5010085 Failure to review operating procedures as often as necessary to assure that they reflect current operating practice, including changes that result from changes in process chemicals, technology, and equipment, and changes to SS. 19 CCR 2760.3(c)
5010086 Failure to certify annually that the operating procedures are current and accurate. 19 CCR 2760.3(c)
5010087 Failure to develop and implement safe work practices to provide for the control of hazards during operations such as logout/tagout; confined space entry; opening process equipment or piping; and control over entrance into the SS by maintenance, contractor, laboratory, or other support personnel. 19 CCR 2760.3(d) 5010088 Failure to establish and implement written procedures to maintain the on-going integrity of process equipment. 19 CCR 2760.5(b) 5010089 Failure to establish and implement written procedures to manage changes (except for "replacements in kind") to process chemicals, technology, equipment, and procedures; and changes to stationary sources that affect a covered process. 19 CCR 2760.6(a) 5010090 Failure to ensure the following considerations are addressed in the management of change procedures prior to any change: 1. The technical basis for the proposed change; 2. Impact of change on safety and health; 3. Modifications to and/or development of new operating and maintenance procedures; 4. Necessary time period for the change;

5. Authorization requirements for the proposed change. 19 CCR 2760.6(b)
5010091 Failure to update PSI if a management of change occurred that resulted in a change in the PSI. 19 CCR 2760.6(d)
5010092 Failure to update written operating or written maintenance procedures or practices prior to the start-up of the process if a management of change occurred that resulted in a change in the procedures or practices. 19 CCR 2760.6(e)
5010093 Failure to perform a pre-startup safety review for new SS and for modified SS when the modification is significant enough to require a change in the process safety information. 19 CCR 2760.7(a) 5010094 Failure to ensure that the pre-startup safety review confirms, as a verification check, independent of the management of change process, the following prior to the introduction of a RS to a process: 1.

Construction and equipment was in accordance with design specifications. 2. Safety, operating, maintenance & emergency procedures are in place and are adequate. 3. For new SS, a process hazard analysis has been performed and recommendations have been resolved or implemented before startup, and modified SS meet the requirements contained in the management of change, section 2760.6, and; 4. Training of each employee involved in operating a process had been completed. 19 CCR 2760.7(b)
5010095 Failure to certify that they have evaluated compliance with the provisions of this article at least every three years to verify that the procedures and practices developed under the chapter are adequate and are being followed. 19 CCR 2760.8(a)
5010096 Failure to ensure that the compliance audit is conducted by at least one person knowledgeable in the process. 19 CCR 2760.8(b) 5010097 Failure to develop, and make available to the AA, a report of the scope, methods used, results and findings of the compliance audit. 19 CCR 2760.8(c)

C O U N T Y O F S A N D I E G O

COMPLIANCE INSPECTION REPORT
CalARP Program (continued)
INSPECTION DATE: 06/10/2016 PAGE 12 OF 12
RECORD ID #: DEH2011-HUPFP-214305
CalARP Program Level 3 (continued)
# VIOLATION DESCRIPTION
5010098 Failure to promptly determine and document an appropriate response to each of the findings of the compliance audit, and document that deficiencies have been corrected, including completion dates, within required timetables. 19 CCR 2760.8(d)
5010099 Failure to retain the two most recent compliance audit reports. 19 CCR 2760.8(e)
5010100 Failure to investigate each incident which resulted in, or could reasonably have resulted in, a catastrophic release of a RS. 19 CCR 2760.9(a)
5010101 Failure to initiate an incident investigation within 48 hours following the incident. 19 CCR 2760.9(b)
5010102 Failure to establish an incident investigation team that consists of at least one person knowledgeable in the process involved, including a contract employee if the incident involved work of the contractor, and other persons with appropriate knowledge and experience to thoroughly investigate and analyze the incident. 19 CCR 2760.9(c) 5010103 Failure to prepare a summary of the investigation that includes: 1.

Date the investigation began; 2. A description of the incident including all of the data required under section 2570.9(b) and; 3.

Recommendations from the investigation. 19 CCR 2760.9(d) 5010104 Failure to establish a system to promptly address and resolve the incident report findings and recommendations, including documentation of the resolutions and corrective actions and completion dates within required timelines. 19 CCR 2760.9(e) 5010105 Failure to review the incident investigation report with all affected personnel whose job tasks are relevant to the incident findings including contract employees where applicable. 19 CCR 2760.9(f) 5010106 Failure to retain the incident investigation reports for five years. 19 CCR 2760.9(g)
5010107 Failure to develop a written plan of action regarding the implementation of employee participation. 19 CCR 2760.10(a) 5010108 Failure to consult with employees and their representatives on the conduct and development of the PHA and on the development of the other elements of process safety management. 19 CCR 2760.10(b) 5010109 Failure to provide employees and their representatives with access to the PHA and to all other required information required to be developed under this chapter. 19 CCR 2760.10(c)
5010110 Failure to issue a hot work permit for hot work operations conducted on or near a covered process. 19 CCR 2760.11(a)
5010111 Failure to ensure the hot work permit documents the following: 1. The fire prevention and protection requirements in section 5189 of Title 8 [Process Safety Management of Acutely Hazardous Materials] have been implemented prior to beginning the hot work operations. 2. The date(s) authorized for hot work. 3. The object on which hot work is to be performed is identified. 19 CCR 2760.11(b)
5010112 Failure to keep the hot work permit on file until completion of the hot work operations. 19 CCR 2760.11(b)
5010113 Failure of the owner/operator to perform the following for contractors performing maintenance or repair: 1. When selecting a contractor, obtain and evaluate information regarding the contract owner or operator's safety performance and programs; 2. Inform the contract owner or operator of the known potential fire, explosion, or toxic release hazards related to the contractor's work and the process; 3.

Explain to the contract owner or operator the applicable provisions of Article 7 [Emergency Response Program]; 4. Develop and implement safe work practices consistent with section 2760.3(d) [Operating Procedures], to control the entrance, presence, and exit of the contract owner or operator and contract employees in covered process areas; 5. Evaluate and document the evaluation of the performance of the contract owner or operator in fulfilling their obligations as specified in section 2760.12(c). 19 CCR 2760.12(b) 5010114 Failure to evaluate the performance of the contract owner or operator in fulfilling: 1. Each contract employee is trained in the practices necessary to safely perform his or her job; 2. Each contract employee is instructed in the known potential fire, explosion, or toxic release hazards related to his or her job, the process, and applicable provisions of the ER plan; 3. Document that each contract employee has received & understood the training required by this section; 4. Prepare a record which contains training record contains the identity of the contract employee, date of training, & the means used to verify that the employee understood the training; 5. Each contract employee follows the safety rules of the SS including the safe work practices required by section 2760.3(d) [Operating Procedures]; 6. Advise the owner or operator of any unique hazards presented by, or of any hazards found by, the contract owner or operator¿s work. 19 CCR 2760.12(c) HM-972 CalARP ( 02-15)

# VIOLATION DESCRIPTION
5010115 Failure of a SS whose employees will not respond to accidental releases of RS to meet the following: 1. Document inclusion in the community ER plan developed under 42 USC 11003, in the City or County Hazardous Materials Area Plans and/or in the hazardous materials business plan program pursuant to HSC 25507 for SS with any regulated toxic substances held in a process above the TQ; 2.

Document coordinated response actions with the local fire department and hazardous materials response agencies for SS with only regulated flammable substances held in a process above the TQ; 3. Appropriate mechanisms and written procedures are in place to notify emergency responders of a need for a response. 19 CCR 2765.1(b)
5010116 Failure to develop, implement, & maintain at the SS an ER program that includes: 1. Procedures for informing and interfacing with the public and local ER agencies about accidental releases, emergency planning, and ER; 2. Documentation of proper first-aid and emergency medical treatment necessary to treat accidental human exposures; 3.

Procedures and measures for ER after an accidental release of a RS; 4.

Procedures for the use of ER equipment and for its inspection, testing, and maintenance are developed by the SS; 5. Training for all employees in relevant procedures and relevant aspects of the Incident Command System; 6. Procedures to review and update the ER plan to reflect changes at the SS are developed and employees are informed of these changes. 19 CCR 2765.2(a)
5010117 Failure to coordinate the ER plan with the community emergency response plan developed under 42 USC 11003. 19 CCR 2765.2(b) 5010118 Failure to promptly provide to the LEPC or emergency response officials, information necessary for developing and implementing the community ER plan upon request. 19 CCR 2765.2(c)
5020006 Failure to provide initial training for each employee presently involved in operating a process, and each employee before being involved in operating a newly assigned process on the following: 1. Overview of the process; 2. Operating procedures per section 2760.3; 3. Safety & health hazards; 4. Emergency operations including shutdown; 5.

Applicable safe work practices. 19 CCR 2760.4(a)
5020007 Failure to provide refresher training at least every three years and more often if necessary, to each employee involved in operating a process to assure that the employee understands & adheres to the current operating procedures of the process. 19 CCR 2760.4(b) 5020008 Failure to prepare a training record which contains: 1. Identity of the employee; 2. Date of training; 3. Means used to verify that the employee understood the training. 19 CCR 2760.4(c)
5020009 Failure to train each employee involved in maintaining the on-going integrity of process equipment on the following: 1. Overview of the process and its hazards; 2. Procedures applicable to the employee's job tasks to assure that the employee can perform the job tasks in a safe manner. 19 CCR 2760.5(c)
5020010 Failure to ensure employees involved in operating a process and maintenance and contract employees whose job tasks would be affected by a change in the process are informed and trained in the change prior to start-up of the process or affected part of the process. 19 CCR 2760.6(c)
5030002 Failure to ensure: 1. Inspections and tests are performed on process equipment; 2. Inspection and testing procedures follow recognized and generally accepted good engineering practices; 3. The frequency of inspections and tests of process equipment is consistent with applicable manufacturers' recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience; 4. Each inspection or test that has been performed on process equipment is documented and includes the date of inspection or test, name of the person who performed the inspection or test, serial number or other identifier of the equipment inspected or tested, description of the inspection or test performed, and the results of the inspection or test. 19 CCR 2760.5(d) 5030003 Failure to correct deficiencies in equipment that are outside acceptable limits before further use or in a safe and timely manner when necessary means are taken to assure safe operation. 19 CCR 2760.5(e)
5030004 Failure to ensure for quality assurance: 1. In the construction of new plants and equipment that equipment as it is fabricated is suitable for the process application for which it will be used. 2. Appropriate checks and inspections are performed to assure that equipment is installed properly and consistent with design specifications and the manufacturer's instructions. 3. Maintenance materials, spare parts, and equipment are suitable for the process application for which they will be used. 19 CCR 2760.5(f)
HM-926(01/15)

COUNTY OF SAN DIEGO

CORRECTIVE ACTION FORM TO

DOCUMENT RETURN TO COMPLIANCE
FACILITY NAME: CHULA VISTA ENERGY CENTER, LLC
ADDRESS: 3497 MAIN ST
CITY/ZIP: CHULA VISTA /91911
INSPECTION DATE: 06/10/2016
RECORD ID #: DEH2011-HUPFP-214305
SPECIALIST: Manon Maschue
INSPECTION CONTACT: Susana Miramontes
TITLE: Administrative and EHS Specialist
PHONE:619-579-9002
E-MAIL:[email protected]
VIOL# DATE

CORRECTED

INDICATE HOW VIOLATIONS WERE CORRECTED
(Attach Any Supporting Documentation) DUE DATE
#1 5010031 07/10/2016
#2 5010029 07/10/2016
#3 5010049 07/10/2016
#4 5010051 07/10/2016
#5 5030001 07/10/2016
#6 5010056 07/10/2016
I certify under penalty of law 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

TITLE OF FACILITY REPRESENTATIVE SIGNATURE

DATE SIGNED

SEND COMPLETED FORM AND SUPPORTING DOCUMENTATION TO THE ADDRESS LISTED BELOW

COUNTY OF SAN DIEGO USE ONLY
REVIEWED BY: DATE:

SPECIALIST'S COMMENTS:

All violations noted on date listed above were corrected Based On Information Provided By The Facility RTC entered by Specialist on:

Based On Field Verification By Specialist 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
1 Maschue, Manon E.

From: Stephen Cobbe <[email protected]>
Sent: Friday, July 15, 2016 1:56 PM
To: Maschue, Manon E.

Cc: Susana Miramontes
Subject: HMD Compliance Inspection
Attachments: CVEC 2016 RTC Corrective Action Form..pdf; Hazard Review Recommendations and Corrective Actions..pdf
Follow Up Flag: Follow up
Flag Status: Flagged
Mrs. Maschue,

Attached you will find the RTC for Chula Vista Energy Center CUPA violations.  The Compliance Audit Report that was completed on 3/13/14 was not located and is currently still being searched.  Question could the Hazard Review that was completed on October 21, 2013 in the CalARP Binder be used as partial compliance for the A udit Report? Please give me or Susie a call to discuss further what needs to be done to correct this issue.

Recommendations made in the Compliance Inspection Report have been addressed as follows:  Routine sensor calibration schedule, preventive maintenance records and paper records of the ammonia system maintenance were located and ar
e available on site.   Operating Procedures binder and Ammonia System & Maintenance binder on site includes equipment inspections and once inspections are complete they are logged into our new computer management system (MA/CMMS).  Management of change process has been approved to have the 8 ammonia sensors changed from 75 ppm high‐high to 50 ppm high‐high.  Software change to begin the week of July 11, 2016. Ammonia Detection Sensor ending in serial number 110033 is no longer at fault.  Regarding recommendations that were made in the Hazard Review on 2013 seven of the nine recommendations have been addressed please see attachment.  Chemical inve ntory list and site map with location of fire hydrant has been submitted into CERS.  Finally, the Federal SPCC Plan has been reviewed and certified by Plant Manager.  Our apologies for not submitting this morning as somethings had come up and we got a little busy.

Sincerely
Stephen

Stephen Cobbe
Plant Manag
er, San Diego
Wellhead Services, Inc.
220 N. Johnson Ave.

El Cajon, CA 92020
(619) 579-9002 Office
(619) 627-2908 Cell
(619) 579-9005 Fax
[email protected]

1 Maschue, Manon E.

From: Susana Miramontes <[email protected]>
Sent: Friday, July 15, 2016 2:53 PM
To: Maschue, Manon E.

Cc: Stephen Cobbe
Subject: Re: Compliance Audit Report 2014
Attachments: CVEC RMP Compliance Audit 3.13.2014.doc; CVEC 2016 RTC Corrective Action Form..pdf
Good Afternoon Manon,

I always told to never lose faith and today is a good example.  Stephen and I knew this report was somewhere just misplaced and we waited to the last minute to tell you and GUESSS what we found.  So happy to send you the copy and here’s an updated RTC.  Have a great we ekend!!!

Susana Miramontes
Administrative and EHS Specialist
San Diego Wellhead Services, Inc.
220 N. Johnson Ave.

El Cajon, Ca 92020
619-579-9002 Office
619-456-5332 cell
[email protected]

COUNTY OF SAN DIEGO

CORRECTIVE ACTION FORM TO

DOCUMENT RETURN TO COMPLIANCE
RECORD ID II:

SPECIALIST:

INSPECTION DATE: I I
CONTACT: Chula Vista Energy Center FACILITY NAME ________________ _ ADDRESS 3497 Main Street CITY Chula Vitsta ZIP 91911
VIOL/I DATE INDICATE How VIOLATIONS WERE CORRECTED

CORRECTED
1 V 06 / 13 I 16
2 I\' 06 / [3 I 16
3 �· 06 /22 I 16
4 IV 06 / 23 I 16
5 06 / 23 / 16 IV
6 06 / D / 16
(Atlllch llllY su1morliLH! ctocumc11tntio11.)
On 6-13-16 updated rcgiMr.ilfon lnformation including updated Ca!ARP RMP QuJlified Person and Cn!ARP ER Contact w,1s emailed to CUPA.

Same /\s 1\bovc.
uper.llmg l'rocea1msliindcr has 6cm located and upd1teJ and is a\•ail.1ble 011 site.

Am111oni.1 System and i\lalnknancc bimkr has been locatnl aml upc.latec.l and Is avaibl:ile on site. 1\11 ammonia equipment scheduled mainten,ince plan Is avall•lile and located In the A111mo11i,1 Srstem and i\laintenance binder 011 site. Our preventive mainten,rna S)'Stem (i\lA/Ci\li\lS) has been cstablishe,1 to make a schedule for inspections and teslino of ,111 ,unmonia caulomcnt.

A 2009 Compliance Audit Report wJs located in the Ri\lP liook from the former owners i\li\lC.

The 3/13/14 Compliance Audit Report was located and available on site in the CalARP binder. 7 \' I I
8 \' I I
9 \' I I
l 0
\' I I
I ce1tify 1111der penalty of lnll' thnt lltis faciliry ltM coirected n/11-iolntio11s 111111ked 011 the Co111µ/ia11ce !11sµectio11 Repo11/Notice of l'iolnt/011. I !tare pe1so11ally e.mm/11ed and m11fa111iliar ll'itlt tlte i11fo1111at/011 s11bmi11ed and beliere the i11fo1111ntio11 is 1111e, ncwmte 1111d complete. I 11111 a111holi1ed to file this w1ijirn1io11for the facility, aud m11 mrnre t/,nt tl,ere are slg11ijirn11t µe11nlties for s11b111illi11gfalse i11/01111ntio11.

Plant Manager
COUNTY OF SAN DIEGO USE ONLY: Hcvlcwc<l by: _______________ Dntl': _ __,/ _ __,_/ __ (Specialist's nnme nnd tln tc required for processing)
Speclnllst's comments:---------------------------------------- D All vloln tlons noted 011 !late listed nbove were corrected.

D Dnse<I 011 informnlion provlcle<l by the fnclllty
D Onset! 011 fie ld vel'lflcnllo11 by Specinlist
D RTC entered In Klvn L>y Specialist on: _ _,/'----'--- DRTC entered In Klvn L>y Office Ass lstnnl on:_-'-/---'--- ll\t-9!6 (OJ/14) 1-CR
Depnrtnm,t of Enl'lro11111e11tnl lknllh, llnznrclo111 i\fotcrlnls Dil'lslou, P.O. Box 129261, Snn Diego, CA 92112-9261 hllp://1rn w,st!cclrh.org 858-505-6880
D1STRl8Ufl0�: \\'IIITE,RE11JR1'TOll,IU HI.LOl\'.f,ICILIT\' Rn,11:-s

COUNTY OF SAN DIEGO

UPFP INSPECTION CHECKLIST
FACILITY NAME: CHULA VISTA ENERGY CENTER, LLC
ADDRESS: 3497 MAIN ST
CITY/ZIP: CHULA VISTA /91911
INSPECTION DATE: 06/25/2018
RECORD ID #: DEH2011-HUPFP-214305
TIME START: 9:15 AM END: 1:15 PM
SPECIALIST: Manon Maschue
INSPECTION CONTACT:Susanna Miramontes
TITLE: EH&S Specialist
PHONE:(619) 579-9002
E-MAIL:[email protected]
HM-9000(01/15) DEH CUPA Inspection eForm v66 Dated 1/10/2017 14:30

FACILITY REFERENCE DATA
ACCELA

CERS
RECORD STATUS: Permit Renewed
PERMIT EXPIRATION DATE: 08/31/2018
BALANCE DUE: $1,615.00
INSPECTOR: Manon Maschue
INSPECTION TYPE: Routine
INSPECTION STATUS: Complete
EPA ID NUMBER: CAL000346986
FACILITY CERS ID NUMBER:10359508
CERS LEAD USER: Susana Miramontes
LAST CERS SUBMITTAL DATE: 06/14/2017
ENVIRONMENTAL CONTACT EMAIL: [email protected]
ENVIRONMENTAL CONTACT PHONE: 6195799002

FACILITY INFORMATION

YES NO YES NO INACTIVATION INSPECTION: ✖
CHANGE OF OWNER: ✖
CHANGE IN BUSINESS TYPE: ✖
BUSINESS TYPE: Public Utilities-Not Fleet Fuel Facility ISSUE INITIAL INVOICE: ✖
ASSESS NON-NOTIFICATION FEE: ✖
ASSESS RE-INSPECTION FEE: ✖
FACILITY SUBJECT TO BASE FEE: ✖
FACILITY SUBJECT TO CUPA FEE: ✖
UPDATE FACILITY ADDRESS IN AA: ✖
BUSINESS CLOSE DATE:

HAZARDOUS MATERIALS: ✖
HAZARDOUS WASTE: ✖
ABOVEGROUND PETROLEUM STORAGE ACT:* ✖
TOTAL SHELL CAPACITY APSA: 0
UNDERGROUND STORAGE TANK: ✖
CALARP PROGRAM (CERS): ✖
CALARP PROGRAM LEVEL:

1 2 3 N/A
MEDICAL WASTE: ✖
MW FACILITY GENERATING OVER 200 LBS PER MONTH: ✖
EPIC PARTICIPANT: ✖
NUMBER OF TLV GASES AT THE FACILITY: 0
HW GENERATOR STATUS :

LQG SQG CESQG RCRA LQG N/A
TIERED PERMIT LEVEL(S) :

CESQT CESW CE-L CE-CL HHW PBR CA N/A

PRIMARY BILLING CODE
Not Applicable

SECONDARY BILLING CODE
Not Applicable

TERTIARY BILLING CODE
Not Applicable
INSPECTION SCOPE:*
HAZARDOUS MATERIALS: GEN HAZMAT APSA UST
MEDICAL WASTE: SQG SQG - TREATS

LQG LQG - ABBREVIATED LQG - TREATS
HAZARDOUS WASTE: SQG LQG
CALARP: 1 2 3
TIERED PERMITTING: CESQT CESW CE-L CE-CL

CA PBR HHW
CONSENT TO CONDUCT INSPECTION GRANTED BY: INSPECTION CONTACT NAME: Stephen Cobbe TITLE: Plant Manager

REMOVE BLANK CHECKLISTS FROM FINAL INSPECTION REPORT REFUSED TO SIGN TIME ACCOUNTING (Routine) TOTAL TIME ENTERED: 4
Date Time Group Type
06/25/2018 1.2 HMD Inspection Report Writing - Record
06/25/2018 1.3 HMD Inspection Travel Time - Record
06/25/2018 0.5 HMD Inspection HM/HW - Record
06/25/2018 1 HMD Inspection CalARP Level 1 - Record

COUNTY OF SAN DIEGO

UPFP INSPECTION CHECKLIST
FACILITY NAME: CHULA VISTA ENERGY CENTER, LLC
ADDRESS: 3497 MAIN ST
CITY/ZIP: CHULA VISTA /91911
INSPECTION DATE: 06/25/2018
RECORD ID #: DEH2011-HUPFP-214305
TIME START: 9:15 AM END: 1:15 PM
SPECIALIST: Manon Maschue
INSPECTION CONTACT:Susanna Miramontes
TITLE: EH&S Specialist
PHONE:(619) 579-9002
E-MAIL:[email protected]
HM-9000(01/15) DEH CUPA Inspection eForm v66 Dated 1/10/2017 14:30 INSPECTION REPORT EMAILS:

[email protected],[email protected]
RECORD COMMENT:

HM-924(01/15)

COUNTY OF SAN DIEGO

COMPLIANCE INSPECTION REPORT
FACILITY NAME: CHULA VISTA ENERGY CENTER, LLC
ADDRESS: 3497 MAIN ST
CITY/ZIP: CHULA VISTA /91911
INSPECTION DATE: 06/25/2018 PAGE 1 OF 10
RECORD ID #: DEH2011-HUPFP-214305
TIME START: 9:15 AM END: 1:15 PM
SPECIALIST: Manon Maschue
INSPECTION CONTACT:Susanna Miramontes
TITLE: EH&S Specialist
PHONE:(619) 579-9002
E-MAIL:[email protected]
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 N/A
✖ Unified Program Facility Permit Current
✖ Hazardous Materials Business Plan Available
✖ Employee Training is Adequate
✖ Waste Disposal Records Available for Review
✖ Emergency Contacts Current Updated today
✖ Chemical Inventory/Map Current Updated today
Yes N/A
✖ Contingency Plan Available LQG SQG✖
✖ Employee Training Records Available
✖ Universal Waste Managed Properly
✖ Waste Containers Closed✖ Labeled✖
✖ Waste Containers in Good Condition
Permit Expires On 08/31/2018
CONSENT TO CONDUCT INSPECTION GRANTED BY: Stephen Cobbe TITLE: Plant Manager INTRODUCTION:

The County of San Diego Hazardous Materials Division (HMD) is a division of the Department of Environmental Health (DEH).

DEH is the Certified Unified Program Agency (CUPA) for the County of San Diego. Californians are protected from hazardous waste and materials by a Unified Program that ensures consistency throughout the state in regard to administrative requirements, permits, inspections, and enforcement. The CUPA implements the Unified Program throughout San Diego County as it applies regulatory standards established by five different state agencies to businesses that manage hazardous materials, generate hazardous or medical wastes, store petroleum in aboveground petroleum storage tanks, and store hazardous substances in underground storage tanks. Additional information on the CUPA program can be found here: http:// www.sandiegocounty.gov/deh/hazmat/hmd_cupa.html

A routine Unified Program facility inspection was conducted on June 25, 2018 with Stephen Cobbe, Plant Manager and Ty Cheesbrough, Plant Technician. Consent to inspect, sample and photograph as needed was obtained from Stephen Cobbe. The inspection was conducted to assess compliance with the following Unified Program elements:
■ California Accidental Release Prevention Program (CalARP) (HSC Div 20 Ch 6.95 Art 2 & 19 CCR Div 2 Ch 4.5) ■ Hazardous Materials Chemical Inventory & Business Plan (HMBP) (HSC Div 20 Ch 6.95 Art 1 & 19 CCR Div 2 Ch 4) ■ Hazardous Waste Management (HSC Div 20 Ch 6.5 & 22 CCR Div 4.5 Ch 10) ■ Spill Prevention Control & Countermeasures Plan* (SPCC) (40 CFR Sec 112 & HSC Ch 6.67)

Chula Vista Energy Center (CVEC) is a 35 megawatt power generator which runs not more than an average of 100 hours per year.

It is currently operated by Wellhead Services. CVEC uses 19% ammonium hydroxide for selective catalytic reduction of oxides of nitrogen produced from making power.

No violations were observed during this inspection.

INSPECTION REMARKS:

CalARP Remarks:

Program 1 - Ammonium Hydroxide
Chula Vista Energy Center (CVEC) submitted a Program 1 RMP update to the CUPA April, 2017. At this time CVEC revised their secondary containment for the ammonia tank by installing a sloped cover (in place of the polyballs). The revised area of concern keeps the plume of ammonia on the CVEC property according to the worst case scenario they submitted to the CUPA. The Hazard Assessment indicates there will be no off-site impacts from a worst case release of all contents of the ammonium HM-924(01/15)

COUNTY OF SAN DIEGO

SUPPLEMENTAL COMPLIANCE

INSPECTION REPORT
INSPECTION DATE: 06/25/2018 PAGE 2 OF 10
RECORD ID #: DEH2011-HUPFP-214305
hydroxide tank. An RMP update is required every 5 years. Be sure to also perform a new Hazard Assessment every 5 years.

The 5-year updated and certified (2745.9) RMP (including Registration Information 2740.1, Executive Summary 2745.3, Offsite Consequence Analysis 2745.4, 5-year accident history 2745.5 may be e-mailed, sent by courier or through U.S. Mail, as you like.

As a Program 1 Facility you are required to ensure that response actions have been coordinated with local emergency planning and response agencies (e.g., site visits by first responders). Document these.

Incident Investigation: Near misses are investigated and documented. There have been no near missed or releases of ammonia in the last 5 years.

Emergency Response: Chula Vista Energy is a non-responding facility. They rely on the local fire department and the Regional Hazardous Incident Response Team (HIRT) for emergency response to ammonium hydroxide spills. The local Fire Department visits at least twice a year for either a routine visit, new employee orientation or evacuation and response drills. Chula Vista Energy Center has a clean up contact with "Environmental Logistics (Transporter #5508)."

RMP Certification Statement in this RMP is the proper statement that is provided in Section 2735.5(d)(4).

Be advised that the CUPA is reviewing the Off-site Consequences Analysis for all Program 1 Facilities to verify they are in the correct program.

HMBP Remarks:

Last HMBP training (which included EPCRA, Release Notification, Health and Safety and RMP Training) was conducted August 2017. Fire Action Training was last conducted March 2018.

Hazardous Waste Remarks:

Used oily water is generated from the "wash down tank" which is non-hazardous. Oil, oily water from maintenance and oily solid wastes are generated on a regular basis.

SPCC Remarks:

This facility has 1070 gallons of APSA-regulated oils on site so is not regulated under California's Aboveground Petroleum Storage Act. This facility has a Federal SPCC plan (for a total of 6,510 gallons of SPCC-regualted oils) on site that was last reviewed and certified June 7, 2016. HSC 25270.2. "Aboveground storage tank" does not include Oil-filled electrical equipment, including, but not limited to, transformers, circuit breakers, or capacitors, if the oil-filled electrical equipment when the equipment contains less than 10,000 gallons of dielectric fluid, is non-PCB and is inspected "routinely." This is a courtesy reminder that you Federal SPCC plan must be reviewed and re-certified every 5 years.

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 , Manon Maschue , 858.518.7390 [email protected]

INSPECTION PHOTOS
None
HM-924(01/15)

COUNTY OF SAN DIEGO

SUPPLEMENTAL COMPLIANCE

INSPECTION REPORT
INSPECTION DATE: 06/25/2018 PAGE 3 OF 10
RECORD ID #: DEH2011-HUPFP-214305
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
Stephen Cobbe

TITLE OF FACILITY REPRESENTATIVE
Plant Manager

SIGNATURE

DATE SIGNED
06/25/2018
Department of Environmental Health, Hazardous Materials Division, P.O. Box 129261, San Diego, CA 92112-9261 Phone: (858) 505-6880 http://www.sdcdeh.org

C O U N T Y O F S A N D I E G O

COMPLIANCE INSPECTION REPORT
Handlers of Hazardous Materials and Small and Large
Quantity Generators of Hazardous Waste
INSPECTION DATE: 06/25/2018 PAGE 4 OF 10
RECORD ID #: DEH2011-HUPFP-214305
FACILITY NAME: *CHULA VISTA ENERGY CENTER, LLC
ADDRESS: * 3497 MAIN ST CITY/ZIP: *CHULA VISTA 91911
Each violation checked below is for the section(s) of the California Health and Safety Code (HSC), 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

HAZARDOUS MATERIALS REQUIREMENTS
# VIOLATION DESCRIPTION
1010001 Failed to establish and implement a HMBP. HSC 25505(a) and 25507(a) 1010002 HMBP not submitted to the CUPA in CERS. HSC 25508(a)(1)(A); 27 CCR 15188(a),(b),(d) 1010003 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) 1010004 Chemical inventory incomplete or not submitted in CERS. HSC 25505(a)(1); 25507(a); 25508.1(a-b); 19 CCR 2654 (a) or (d) 1010005 Site map not submitted in CERS or not sufficient. HSC 25505(a)(2); 25508.1(f); 19 CCR 2652(a)(3) 1010006 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 25508.1(a-f); 19 CCR 2654(d); SDCC 68.904(c)(6)
1010008 HMBP not certified annually as complete and accurate in CERS. HSC 25508(a)(1)(A), 25508.2, 19 CCR 2654(b) 1010010 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)(1)(A); 19 CCR 2658
1010011 Failure to notify property owner in writing that the business is subject to the HMBP program. HSC 25505.1 1010012 Failure to provide a copy of HMBP to the property owner within five working days upon request from property owner. HSC 25505.1 1010014 Failure to submit emergency response plan in CERS, when not meeting agricultural handler exemption. HSC 25507.1(a) and 25508(a)(1)(A); 19 CCR 2670, 2671
1010015 Failure to submit employee training plan in CERS, when not meeting agricultural handler exemption. HSC 25507.1(a) and 25508(a)(1)(A) 1010016 HMBP not established or submitted in CERS, when not meeting the remote site exemption. HSC 25507.2 and 25508(a)(1)(A) 1020001 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) and 25508(a)(1)(A); 19 CCR 2659(a) 1020002 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) 1040001 Hazardous materials release or threatened release not immediately reported to the CUPA and OES upon discovery. HSC 25510(a); 19 CCR 2631(a) HMD1001 Unified Program Facility permit not obtained for hazardous materials. SDCC 68.905; 68.906, 68.907 HMD1005 Emergency contact not provided or current in CERS. HSC 25508.1(f); SDCC 68.904(b) HMD1007 Highly toxic gas (TLV<10 ppm) not disclosed in CERS. SDCC 68.1113(a) HMD1008 Annual carcinogen/reproductive toxin list not submitted in CERS. SDCC 68.1113(b) 1010017 HMBP not readily available to facility personnel or the CUPA. HSC 25505(c)

HAZARDOUS WASTE REQUIREMENTS FOR SQGS ONLY
# VIOLATION DESCRIPTION
HMD0226 Did not accumulate waste in a container or tank. 22 CCR 66262.34(d)(2); 40 CFR 262.34(d)(2) 3030007 Failed to properly label/date hazardous waste container &/or tank. 22 CCR 66262.34(f) 3030010 Accumulated waste too long (>180 or 270 days) or (>90 days). HSC 25201(a), 25123.3(h)(1); 22 CCR 66262.34(d); 40 CFR 262.34(e) and/or (f) 3030013 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 3030015 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 3030017 Failed to properly close hazardous waste container(s). 22 CCR 66262.34(d)(2); 40 CFR 262.34(d)(2), 265.173 3030019 Failed to inspect hazardous waste storage area at least weekly. 22 CCR 66262.34(d)(2); 40 CFR 262.34(d)(2), 265.174 3030022 Failed to properly separate incompatible waste. 22 CCR 66262.34(d)(2); 40 CFR 262.34(d)(2), 265.177 3030030 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 3030036 Failed to maintain adequate aisle space. 22 CCR 66262.34(d)(2); 40 CFR 262.34(d)(4), 265.35 3010022 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)
3020001 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) 3030032 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 3030039 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) HMD0412 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)

HAZARDOUS WASTE TANK SYSTEMS FOR SQGS ONLY
# VIOLATION DESCRIPTION
3030024 Failed to operate uncovered tank to ensure at least 2 ft. of freeboard 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)
HM-923 (06-17)

C O U N T Y O F S A N D I E G O

COMPLIANCE INSPECTION REPORT
Hazardous Materials and Hazardous Waste (continued)
INSPECTION DATE: 06/25/2018 PAGE 5 OF 10
RECORD ID #: DEH2011-HUPFP-214305
3030025 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) 3030027 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)
3030028 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) 3050007 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)
HMD1612 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) HMD1614 Failed to pre-notify the CUPA in writing prior to closing a hazardous waste tank system. 22 CCR 67383.3(a)(1) HMD1615 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 LQGS

RECORD KEEPING/OPERATIONAL REQUIREMENTS
# VIOLATION DESCRIPTION
HMD0131 Unified Program Facility Permit not obtained &/or maintained for the generation of hazardous waste. SDCC 68.905 HMD0150 Failed to submit complete and accurate Facility Information in CERS. 27 CCR 15188(b-c); SDCC 68.904(b) 3030053 Failed to maintain waste analysis records, analytical records &/or waste determination results for at least 3 years. 22 CCR 66262.40(c) 3010002 Failed to obtain &/or maintain an active EPA ID Number. 22 CCR 66262.12(a) 3010008 Failed to properly complete a uniform hazardous waste manifest. 22 CCR 66262.23(a) 3010009 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) 3010010 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)
3010011 Failed to send copy of the uniform hazardous waste manifest to DTSC within 30 days of shipment. 22 CCR 66262.23(a)(4) 3010013 Failed to meet the consolidated manifesting requirements for waste shipment. HSC 25160.2(b)(3) &/or (c) 3010014 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) 3030006 Failed to determine if a hazardous waste is restricted or prohibited from land disposal and has to be treated. 22 CCR 66268.7(a)(1) 3010016 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 25143.10(a), (c) &/or (d) HMD0149 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) HMD0152  Failed to report &/or update the required inventory information for hazardous waste(s) generated at the facility in CERS.  SDCC 68.904(a)(2) HMD0140 Failed to have Land Disposal Restriction documentation onsite for 3 years. 22 CCR 66268.7(a)(8) 3250005 Failed to obtain a Treatment, Storage and Disposal Facility (TSDF) permit or authorization to store/treat/dispose of hazardous waste. HSC 25201(a) 3050005 Failed to have adequate records demonstrating claim of exemption or exclusion for recyclable materials. HSC 25143.2(f) HMD0142 Failed to notify the CUPA in CERS for onsite hazardous waste treatment/tiered permitting. HSC 25201(a) HMD0138 Manifest signed by the TSDF not available for inspection. 22 CCR 66262.40(a); HSC 25185(a)(4)

DISPOSAL AND TRANSPORTATION
# VIOLATION DESCRIPTION
3010007 Failed to prepare a hazardous waste manifest for the transport of a waste for off-site transfer, treatment, storage, or disposal. HSC 25160(b)(1) or (2), 25160.2(b)(9); 22 CCR 66262.20(a)
3030005 Failed to make a proper waste determination. 22 CCR 66262.11, 66262.40(c) 3050001 Failed to use a DTSC registered hazardous waste transporter to transport hazardous waste. HSC 25163(a) 3050002 Failed to properly dispose of hazardous waste at an authorized facility. HSC 25189.5(a) HMD0308 Impermissible dilution of hazardous waste. 22 CCR 66268.3(a) HMD0305 Disposed of used oil illegally. HSC 25250.5(a), 25189.5(a) HMD0306 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
3030001 Failed to meet the management requirements when handling or storing spent lead-acid batteries. 22 CCR 66266.81(a) 3030003 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)
3030004 Failed to properly manage, store, label &/or recycle used oil filters &/or used fuel filters. HSC 25250.22; 22 CCR 66266.130 3050004 Generator intentionally contaminated used oil with another hazardous waste other than minimal amounts of fuel. HSC 25250.7(a), (c) HMD0222 Failed to properly label Excluded Recyclable Materials (ERM) accumulated in a container or tank. HSC 25143.9(a) HMD0216 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)
HMD0217 Failed to repackage and properly label damaged/deteriorated hazardous material container within 96 hours. HSC 25124(b)(3)(B); 22 CCR 66262.34(f) HMD0219 Failed to properly segregate used oil &/or fuel drained from filters. HSC 25250.22(b)(4); 22 CCR 66266.130(c)(6) 3030057 Failed to comply with hazardous waste satellite container regulation. 22 CCR 66262.34(e) HMD0023 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) 3030058 Failed to mark date on empty container larger than 5 gallons &/or manage it within one year. 22 CCR 66261.7(f) 3030059 Failure of the owner or operator managing laboratory hazardous waste in a laboratory accumulation area to comply with the quantity limitations, management, training, or documentation requirements. HSC 25200.3.1(b) HM-923 (06-17)

C O U N T Y O F S A N D I E G O

COMPLIANCE INSPECTION REPORT
Hazardous Materials and Hazardous Waste (continued)
INSPECTION DATE: 06/25/2018 PAGE 6 OF 10
RECORD ID #: DEH2011-HUPFP-214305

UNIVERSAL WASTE HANDLER REQUIREMENTS
# VIOLATION DESCRIPTION
3010004 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)
HMD0151 Failed to maintain universal waste handler training records for 3 years. 22 CCR 66273.36(c),(d) 3020003 Failed to properly train handlers of universal waste in universal waste management and response procedures. 22 CCR 66273.36(a),(b) 3030008 Failed to properly label or mark Universal Waste container, package, or pallet (excluding CESQUWG) 22 CCR 66273.34 3030011 Failed to properly dispose of Universal Waste within one year. 22 CCR 66273.35(a) &/or (b) HMD0147 Failed to keep records of offsite Universal Waste shipment(s) available for inspection for 3 years. 22 CCR 66273.39(c),(d)(2) 3030051 Failed to meet accumulation, labeling, marking, &/or containment standards for Universal Waste aerosol containers. HSC 25201.16(f) 3040004 Failed to manage universal waste in a manner to prevent release(s) to the environment. 22 CCR 66273.33; 66273.33.5 HMD0307 Disposal of universal waste (UW) to an unauthorized point. HSC 25189.5(a); 22 CCR 66273.31(a), 66273.8(b) 3010005 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) 3030055 Failure of certified appliance recycler (CAR) to properly remove and dispose of all materials that require special handling (MRSH). HSC 25211.3, 25212, 25212(c)
HM-923 (06-17)

C O U N T Y O F S A N D I E G O

COMPLIANCE INSPECTION REPORT
Aboveground Petroleum Storage Act (APSA) Program
INSPECTION DATE: 06/25/2018 PAGE 7 OF 10
RECORD ID #: DEH2011-HUPFP-214305
Each violation checked below is for the section(s) of the California Health and Safety Code (HSC) or 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 a DEH Corrective Action Form (HM-926) or other correspondence to document your return to compliance. Please call (858) 505-6880 or your Specialist if you have any questions.

GENERAL APSA FACILITY REQUIREMENT
(CHAPTER 6.67 OF DIVISION 20 OF THE HSC & SDCC)
# VIOLATION DESCRIPTION
4010001 Failed to prepare a Spill Prevention, Control, and Countermeasures (SPCC) Plan. HSC 25270.4.5(a), 40 CFR 112.3, 112.6 4030038 Failed to implement the SPCC Plan. HSC 25270.4.5(a), 40 CFR 112.3, 112.6 4010032 Failed to submit a tank facility statement or update/certify Business Plan annually. HSC 25270.6(a)(1) or (a)(2) 4010033 Failed to pay the APSA program fee or obtain Unified Program Facility Permit. HSC 25270.6(b), SDCC 68.905 4040001 Failed to immediately, upon discovery, report a one-barrel (42 gallons) or greater release of petroleum to Cal OES and the CUPA . HSC 25270.8 4010037 Failed to meet conditions of APSA exemption for oil-filled electrical equipment including containment and visual inspection. HSC 25270.2(a)(4) REQUIREMENTS BASED ON 40 CFR 112.1-112.6
# VIOLATION DESCRIPTION
4010035 Failed to prepare an appropriate SPCC Plan within six months when the facility no longer meets the conditions of a qualified facility. (40 CFR 112.3(a)(1), 112.3(g), 112.6.) HSC 25270.4.5(a)
4010047 (Qualified Facility only- Tier I or II) Failed to have management, or a Professional Engineer if applicable, certify the SPCC Plan and comply with the certification requirements. (40 CFR 112.6(a)(1), 112.6(b).) HSC 25270.4.5(a) 4010048 (Qualified Facility only- Tier I) Failed to certify the SPCC Plan according to 40 CFR 112.6(a)(1) if a technical change has been made to the facility design, construction, operation, or maintenance. (40 CFR 112.6(a)(2).) HSC 25270.4.5(a) 4010052 (Qualified Facility only- Tier II) Failed to have technical amendment(s) certified by management, or a Professional Engineer if applicable. (40 CFR 112.6(b) (2), 112.6(b)(2)(i).) HSC 25270.4.5(a)
4010054 (Qualified Facility only- Tier I) Failed to include in the SPCC Plan a prediction of direction and total quantity of oil potentially discharged from the facility as a result of each type of major equipment failure. (40 CFR 112.6(a)(3)(i).) HSC 25270.4.5(a) 4030041 (Qualified Facility only- Tier I) Failed to provide bulk storage containers/tanks with adequate sized secondary containment to contain the capacity of the largest container plus freeboard for precipitation; failed to position/locate mobile or portable containers to prevent a discharge. (40 CFR 112.6(a) (3)(ii).) HSC 25270.4.5(a)
4030042 (Qualified Facility only- Tier I) Failed to provide systems or follow procedures to prevent overfills as described in the SPCC Plan; failed to routinely test overfill equipment to ensure proper operation. (40 CFR 112.6(a)(3)(iii).) HSC 25270.4.5(a) 4010003 Failed to have a Professional Engineer certify and review the SPCC Plan. (40 CFR 112.3(d).) HSC 25270.4.5(a) 4010008 Failed to maintain a complete copy of the SPCC Plan at the facility if the facility is normally attended at least four hours per day, or at the nearest field office if the facility is not so attended. (40 CFR 112.3(e)(1).) HSC 25270.4.5(a) 4010010 Failed to make SPCC Plan technical amendment(s) within six months when the facility has had a change in design, construction, operation, or maintenance which affects the facility's discharge potential; failed to implement within six months following preparation of the amendment. (40 CFR 112.5(a), 112.5(b).) HSC 25270.4.5(a)
4010009 Failed to perform and properly document a five-year review of the SPCC Plan. (40 CFR 112.5(b).) HSC 25270.4.5(a) 4010039 Failed to have technical amendments certified by a licensed Professional Engineer. (40 CFR 112.5(c).) HSC 25270.4.5(a)

GENERAL SPCC REQUIREMENTS
BASED UPON 40 CFR 112.7
# VIOLATION DESCRIPTION
4010012 Failed to prepare a written SPCC Plan in accordance with good engineering practices and any applicable more stringent State rules, regulations, and guidelines; failed to prepare a SPCC Plan that follows the sequence of rule or provides a cross-reference; failed to prepare a SPCC Plan that addresses additional procedures/methods/equipment not fully operational; failed to obtain facility management approval for implementation of the SPCC Plan . (40 CFR 112.7 and 112.7(a)(1).) HSC 25270.4.5(a) 4010014 Failed to include alternative environmental protection to SPCC requirements within SPCC Plan. (40 CFR 112.7(a)(2).) HSC 25270.4.5(a) 4010015 Failed to include in the SPCC Plan an adequate facility diagram, or no facility diagram included. The facility diagram is not required for a Tier I Qualified Facility. (40 CFR 112.7(a)(3).) HSC 25270.4.5(a)
4010016 Failed to adequately describe in the SPCC Plan the physical layout of facility, types of oil and storage capacities, tanks, containers, equipment, mobile refuelers, portable containers, transfer operations, and other required information. (40 CFR 112.7(a)(3), 112.7(a)(3)(i-vi).) HSC 25270.4.5(a) 4010017 Plan does not contain procedures for reporting a discharge, and/or a contact list and phone numbers for the facility response coordinator, National Response Center, cleanup contractors with an agreement for response, and all appropriate Federal, State, and local agencies. (40 CFR 112.7(a)(4).) HSC 25270.4.5(a)
4010018 Discharge response procedures are not adequately organized to be readily accessible in an emergency. (40 CFR 112.7(a)(5).) HSC 25270.4.5(a) 4010019 Failed to include in the SPCC Plan a prediction of the direction, rate of flow, and total quantity of oil that could be discharged for each type of major equipment failure where experience indicates a reasonable potential for equipment failure. (40 CFR 112.7(b).) HSC 25270.4.5(a) 4010020 (General Containment) Failed to provide, or include in the SPCC Plan, the appropriate containment, diversionary structures, or equipment to prevent a discharge that will not escape containment before cleanup occurs, including typical failure mode and most likely quantity of discharge. (40 CFR 112.7(c).) HSC 25270.4.5(a)
4010004 Failed to clearly explain why appropriate containment/diversionary structures are not practicable and/or SPCC Plan claiming impracticability is not certified by a licensed Professional Engineer. (40 CFR 112.7(d).) HSC 25270.4.5(a) 4010005 Failed to prepare an Oil Spill Contingency Plan following the provisions of 40 CFR Part 109 for impracticability claim. (40 CFR 112.7(d)(1).) HSC 25270.4.5(a)
4010006 Failed to provide a written commitment of manpower, equipment, materials when claiming impracticability. (40 CFR 112.7(d)(2).) HSC 25270.4.5(a) 4010021 Failed to have record of inspections and integrity tests signed by the appropriate supervisor or inspector, keep written procedures and records of inspections and integrity tests for at least three years, and/or keep comparison records. (40 CFR 112.7(e), 112.8(c)(6).) HSC 25270.4.5(a) 4020001 Failed to train oil-handling personnel on: operation/maintenance of equipment to prevent discharges; discharge procedure protocols; applicable laws, rules, and regulations; general facility operations; and the contents of the SPCC Plan. (40 CFR 112.7(f)(1).) HSC 25270.4.5(a) 4010022 Failed to designate person accountable for discharge prevention who reports to facility management. (40 CFR 112.7(f)(2).) HSC 25270.4.5(a) 4010023 Failed to conduct annual discharge prevention briefings to ensure understanding of SPCC plan. (40 CFR 112.7(f)(3).) HSC 25270.4.5(a) HM-950 APSA (06-17)

C O U N T Y O F S A N D I E G O

COMPLIANCE INSPECTION REPORT
APSA Program (continued)
INSPECTION DATE: 06/25/2018 PAGE 8 OF 10
RECORD ID #: DEH2011-HUPFP-214305
4030001 Failed to address security and access control of the oil handling, processing, and storage areas to both prevent acts of vandalism and assist in discovery of discharges. (40 CFR 112.7(g).) HSC 25270.4.5(a)
4030002 (For loading/unloading racks) Failure of the secondary containment, and/or rack drainage to flow to a catchment basin, treatment system, or quick drainage system, and hold at least the maximum capacity of the largest single compartment of any tank car or tank truck. (40 CFR 112.7(h)(1).) HSC 25270.4.5(a)
4030003 (For loading/unloading racks) Failed to provide an interlocked warning light or physical barriers, warning signs, wheel chocks, or vehicle brake interlock system in the area adjacent to the loading/unloading rack to prevent vehicles from departing before complete disconnection of transfer lines. (40 CFR 112.7(h)(2).) HSC 25270.4.5(a)
4030016 Failed to evaluate field-constructed storage tank for brittle fracture or other catastrophe and take appropriate action. (40 CFR 112.7(i).) HSC 25270.4.5(a 4010013 Failure to discuss in the SPCC Plan conformance with SPCC requirements and other effective discharge prevention and containment procedures or any more stringent State rules, regulations and guidelines. (HSC 6.67 25270.4.5(a); 40 CFR 112.7(a)(1), 112.7(j)) 4030034 (For oil-filled operational equipment) Failed to provide general secondary containment or fulfill alternative requirements to general secondary containment. (40 CFR 112.7(k).) HSC 25270.4.5.(a)
SPCC REQUIREMENTS BASED UPON 40 CFR 112.8 & 112.20
REFER TO APSA (HSC CHAPTER 6.67) FOR DEFINITION OF "STORAGE TANK" # VIOLATION DESCRIPTION
4010027 Failed to restrain drainage from diked storage areas by valve(s) or manually activated pump/ejector to prevent discharge. (40 CFR 112.8(b)(1).) HSC 25270.4.5(a)
4030005 Failed to use valves of manual, open-and-closed design, for drainage of diked areas. (40 CFR 112.8(b)(2).) HSC 25270.4.5(a) 4030008 Facility drainage system from undiked areas not designed/equipped to retain oil or return oil to facility and/or failed to ensure catchment basin is not in an area subject to flooding. (40 CFR 112.8(b)(3), 112.8(b)(4).) HSC 25270.4.5(a) 4030009 Failed to provide at least two lift pumps and permanently install at least one pump where drainage waters are treated in more than one treatment unit and such treatment is continuous, and pump transfer is needed. (40 CFR 112.8(b)(5).) HSC 25270.4.5(a) 4030012 Storage tanks not compatible with materials stored or conditions of storage. (40 CFR 112.8(c)(1).) HSC 25270.4.5(a) 4030010 (Sized Containment) Secondary containment not sized to contain the entire capacity of the largest single storage tank plus freeboard for precipitation. (40 CFR 112.8(c)(2).) HSC 25270.4.5(a)
4030013 Failure to ensure diked areas are sufficiently impervious to contain discharged oil. (40 CFR 112.8(c)(2).) HSC 25270.4.5(a) 4030006 Failed to ensure all of the following before allowing drainage of uncontaminated rainwater from diked area: keep bypass valve normally sealed closed, inspect the retained rainwater, and open then reseal bypass valves under responsible supervision. (40 CFR 112.8(c)(3).) HSC 25270.4.5(a) 4010026 Failed to maintain adequate records (or NPDES permit records) of drainage from diked areas. (40 CFR 112.8(c)(3)(iv).) HSC 25270.4.5(a) 4030017 Failed to provide corrosion protection for partially buried storage tanks. (40 CFR 112.8(c)(5).) HSC 25270.4.5(a) 4030015 Failed to test or inspect each aboveground tank or container for integrity on a regular schedule and after material repairs. (40 CFR 112.8(c)(6).) HSC 25270.4.5(a)
4030014 Failed to ensure tanks are inspected and tested by an appropriately qualified person in accordance with industry standards. (40 CFR 112.8(c)(6).) HSC 25270.4.5(a)
4010028 Failed to include in the SPCC Plan procedures to test or inspect each aboveground container for integrity in accordance with industry standards on a regular schedule, after material repairs are made, by qualified personnel; failed to include the frequency and type of testing and inspections based on container size, configuration, and design. (40 CFR 112.8(c)(6).) HSC 25270.4.5(a) 4030018 Failure of steam return/exhaust of internal heating coils, which discharge into an open water course, to be monitored, passed through a settling tank, skimmer, or other separation system. (40 CFR 112.8(c)(7).) HSC25270.4.5(a) 4030019 Failed to engineer or update each container/tank installation in accordance with good engineering practice to avoid discharges and/or failed to provide at least one of the following devices: audible/visual high liquid level alarm, high liquid level pump cutoff devices, audible or code signal communications between tank gauge and pumping station, or fast response system for determining liquid levels, such as computers, telepulse or direct vision gauges. (40 CFR 112.8(c)(8)(i-iv).) HSC 25270.4.5(a) 4030022 Failed to regularly test liquid level sensing devices to ensure proper operation. (40 CFR 112.8(c)(8)(v).) HSC 25270.4.5(a) 4030023 Failed to observe effluent treatment facilities frequently enough to detect any potential for discharges as described in 40 CFR 112.1(b). (40 CFR 112.8(c) (9).) HSC 25270.4.5(a)
4030021 Failed to promptly correct visible discharges and/or remove any accumulations of oil in diked areas. (40 CFR 112.8(c)(10).) HSC 25270.4.5(a) 4030020 (For mobile or portable storage tanks EXCEPT mobile refuelers) Failed to position or locate mobile or portable storage container, and/or failure to provide secondary containment with sufficient capacity to contain the largest single mobile or portable container/compartment and sufficient freeboard for precipitation. (40 CFR 112.8(c)(11).) HSC 25270.4.5(a) 4030025 Failed to inspect buried piping when exposed for any reason; failed to do additional examination or take corrective action if corrosion damage is identified. (40 CFR 112.8(d)(1).) HSC 25270.4.5(a)
4030027 Failed to provide corrosion protection for buried piping. (40 CFR 112.8(d)(1).) HSC 25270.4.5(a) 4030028 Failed to cap/blank-flange piping connection at transfer point and mark its origin if not in service. (40 CFR 112.8(d)(2).) HSC 25270.4.5(a) 4030029 Failed to design pipe supports to minimize abrasion/corrosion and to allow for expansion/contraction. (40 CFR 112.8(d)(3).) HSC 25270.4.5(a) 4030026 Failed to regularly inspect aboveground valves, piping, and appurtenances. (40 CFR 112.8(d)(4).) HSC 25270.4.5(a) 4030030 Failed to conduct integrity and leak test on buried piping at installation, modification, construction, relocation or replacement. (40 CFR 112.8(d)(4).) HSC 25270.4.5(a)
4030031 Failed to adequately warn vehicles entering facility to protect piping and other transfer operations. (40 CFR 112.8(d)(5).) HSC 25270.4.5(a) 4010044 Failed to complete and maintain at the facility the Substantial Harm Criteria certification form when owner or operator determines that the facility could not be reasonably expected to cause substantial harm to the environment. (40 CFR 112.20(e).) HSC 25270.4.5(a) HM-950 APSA (06-17)

C O U N T Y O F S A N D I E G O

COMPLIANCE INSPECTION REPORT
California Accidental Release Prevention (CalARP)
Program 1
INSPECTION DATE: 06/25/2018 PAGE 9 OF 10
RECORD ID #: DEH2011-HUPFP-214305
VIOLATION REPORT: Each violation checked below is for the section(s) of the California Health and Safety Code (HSC), 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) and Title 42 of the United States Code (USC) 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. Administering Agency (AA); process hazard analysis (PHA); process safety information (PSI); emergency response (ER); regulated substance (RS); stationary source (SS); threshold quantity (TQ)

GENERAL APPLICABILITY & COORDINATION
# VIOLATION DESCRIPTION
5010001 Failure to comply with CalARP provisions when having a regulated substance in a process listed in Table 1/2. 19 CCR 4.5 2735.4(a)(1) 5010002 Failure to comply with CalARP provisions when having a regulated substance in a process listed in Table 3. 19 CCR 4.5 2735.4(a)(2) 5010003 Failure to comply with CalARP provisions when having a regulated substance in a process listed in Table 1/2 and 3. 19 CCR 4.5 2735.4(a)(3) 5010004 Failure to closely coordinate with the CUPA to implement the CalARP requirements. 19 CCR 4.5 2735.5(a) 5030005 Failure to identify hazards that may result from releases, design and maintain a safe facility or minimize the consequences of an accidental release. HSC 25531.2(b)
5010006 Failure to ensure response actions are coordinated with local emergency planning and response agencies. 19 CCR 4.5 2735.5(d)(3) 5010120 Failure to coordinate with CUPA to ensure appropriate technical standards are applied to implement CalARP. 19 CCR 4.5 2785.1(a) 5010121 Failure to request assistance from the CUPA when necessary to address compliance/safety issues with CalARP. 19 CCR 4.5 2785.1(b)

RMP COMPONENTS AND SUBMISSION

RMP SUBMISSION
# VIOLATION DESCRIPTION
5010005 Failure to submit an RMP which includes all requirements in Section 2745.3 to 2745.5 and 2745.8 to 2745.9. 19 CCR 4.5 2735.5(b)(1), 2735.5(d), 2745.1(a)
5010016 Failure to submit the RMP information required by the USEPA to the USEPA. 19 CCR 4.5 2745.1(b)(1), 2745.1(b)(2) 5010017 Failure to submit the RMP information required by the USEPA to the CUPA. 19 CCR 4.5 2745.1(c) 5010018 Failure of a stationary source to submit a Risk Management Plan to the Administering Agency after the owner or operator has received a notice from the Administering Agency requesting submission of a Risk Management Plan. CA HSC 25536(b) 5010019 Failure to submit an RMP to the CUPA prior to the date a RS is in a process above the TQ. 19 CCR 4.5 2745.1(d) 5010020 Failure to exclude classified information from the RMP. 19 CCR 4.5 2745.1(h)

RMP CERTIFICATION
# VIOLATION DESCRIPTION
5010021 Failure to ensure that the RMP is certified complete by a QUALIFIED PERSON and the stationary source owner or operator. 19 CCR 4.5 2745.2(a) 5010023 Failure to submit in the RMP the certification statement provided in Section 2735.5(d)(4).

RMP UPDATES
# VIOLATION DESCRIPTION
5010025 Failure to revise, update, and submit the RMP to the USEPA and CUPA per timelines in Section 2745.10(a). 19 CCR 4.5 2745.10(a) 5010026 Failure to revise, update, and submit the RMP to the USEPA and CUPA per timelines in Section 2745.10(b). 19 CCR 4.5 2745.10(b) 5010027 Failure to submit a de-registration to the USEPA and CUPA within six months of the regulated substance removal. 19 CCR 4.5 2745.10(c) 5010028 Failure to submit a de-registration to the CUPA within six months of the regulated substance removal. 19 CCR 4.5 2745.10(d) 5010029 Failure to contact the CUPA within 30 days of a change of owner or operator to update the registration. 19 CCR 4.5 2745.10(f)

RMP CORRECTIONS
# VIOLATION DESCRIPTION
5010030 Failure to correct and submit the data required in the RMP under sections 2745.5, 2745.6(j), and 2745.7(l) (NEW ACCIDENT HISTORY). 19 CCR 4.5 2745.10.5(a)
5010031 Failure to correct and submit the EMERGENCY CONTACT information in the RMP within one month of any change. 19 CCR 4.5 2745.10.5(b)

COVERED PROCESS MODIFICATION
# VIOLATION DESCRIPTION
5010032 Failure to notify the CUPA in writing at least five calendar days before implementing any covered process modifications. 19 CCR 4.5 2745.11(a)(1) 5010033 Failure to notify the CUPA within 48 hours after the modification where pre-notification is not reasonable. 19 CCR 4.5 2745.11(a)(2)

CERTIFICATE OF OCCUPANCY
# VIOLATION DESCRIPTION
5010034 Failure to comply with Government Code Section 65850.2(b) prior to issuance of a certificate of occupancy. 19 CCR 4.5 2745.12

RMP REVIEW
# VIOLATION DESCRIPTION
5010022 Failure to correct deficiencies within 60 calendar days from receipt of the notification of RMP deficiencies. 19 CCR 4.5 2745.2(b)(1)

REGISTRATION
# VIOLATION DESCRIPTION
5010008 Failure to include a registration in the RMP that reflects all covered processes. 19 CCR 4.5 2735.5(b)(2) 5010012 Failure to complete the registration information and submit it with the RMP to the USEPA and the CUPA. 19 CCR 4.5 2740.1(a) 5010013 Failure to complete the registration information and submit it with the RMP to the CUPA. 19 CCR 4.5 2740.1(b) 5010014 Failure to submit a registration with a certification of accuracy to the CUPA prior to submittal of the RMP. 19 CCR 4.5 2740.1(c) 5010015 Failure to include the data required in Section 2740.1(d)(1) through (d)(20) in the registration. 19 CCR 4.5 2740.1(d) HM-972 CalARP (06-17)

C O U N T Y O F S A N D I E G O

COMPLIANCE INSPECTION REPORT
CalARP Program 1 (continued)
INSPECTION DATE: 06/25/2018 PAGE 10 OF 10
RECORD ID #: DEH2011-HUPFP-214305

HAZARD ASSESSMENT
# VIOLATION DESCRIPTION
5010035 Failure to prepare a worst-case release scenario analysis as provided in Section 2750.3. 19 CCR 4.5 2750.1 5010036 Failure to complete the five-year accident history as provided in Section 2750.9. 19 CCR 4.5 2750.1

RECORDKEEPING
# VIOLATION DESCRIPTION
5010119 Failure to maintain records supporting the implementation of CalARP for five years unless otherwise provided. 19 CCR 4.5 2775.1 HM-972 CalARP (06-17)
HM-924(01/15)

COUNTY OF SAN DIEGO

COMPLIANCE INSPECTION REPORT
FACILITY NAME: CHULA VISTA ENERGY CENTER, LLC
ADDRESS: 3497 MAIN ST
CITY/ZIP: CHULA VISTA /91911
INSPECTION DATE: 06/21/2021 PAGE 1 OF 9
RECORD ID #: DEH2011-HUPFP-214305
TIME START: 8:00 AM END: 1:00 PM
SPECIALIST: Manon Maschue
INSPECTION CONTACT:Susanna Miramontes
TITLE: EH&S Specialist
PHONE:(619) 579-9002
E-MAIL:[email protected]
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. ✖ Unified Program Facility Permit Current
✖ Hazardous Materials Business Plan Available
✖ Employee Training is Adequate
✖ Waste Disposal Records Available for Review
✖ Emergency Contacts Current Updated today
✖ Chemical Inventory/Map Current Updated today
✖ Contingency Plan Available LQG SQG✖
✖ Employee Training Records Available
✖ Universal Waste Managed Properly
✖ Waste Containers Closed✖ Labeled✖
✖ Waste Containers in Good Condition
Permit Expires On 08/31/2021
CONSENT TO CONDUCT INSPECTION GRANTED BY: Susanna Miramontes TITLE: EH&S Specialist INTRODUCTION:

ROUTINE INSPECTION

The County of San Diego Hazardous Materials Division (HMD) is a division of the Department of Environmental Health & Quality (DEHQ). DEHQ is the Certified Unified Program Agency (CUPA) for the County of San Diego. Californians are protected from hazardous waste and materials by a Unified Program that ensures consistency throughout the state in regard to administrative requirements, permits, inspections, and enforcement. As the CUPA, the HMD implements the Unified Program throughout San Diego County as it applies regulatory standards established by five different state agencies to businesses that manage hazardous materials, generate hazardous or medical wastes, store petroleum in aboveground petroleum storage tanks, and store hazardous substances in underground storage tanks. Additional information on the CUPA program can be found here:
http://www.sandiegocounty.gov/deh/hazmat/hmd_cupa.html

A routine Certified Unified Program Agency (CUPA) facility inspection was conducted June 21, 2021 with Susana Miramontes, Administrative and EH&S Specialist and Ty Cheesebrough of Wellhead. Consent to inspect, sample and photograph as needed was obtained from Susana Miramontes. The inspection was conducted to assess compliance with the following Unified Program elements:

• Hazardous Materials Chemical Inventory & Business Plan (HMBP) (HSC Div 20 Ch 6.95 Art 1 & 19 CCR Div 2 Ch 4) • Spill Prevention Control & Countermeasures Plan* (SPCC) (40 CFR Sec 112 & HSC Ch 6.67) • Hazardous Waste Management (HSC Div 20 Ch 6.5 & 22 CCR Div 4.5 Ch 10) • California Accidental Release Prevention Program (CalARP) (HSC Div 20 Ch 6.95 Art 2 & 19 CCR Div 2 Ch 4.5)

The Chula Vista Energy Center is a 35 megawatt natural gas-fired power plant that is typically not staffed. Typically the plant runs not more than 100 hours per year. The plant is operated at this time by Wellhead Services. CVEC uses 19% aqueous ammonia for reducing the oxides of nitrogen which are produced from generating electricity.

No violations were observed during this inspection.

INSPECTION REMARKS:

Hazardous Materials Business Plan (HMBP) Remarks:

The most recent HMBP/CERS submittal was made on 6/24/2021 and was accepted by the CUPA the same day. Reminder that the entire Hazardous Materials Business Plan (HMBP) is required to be submitted in CERS annually, whether there are changes HM-924(01/15)

COUNTY OF SAN DIEGO

SUPPLEMENTAL COMPLIANCE

INSPECTION REPORT
INSPECTION DATE: 06/21/2021 PAGE 2 OF 9
RECORD ID #: DEH2011-HUPFP-214305
or not, pursuant to California Health and Safety Code (HSC) Chapter 6.95 section 25508(a)(1)(A). The HMBP consists of 3 parts:
1) Facility Information, 2) Hazardous Materials Inventory & Site Map, 3) Emergency Contingency Plan & Training Plan.

Also, CERS updates must be made within 30 days of any change that could affect emergency response. CERS is not “updated” unless the elements are “submitted” through the CERS website.

Be advised there are exemptions for hazardous materials reporting that may apply to this facility. A summary of reporting exemptions is here: http://www.sandiegocounty.gov/content/sdc/deh/hazmat/hazmat/hmd_chem_reporting_changes.html Your annual permit fees are attached to the number and quantity of hazardous materials you report through CERS, so it is in your best interest to carefully report these items and to not over-report your chemical inventory.

Release reporting requirements were discussed during this inspection. Training for HMBP including HAZCOM was last conducted 4/22/2021. The training program includes IIPP, PPE, Fire Prevention/Action Plan, Contractor & Visitor Control, HMBP and First Responder Awareness, among others.

*****

*SPCC Remarks:

Chula Vista Energy Center has a Federal SPCC plan on site describing over 5,500 gallons of petroleum stored mostly in oil-filled electrical equipment, most of which are exempt from APSA-regulation by definition in HSC 25270.2.

"Aboveground storage tank" in the California APSA regulation does not include oil-filled electrical equipment, including, but not limited to, transformers, circuit breakers, or capacitors, when the equipment contains less than 10,000 gallons of dielectric fluid, is in secondary containment and is inspected routinely. There are other exclusions in the law, but this is the one that applies for this facility.

At this time, based on observations made at the facility and discussions with Ty Cheesebrough and Susana Miramontes, this facility stores, at the most, about 1,125 gallons of petroleum which is subject to APSA. Until such time this facility stores 1,320 gallons of APSA-regulated petroleum on site or more, Chula Vista Energy Center is not subject to APSA.

This is important for 2 reasons:
1) the CUPA regulates APSA-requirements, but is not allowed to regulate the Federal SPCC requirements and 2) if your APSA-regulated petroleum is under 1,320 gallons, there is no additional annual CUPA permit fee for APSA.

Maintain your SPCC for the federal requirement as Chula Vista Energy Center is subject to Federal SPCC.

*****

Hazardous Waste Management Remarks:

Based on a visit to the facility, discussions with Susanna Miramontes and a review of the hazardous waste manifests for the last three years, this facility appears to be, at this time, a small quantity generator (SQG) of hazardous wastes.

Hazardous wastes routinely generated on site include: oily absorbent, oily water, used oil filters and universal wastes (in small quantities). Universal wastes are consolidated at the El Cajon facility.

There are also non-hazardous waste manifests for oily water (<10% oil) which is generated from the "wash down tank."

Spill kits were observed on site today.

*****

HM-924(01/15)

COUNTY OF SAN DIEGO

SUPPLEMENTAL COMPLIANCE

INSPECTION REPORT
INSPECTION DATE: 06/21/2021 PAGE 3 OF 9
RECORD ID #: DEH2011-HUPFP-214305
CalARP Remarks:

Program 1 - Ammonium Hydroxide
Chula Vista Energy Center (CVEC) submitted a Program 1 RMP update to the CUPA 6/7/2018. The 12,000 gallon storage tank contains 10,200 gallons of 19% aqueous ammonia. The Off-site Consequences Analysis (OCA) uses the program SCREEN3 which describes a toxic endpoint traveling to 12 feet. This end point distance considers that the 10,200 gallons of ammonia will "instantaneously" flow beneath the covered containment. Two long "slat" openings and an estimated "greatly reduced evaporation rate" from being below the covered containment were considered in the Off-site Consequences Analysis (OCA). The area of concern keeps the plume of ammonia on the CVEC property according to the worst case scenario they submitted to the CUPA. The Hazard Assessment indicates there will be no off-site impacts from a worst case release of all contents of the ammonium hydroxide tank. An RMP update is required every 5 years. Be sure to also perform a new Hazard Assessment every 5 years.

Be advised that the CUPA is reviewing the OCA for all Program 1 Facilities to verify facilities fall into the correct program level. A request to revisit the worst-case OCA will come in writing.

Incident Investigation: Near misses are investigated and documented. There have been no near missed or releases of ammonia in the last 5 years.

Emergency Response: Chula Vista Energy is a non-responding facility. They rely on the local fire department and the Regional Hazardous Incident Response Team (HIRT) for emergency response to ammonium hydroxide spills. Safety equipment such as emergency eyewash/showers were working and well-identified today. Process piping has labels which indicate flow direction and material state of matter.

The local Fire Department visits at least annually for either a routine visit, new employee orientation or evacuation and response drills. As a Program 1 Facility you are required to ensure that response actions have been coordinated with local emergency planning and response agencies (e.g., site visits by first responders). Document these.

RMP Certification Statement in this RMP is the proper statement that is provided in Section 2735.5(d)(4).

The 5-year updated and certified (2745.9) RMP (including Registration Information 2740.1, Executive Summary 2745.3, Offsite Consequence Analysis 2745.4, 5-year accident history 2745.5 may be e-mailed, sent by courier or through U.S. Mail, to the CUPA, as you like, but not through CERS.

**********

Due to the COVID-19 Pandemic and social distancing, this report was completed by Manon Maschue, left unsigned, and then provided by e-mail to the Facility Representative listed at the bottom of the report on 5/27/2021.

**********

DIRECT QUESTIONS AND/OR CORRESPONDENCE REGARDING THIS REPORT TO:

Manon Maschue, REHS, EHS III
County of San Diego, DEHQ, Hazardous Materials Division PO Box 129261
San Diego, CA 92112-9261
858-518-7390 | [email protected]

**********

HM-924(01/15)

COUNTY OF SAN DIEGO

SUPPLEMENTAL COMPLIANCE

INSPECTION REPORT
INSPECTION DATE: 06/21/2021 PAGE 4 OF 9
RECORD ID #: DEH2011-HUPFP-214305
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 , Manon Maschue , 858-518-7390 [email protected]

INSPECTION PHOTOS
None

INSPECTION ATTACHMENTS
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
Susana Miramontes

TITLE OF FACILITY REPRESENTATIVE
Administration and EH&S Specialist

SIGNATURE
Signature Not Obtained

DATE SIGNED
Department of Environmental Health, Hazardous Materials Division, P.O. Box 129261, San Diego, CA 92112-9261 Phone: (858) 505-6880 http://www.sdcdeh.org

C O U N T Y O F S A N D I E G O

COMPLIANCE INSPECTION REPORT
Handlers of Hazardous Materials and Small and Large
Quantity Generators of Hazardous Waste
INSPECTION DATE: 06/21/2021 PAGE 5 OF 9
RECORD ID #: DEH2011-HUPFP-214305
FACILITY NAME: *CHULA VISTA ENERGY CENTER, LLC
ADDRESS: * 3497 MAIN ST CITY/ZIP: *CHULA VISTA 91911
Each violation checked below is for the section(s) of the California Health and Safety Code (HSC), 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

HAZARDOUS MATERIALS REQUIREMENTS
# VIOLATION DESCRIPTION
1010001 Failed to establish and implement a HMBP. HSC 25505(a) and 25507(a) 1010002 HMBP not submitted in CERS within the required timeframe. HSC 25508(a)(1)(A); 27 CCR 15188(a),(b),(d) 1010003 Business activities &/or Business Owner/Operator page not complete or accurate in CERS. 19 CCR 2652(a)(1); SDCC 68.904(b); HSC 25508(a)(1)(A), 25508(a)(3)
1010004 Chemical inventory incomplete or not submitted in CERS. HSC 25505(a)(1); 25507(a); 25508.1(a-b); 19 CCR 2654 (a) or (d) 1010005 Site map not submitted in CERS or not sufficient. HSC 25505(a)(2); 25508.1(f); 19 CCR 2652(a)(3) 1010006 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 25508.1(a-f); 19 CCR 2654(d); SDCC 68.904(c)(6)
1010008 HMBP not certified as complete and accurate in CERS by the required due date. HSC 25508.2, 19 CCR 2654(b) 1010010 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)(1)(A), 25508(a)(3); 19 CCR 2658
1010011 Failure to notify property owner in writing that the business is subject to the HMBP program. HSC 25505.1 1010012 Failure to provide a copy of HMBP to the property owner within five working days upon request from property owner. HSC 25505.1 1010014 Failure to submit emergency response plan in CERS, when not meeting agricultural handler exemption. HSC 25507.1(a) and 25508(a)(1)(A); 19 CCR 2670, 2671
1010015 Failure to submit employee training plan in CERS, when not meeting agricultural handler exemption. HSC 25507.1(a) and 25508(a)(1)(A) 1010016 HMBP not established or submitted in CERS, when not meeting the remote site exemption. HSC 25507.2 and 25508(a)(1)(A) 1020001 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)(1)(A), 25508(a)(3); 19 CCR 2658, 2659(a) 1030001 (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 25507.1(a)(2); 19 CCR 2670, 2671 1020002 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) 1040001 Hazardous materials release or threatened release not immediately reported to the CUPA and OES upon discovery. HSC 25510(a); 19 CCR 2631(a) HMD1001 Unified Program Facility permit not obtained for hazardous materials. SDCC 68.904; 68.905; 68.906, 68.907; 68.907.1 HMD1005 Emergency contact not provided or current in CERS. HSC 25508.1(f); SDCC 68.904(b) HMD1007 Highly toxic gas (TLV<10 ppm) not disclosed in CERS. SDCC 68.1113(a) HMD1008 Annual carcinogen/reproductive toxin list not submitted in CERS. SDCC 68.1113(b) 1010017 HMBP not readily available to facility personnel or the CUPA. HSC 25505(c)

HAZARDOUS WASTE REQUIREMENTS FOR SQGS ONLY
# VIOLATION DESCRIPTION
HMD0226 Did not accumulate waste in a container or tank. 22 CCR 66262.34(d)(2); 40 CFR 262.34(d)(2) 3030007 Failed to properly label/date hazardous waste container &/or tank. 22 CCR 66262.34(f) 3030010 Accumulated waste too long (>180 or 270 days) or (>90 days). HSC 25201(a), 25123.3(h)(1); 22 CCR 66262.34 (b), 66262.34(d); 40 CFR 262.34(e) and/or (f)
3030013 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 3030015 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 3030017 Failed to properly close hazardous waste container(s). 22 CCR 66262.34(d)(2); 40 CFR 262.34(d)(2), 265.173 3030019 Failed to inspect hazardous waste storage area at least weekly. 22 CCR 66262.34(d)(2); 40 CFR 262.34(d)(2), 265.174 3030022 Failed to properly separate incompatible waste. 22 CCR 66262.34(d)(2); 40 CFR 262.34(d)(2), 265.177 3030030 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 3030036 Failed to maintain adequate aisle space. 22 CCR 66262.34(d)(2); 40 CFR 262.34(d)(4), 265.35 3010022 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)
3020001 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) 3030032 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 3030039 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) HMD0412 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)

HAZARDOUS WASTE TANK SYSTEMS FOR SQGS ONLY
# VIOLATION DESCRIPTION
HM-923 (10-18)

C O U N T Y O F S A N D I E G O

COMPLIANCE INSPECTION REPORT
Hazardous Materials and Hazardous Waste (continued)
INSPECTION DATE: 06/21/2021 PAGE 6 OF 9
RECORD ID #: DEH2011-HUPFP-214305
3030024 Failed to operate uncovered tank to ensure at least 2 ft. of freeboard 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)
3030025 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) 3030027 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)
3030028 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) 3050007 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)
HMD1612 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) HMD1614 Failed to pre-notify the CUPA in writing prior to closing a hazardous waste tank system. 22 CCR 67383.3(a)(1) HMD1615 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 LQGS

RECORD KEEPING/OPERATIONAL REQUIREMENTS
# VIOLATION DESCRIPTION
HMD0131 Unified Program Facility Permit not obtained &/or maintained for the generation of hazardous waste. SDCC 68.904; 68.905; 68.907.1 HMD0150 Failed to submit complete and accurate Facility Information in CERS. 27 CCR 15188(b-c); SDCC 68.904(b) 3030053 Failed to maintain waste analysis records, analytical records &/or waste determination results for at least 3 years. 22 CCR 66262.40(c) 3010002 Failed to obtain &/or maintain an active EPA ID Number. 22 CCR 66262.12(a) 3010008 Failed to properly complete a uniform hazardous waste manifest. 22 CCR 66262.23(a) 3010009 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) 3010010 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)
3010011 Failed to send copy of the uniform hazardous waste manifest to DTSC within 30 days of shipment. 22 CCR 66262.23(a)(4) 3010013 Failed to meet the consolidated manifesting requirements for waste shipment. HSC 25160.2(b)(3) &/or (c) 3010014 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) 3030006 Failed to determine if a hazardous waste is restricted or prohibited from land disposal and has to be treated. 22 CCR 66268.7(a)(1) 3010016 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 25143.10(a), (c) &/or (d) HMD0149 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) HMD0152 Failed to report &/or update the required inventory information for hazardous waste(s) generated at the facility in CERS. SDCC 68.904(a)(2) HMD0140 Failed to have Land Disposal Restriction documentation onsite for 3 years. 22 CCR 66268.7(a)(8) 3250005 Failed to obtain a Treatment, Storage and Disposal Facility (TSDF) permit or authorization to store/treat/dispose of hazardous waste. HSC 25201(a) 3050005 Failed to have adequate records demonstrating claim of exemption or exclusion for recyclable materials. HSC 25143.2(f) HMD0142 Failed to notify the CUPA in CERS for onsite hazardous waste treatment/tiered permitting. HSC 25201(a) HMD0138 Manifest signed by the TSDF not available for inspection. 22 CCR 66262.40(a); HSC 25185(a)(4) 3010035 Failure to annually submit notification of generator's intent to remotely consolidate hazardous waste. HSC 25110.10(d)

DISPOSAL AND TRANSPORTATION
# VIOLATION DESCRIPTION
3010007 Failed to prepare a hazardous waste manifest for the transport of a waste for off-site transfer, treatment, storage, or disposal. HSC 25160(b)(1) or (2), 25160.2(b)(9); 22 CCR 66262.20(a)
3030005 Failed to make a proper waste determination. 22 CCR 66262.11, 66262.40(c) 3050001 Failed to use a DTSC registered hazardous waste transporter to transport hazardous waste. HSC 25163(a) 3050002 Failed to properly dispose of hazardous waste at an authorized facility. HSC 25189.5(a) HMD0308 Impermissible dilution of hazardous waste. 22 CCR 66268.3(a) HMD0305 Disposed of used oil illegally. HSC 25250.5(a), 25189.5(a) HMD0306 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
3030001 Failed to meet the management requirements when handling or storing spent lead-acid batteries. 22 CCR 66266.81(a) 3030003 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)
3030004 Failure to properly manage used oil filters and/or fuel filters in accordance with the requirements. HSC 25250.22; 22 CCR 66266.130 3050004 Generator intentionally contaminated used oil with another hazardous waste other than minimal amounts of fuel. HSC 25250.7(a), (c) HMD0222 Failed to properly label Excluded Recyclable Materials (ERM) accumulated in a container or tank. HSC 25143.9(a) HMD0216 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)
HMD0217 Failed to repackage and properly label damaged/deteriorated hazardous material container within 96 hours. HSC 25124(b)(3)(B); 22 CCR 66262.34(f) HMD0219 Failed to properly segregate used oil &/or fuel drained from filters. HSC 25250.22(b)(4); 22 CCR 66266.130(c)(6) 3030057 Failed to comply with hazardous waste satellite container regulation. 22 CCR 66262.34(e) HMD0023 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)

C O U N T Y O F S A N D I E G O

COMPLIANCE INSPECTION REPORT
Hazardous Materials and Hazardous Waste (continued)
INSPECTION DATE: 06/21/2021 PAGE 7 OF 9
RECORD ID #: DEH2011-HUPFP-214305
3030058 Failed to mark date on empty container larger than 5 gallons &/or manage it within one year. 22 CCR 66261.7(f) 3030060 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 25200.3.1(b) and/or (c)

UNIVERSAL WASTE HANDLER REQUIREMENTS
# VIOLATION DESCRIPTION
3010004 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)
HMD0151 Failed to maintain universal waste handler training records for 3 years. 22 CCR 66273.36(c),(d) 3020003 Failed to properly train handlers of universal waste in universal waste management and response procedures. 22 CCR 66273.36(a),(b) 3030008 Failed to properly label or mark Universal Waste container, package, or pallet (excluding CESQUWG) 22 CCR 66273.34 3030011 Failed to properly dispose of Universal Waste within one year. 22 CCR 66273.35(a) &/or (b) HMD0147 Failed to keep records of offsite Universal Waste shipment(s) available for inspection for 3 years. 22 CCR 66273.39(c),(d)(2) 3030051 Failed to meet accumulation, labeling, marking, &/or containment standards for Universal Waste aerosol containers. HSC 25201.16(f) 3040004 Failed to manage universal waste in a manner to prevent release(s) to the environment. 22 CCR 66273.33; 66273.33.5 HMD0307 Disposal of universal waste (UW) to an unauthorized point. HSC 25189.5(a); 22 CCR 66273.31(a), 66273.8(b) 3010005 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) 3010020 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)
3010006 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
3010033 Failure to obtain Certified Appliance Recycler certification (CAR) from DTSC. HSC 25211.4 3010034 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
3030055 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)
HM-923 (10-18)

C O U N T Y O F S A N D I E G O

COMPLIANCE INSPECTION REPORT
California Accidental Release Prevention (CalARP)
Program 1
INSPECTION DATE: 06/21/2021 PAGE 8 OF 9
RECORD ID #: DEH2011-HUPFP-214305
VIOLATION REPORT: Each violation checked below is for the section(s) of the California Health and Safety Code (HSC), 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) and Title 42 of the United States Code (USC) 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. Administering Agency (AA); process hazard analysis (PHA); process safety information (PSI); emergency response (ER); regulated substance (RS); stationary source (SS); threshold quantity (TQ)

GENERAL APPLICABILITY & COORDINATION
# VIOLATION DESCRIPTION
5010001 Failure to comply with CalARP provisions when having a regulated substance in a process listed in Table 1/2. 19 CCR 4.5 2735.4(a)(1) 5010002 Failure to comply with the appropriate provisions of 19 CCR 4.5 prior to the date in which a regulated substance is first present in a process above the listed threshold quantity, as listed in Table 3 of Section 2770.5. 19 CCR 4.5 2735.4(a)(2) 5010003 Failure to comply with CalARP provisions when having a regulated substance in a process listed in Table 1/2 and 3. 19 CCR 4.5 2735.4(a)(3) 5010004 Failure to closely coordinate with the CUPA to implement the CalARP requirements. 19 CCR 4.5 2735.5(a) 5030005 Failure to identify hazards that may result from releases, design and maintain a safe facility or minimize the consequences of an accidental release. HSC 25531.2(b)
5010006 Failure to ensure response actions are coordinated with local emergency planning and response agencies. 19 CCR 4.5 2735.5(d)(3) 5010120 Failure to coordinate with CUPA to ensure appropriate technical standards are applied to implement CalARP. 19 CCR 4.5 2785.1(a) 5010121 Failure to request assistance from the CUPA when necessary to address compliance/safety issues with CalARP. 19 CCR 4.5 2785.1(b)

RMP COMPONENTS AND SUBMISSION

RMP SUBMISSION
# VIOLATION DESCRIPTION
5010005 Failure to submit an RMP which includes all requirements in Section 2745.3 to 2745.5 and 2745.8 to 2745.9. 19 CCR 4.5 2735.5(b)(1), 2735.5(d), 2745.1(a)
5010016 Failure to submit the RMP information required by the USEPA to the USEPA. 19 CCR 4.5 2745.1(b)(1), 2745.1(b)(2) 5010017 Failure to submit the RMP information required by the USEPA to the CUPA. 19 CCR 4.5 2745.1(c) 5010018 Failure of a stationary source to submit a Risk Management Plan to the CUPA after the owner or operator has received a notice from the CUPA requesting submission of a Risk Management Plan. HSC 6.95 25536(b) 5010019 Failure to submit an RMP to the CUPA prior to the date a RS is in a process above the TQ. 19 CCR 4.5 2745.1(d) 5010020 Failure to exclude classified information from the RMP. 19 CCR 4.5 2745.1(h)

RMP CERTIFICATION
# VIOLATION DESCRIPTION
5010021 Failure to ensure that the RMP is certified complete by a QUALIFIED PERSON and the stationary source owner or operator. 19 CCR 4.5 2745.2(a) 5010023 Failure to submit in the RMP the certification statement provided in Section 2735.5(d)(4).

RMP UPDATES
# VIOLATION DESCRIPTION
5010025 Failure to revise, update, and submit the RMP to the USEPA and CUPA per timelines in Section 2745.10(a). 19 CCR 4.5 2745.10(a) 5010026 Failure to revise, update, and submit the RMP to the USEPA and CUPA per timelines in Section 2745.10(b). 19 CCR 4.5 2745.10(b) 5010027 Failure to submit a de-registration to the USEPA and CUPA within six months of the regulated substance removal. 19 CCR 4.5 2745.10(c) 5010028 Failure to submit a de-registration to the CUPA within six months of the regulated substance removal. 19 CCR 4.5 2745.10(d) 5010029 Failure to contact the CUPA within 30 days of a change of owner or operator to update the registration. 19 CCR 4.5 2745.10(f)

RMP CORRECTIONS
# VIOLATION DESCRIPTION
5010030 Failure to correct and submit the data required in the RMP under sections 2745.5, 2745.6(j), and 2745.7(1) (New Accident History). 19 CCR 4.5 2745.10.5(a)
5010031 Failure to correct and submit the EMERGENCY CONTACT information in the RMP within one month of any change. 19 CCR 4.5 2745.10.5(b)

COVERED PROCESS MODIFICATION
# VIOLATION DESCRIPTION
5010032 Failure to notify the CUPA in writing of the intent to modify the stationary source at least five calendar days before implementing any modifications or no later than 48 hours following the modification if prenotification is not reasonable. 19 CCR 4.5 2745.11(a)(1) 5010033 Failure to establish procedures to manage the proposed modification, which shall be substantially similar to the procedures specified in Sections 2760.6 and 2760.7, and notify the CUPA that the procedures have been established. 19 CCR 4.5 2745.11(a)(2) 5010262 Failure to revise documents as required pursuant to section 2745.11(a) at a modified stationary source. 19 CCR 4.5 2645.11(b)

CERTIFICATE OF OCCUPANCY
# VIOLATION DESCRIPTION
5010034 Failure to comply with Government Code Section 65850.2(b) prior to issuance of a certificate of occupancy. 19 CCR 4.5 2745.12

RMP REVIEW
# VIOLATION DESCRIPTION
5010022 Failure to correct deficiencies within 60 calendar days from receipt of the notification of RMP deficiencies. 19 CCR 4.5 2745.2(b)(1)

REGISTRATION
# VIOLATION DESCRIPTION
5010008 Failure to include a registration in the RMP that reflects all covered processes. 19 CCR 4.5 2735.5(b)(2) 5010012 Failure to complete the registration information and submit it with the RMP to the USEPA and the CUPA. 19 CCR 4.5 2740.1(a) 5010013 Failure to complete the REGISTRATION information and submit it with the RMP to the CUPA.

HM-972 CalARP (10-18)

C O U N T Y O F S A N D I E G O

COMPLIANCE INSPECTION REPORT
CalARP Program 1 (continued)
INSPECTION DATE: 06/21/2021 PAGE 9 OF 9
RECORD ID #: DEH2011-HUPFP-214305
5010014 Failure to submit a registration with a certification of accuracy to the CUPA prior to submittal of the RMP. 19 CCR 4.5 2740.1(c) 5010015 Failure to include the data required in Section 2740.1(d)(1) through (d)(20) in the registration. 19 CCR 4.5 2740.1(d)

HAZARD ASSESSMENT
# VIOLATION DESCRIPTION
5010035 Failure to prepare a worst-case release scenario analysis as provided in Section 2750.3. 19 CCR 4.5 2750.1 5010036 Failure to complete the five-year accident history as provided in Section 2750.9. 19 CCR 4.5 2750.1

RECORDKEEPING
# VIOLATION DESCRIPTION
5010119 Failure to maintain records supporting the implementation of CalARP for five years unless otherwise provided. 19 CCR 4.5 2775.1 HM-972 CalARP (10-18)
HM-924(01/15)

COUNTY OF SAN DIEGO

COMPLIANCE INSPECTION REPORT
FACILITY NAME: CHULA VISTA ENERGY CENTER, LLC
ADDRESS: 3497 MAIN ST
CITY/ZIP: CHULA VISTA /91911
INSPECTION DATE: 06/29/2023 PAGE 1 OF 13
RECORD ID #: DEH2011-HUPFP-214305
TIME START: 8:00 AM END: 12:30 PM
SPECIALIST: Manon Maschue
INSPECTION CONTACT:Susanna Miramontes
TITLE: EH&S Specialist
PHONE:(619) 579-9002
E-MAIL:[email protected]
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. ✖ Unified Program Facility Permit Current
✖ Hazardous Materials Business Plan Available
✖ Employee Training is Adequate
✖ Waste Disposal Records Available for Review
✖ Emergency Contacts Current Updated today
Chemical Inventory/Map Current Updated today
✖ Contingency Plan Available LQG SQG✖
✖ Employee Training Records Available
✖ Universal Waste Managed Properly
✖ Waste Containers Closed✖ Labeled✖
✖ Waste Containers in Good Condition
Permit Expires On 08/31/2023
CONSENT TO CONDUCT INSPECTION GRANTED BY: Susanna Miramontes TITLE: EH&S Specialist INTRODUCTION:

Routine Inspection
The County of San Diego Hazardous Materials Division (HMD) is a division of the Department of Environmental Health & Quality (DEHQ). DEHQ is the Certified Unified Program Agency (CUPA) for the County of San Diego. A routine CUPA facility inspection was conducted 6/29/2023 with Susana Miramontes, EH&S Specialist and Ty Cheesbrough of Wellhead Services. Belinda Velediaz, EHS III with DEHQ, participated in the inspection. Consent to inspect, sample and photograph as needed was obtained from Susana Miramontes. The inspection was conducted to assess compliance with the following Unified Program elements:
• Hazardous Materials Chemical Inventory & Business Plan (HMBP) (HSC Div 20 Ch 6.95 Art 1 & 19 CCR Div 2 Ch 4) • Aboveground Petroleum Storage Act (APSA) (CA HSC Ch 6.67 and 40 CFR Sec 112 - SPCC Plan) • Hazardous Waste Management (HSC Div 20 Ch 6.5 & 22 CCR Div 4.5 Ch 10)

• California Accidental Release Prevention Program (CalARP) (HSC Div 20 Ch 6.95 Art 2 & 19 CCR Div 2 Ch 4.5) The Chula Vista Energy Center (CVEC) is a 35 megawatt (nominal) natural gas-fired power plant that is typically not staffed.

Typically the plant runs less than 100 hours per year. The plant is operated at this time by Wellhead Services. CVEC uses 19% aqueous ammonia for reducing air pollution (oxides of nitrogen (NOx)) produced from generating electricity. The process of NOx reduction is called selective catalytic reduction (SCR). SCR is a permitted air pollution control system.

INSPECTION REMARKS:

Hazardous Materials Business Plan (HMBP) Remarks:

CERS ID: 10359508
The most recent HMBP/CERS submittal was made on 7/5/2023 for the following elements:
• Facility Information (Owner Operator & Business Activities) • Chemical Inventory & Site Map
• APSA Element
This submittal included minor technical edits to the site map including having all of the labels face the same direction as provided in the CUPA's sit map instructions.

The last submittal for the "Plans" CERS element was made on 5/26/2023.

HM-924(01/15)

COUNTY OF SAN DIEGO

SUPPLEMENTAL COMPLIANCE

INSPECTION REPORT
INSPECTION DATE: 06/29/2023 PAGE 2 OF 13
RECORD ID #: DEH2011-HUPFP-214305

Remember to review and resubmit the following three required CERS elements at least annually even if there are no changes:
• Facility Information (Owner Operator & Business Activities) • Chemical Inventory & Site Map
• Plans Element (Emergency Response and Training Plans)

Training for HMBP including HAZCOM, Release Reporting, RMP and SPCC was last conducted 5/4/2023. The training program includes IIPP, PPE, Fire Prevention/Action Plan, Contractor & Visitor Control, HMBP and First Responder Awareness, among others.

Incompatible Chemical Storage Corrected during the inspection:
o One half gallon bottle of sodium hypochlorite (5%) (household bleach) was observed inside the flammable cabinet and was removed to safer storage during the inspection.

Fire System Suppression Chemicals exempted from Chemical Inventory Reporting:
o There is on site compressed Nitrogen used for fire fighting. It provides pressure to sprinklers. This fire suppression system is not in CERS due to a local exemption.
o FM200 is used for fire suppression for the control room. This is also not reported in CERS due to fire suppression system exemption.
o No CO2 observed on site during this inspection.

*****

APSA/SPCC Remarks:

Chula Vista Energy Center has a Federal SPCC plan on site describing over 5,500 gallons of petroleum stored mostly in oil-filled electrical equipment, most of which are exempt from APSA-regulation by definition in HSC 25270.2.

"Aboveground storage tank" in the California APSA regulation does not include oil-filled electrical equipment, including, but not limited to, transformers, circuit breakers, or capacitors, when the equipment contains less than 10,000 gallons of dielectric fluid, is in secondary containment and is inspected routinely. There are other exclusions in the law, but this is the one that applies for this facility.

At this time, based on observations made at the facility and discussions with Ty Cheesebrough and Susana Miramontes, this facility stores, at the most, about 1,128 gallons of petroleum which is subject to APSA. Included in the 1,128 gallons, there is on site one 750 gallon Tank in and Underground Area (TIUGA). Due to the existence of this TIUGA, Chula Vista Energy Center is subject to APSA.

An APSA CERS submittal was made during this inspection on 7/5/2023.

Training/Spill Prevention briefings are conducted and documented. Last SPCC Training was conducted 5/4/2023.

The SPCC is P.E. Certified. The SPCC Plan was last reviewed for changes 5/11/2021.

*****

Hazardous Waste Management Remarks:

CalEPA ID CAL 000 346 986

Based on a visit to the facility, discussions with Susanna Miramontes and a review of the hazardous waste manifests for the last three years, this facility appears to be, at this time, a small quantity generator (SQG) of hazardous wastes.

HM-924(01/15)

COUNTY OF SAN DIEGO

SUPPLEMENTAL COMPLIANCE

INSPECTION REPORT
INSPECTION DATE: 06/29/2023 PAGE 3 OF 13
RECORD ID #: DEH2011-HUPFP-214305
Hazardous wastes routinely generated on site include: oily absorbent, oily water, used oil filters and universal wastes (in small quantities). Universal wastes are consolidated at the El Cajon facility.

There are also non-hazardous waste manifests for oily water (<10% oil) which is generated from the "wash down tank." Spill kits were observed on site today.

Hazardous Waste Management Training was last conducted 3/8/2022.

*****

CalARP Remarks:

Covered Process & Program: The facility stores 10,200 gallons of aqueous ammonia in a 12,000 gallon tank. Tank is said to be maximum 85% full. The ammonia is reported as 19% concentration.

Aqueous ammonia is used at this facility in an air pollution control application known as selective catalytic reduction (SCR).

CVEC has submitted a Program 1 RMP for this process. The Off-site Consequences Analysis (OCA) uses the program SCREEN3 which describes a toxic endpoint traveling to 12 feet. This end point distance considers that the ammonia will "instantaneously" flow beneath the covered containment. Two long "slat" openings and an estimated "greatly reduced evaporation rate" from being below the covered containment were considered in the Off-site Consequences Analysis (OCA). The area of concern keeps the plume of ammonia on the CVEC property according to the worst case scenario they submitted to the CUPA. The Hazard Assessment indicates there will be no off-site impacts from a worst case release of all contents of the ammonium hydroxide tank.

Be advised that the CUPA is reviewing the OCA for all Program 1 Facilities to verify facilities fall into the correct program level. A request to revisit the worst-case OCA will come in writing.

***
RMP Submittal: Chula Vista Energy Center (CVEC) submitted a Program 1 RMP update to the CUPA dated 10/2019.

***
RMP Certification Statement: This RMP contains the proper certification statement found in 19 CCR Section 2735.5(d)(4).

***
RMP Updates: Every 5 years this facility is required to submit an RMP Update to the CUPA to include an updated Hazard Assessment and 5-year accident history.

At this time, CalARP-specific information is not submitted through CERS. When changes in personnel occur that affect the CalARP Program, submit any CalARP responsible party, CalARP Qualified Person, certification or other modifications in writing within 30 days from the change directly to the CUPA (using mail, courier or e-mail), not through CERS.

***
Five (5)-year Accident History & Incident Investigations: There have been no releases of ammonia in the last 5-years per statements by Susanna Miramontes.

***
HM-924(01/15)

COUNTY OF SAN DIEGO

SUPPLEMENTAL COMPLIANCE

INSPECTION REPORT
INSPECTION DATE: 06/29/2023 PAGE 4 OF 13
RECORD ID #: DEH2011-HUPFP-214305
Emergency Response: CVEC is a non-responding CalARP facility. Per statements from Susanna Miramontes and Ty Cheesbrough, in the event of an ammonia release, staff will size-up, isolate and deny entry and call for a response from local FD and a clean up contractor if needed.

Safety equipment such as emergency eyewash/showers were working and well-identified today. The ammonia tank sits inside a properly sized secondary containment. The ammonia tank fill area is contained in a secondary containment. Delivery's of ammonia are witnessed and verified by facility staff. Process piping has labels which indicate the name of the contained material and flow direction of the contained material.

A windsock was visible during the inspection.

***
General Duty Clause: Be advised that the CUPA regulates California Health and Safety Code 25531.2. (b) which states:
...Owners and operators of stationary sources producing, processing, handling, or storing hazardous materials have a general duty, in the same manner and to the same extent as is required by Section 654 of Title 29 of the United States Code, to identify hazards that may result from releases using appropriate hazard assessment techniques, to design and maintain a safe facility taking those steps as are necessary to prevent releases, and to minimize the consequences of accidental releases that do occur.

29 U.S.C. § 654, 5(a)1, (the "General Duty Clause") requires the following: “Each employer shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees."

**********

This report was reviwed with the Facility Contact below and was submitted into eForms unsigned on 7/7/2023.

A copy of the signed report was requested and, when received, will be submitted to Acella.

**********

DIRECT QUESTIONS AND/OR CORRESPONDENCE REGARDING THIS REPORT TO:

Manon Maschue, REHS, EHS III
County of San Diego, DEHQ, Hazardous Materials Division PO Box 129261
San Diego, CA 92112-9261
858-518-7390 | [email protected]

**********

Helpful Websites:
• For guidance documents on hazardous materials-related topics, go to: https://www.sandiegocounty.gov/content/sdc/deh/hazmat/hmd_publications.html • For information on the California Environmental Reporting System (CERS), go to: https://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: https://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 HM-924(01/15)

COUNTY OF SAN DIEGO

SUPPLEMENTAL COMPLIANCE

INSPECTION REPORT
INSPECTION DATE: 06/29/2023 PAGE 5 OF 13
RECORD ID #: DEH2011-HUPFP-214305
If you have any questions regarding this inspection, please contact , Manon Maschue , 858.518.7390 [email protected]

INSPECTION PHOTOS
None

INSPECTION ATTACHMENTS
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:
https://www.sandiegocounty.gov/deh/hazmat/hmd_cers.html

PRINTED NAME OF FACILITY REPRESENTATIVE
Susanna Miramontes

TITLE OF FACILITY REPRESENTATIVE
EH&S Specialist

SIGNATURE
Signature Not Obtained

DATE SIGNED
Department of Environmental Health and Quality, Hazardous Materials Division, P.O. Box 129261, San Diego, CA 92112-9261 Phone: (858) 505-6880 http://www.sdcdehq.org
7/12/2023

C O U N T Y O F S A N D I E G O

COMPLIANCE INSPECTION REPORT
Handlers of Hazardous Materials and Small and Large
Quantity Generators of Hazardous Waste
INSPECTION DATE: 06/29/2023 PAGE 6 OF 13
RECORD ID #: DEH2011-HUPFP-214305
FACILITY NAME: *CHULA VISTA ENERGY CENTER, LLC
ADDRESS: * 3497 MAIN ST CITY/ZIP: *CHULA VISTA 91911
Each violation checked below is for the section(s) of the California Health and Safety Code (HSC), 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

HAZARDOUS MATERIALS REQUIREMENTS
# VIOLATION DESCRIPTION
1010001 Failed to establish and implement a HMBP. HSC 25505(a) and 25507(a) 1010002 HMBP not submitted in CERS within the required timeframe. HSC 25508(a)(1); 27 CCR 15188(a),(b),(d) 1010003 Business activities &/or Business Owner/Operator page not complete or accurate in CERS. 19 CCR 2652(a)(1); SDCC 68.904(b); HSC 25508(a)(1), 25508(a) (3)
1010004 Chemical inventory incomplete or not submitted in CERS. HSC 25505(a)(1); 25507(a); 25508.1(a-b); 19 CCR 2654 (a) or (d) 1010005 Site map not submitted in CERS or not sufficient. HSC 25505(a)(2); 25508.1(f); 19 CCR 2652(a)(3) 1010006 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 25508.1(a-f); 19 CCR 2654(d); SDCC 68.904(c)(6)
1010008 HMBP not certified as complete and accurate in CERS by the required due date. HSC 25508.2, 19 CCR 2654(b) 1010010 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)(1), 25508(a)(3); 19 CCR 2658
1010011 Failure to notify property owner in writing that the business is subject to the HMBP program. HSC 25505.1 1010012 Failure to provide a copy of HMBP to the property owner within five working days upon request from property owner. HSC 25505.1 1010014 Failure to submit emergency response plan in CERS, when not meeting agricultural handler exemption. HSC 25507.1(a) and 25508(a)(1); 19 CCR 2670, 2671
1010015 Failure to submit employee training plan in CERS, when not meeting agricultural handler exemption. HSC 25507.1(a), 25508(a)(1), 19 CCR 2670, 2671 1010016 HMBP not established or submitted in CERS, when not meeting the remote site exemption. HSC 25507.2 and 25508(a)(1) 1020001 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)(1), 25508(a)(3); 19 CCR 2659(a) 1030001 (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 25507.1(a)(2); 19 CCR 2670, 2671 1020002 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) 1040001 Hazardous materials release or threatened release not immediately reported to the CUPA and OES upon discovery. HSC 25510(a); 19 CCR 2631(a) HMD1001 Unified Program Facility permit not obtained for hazardous materials. SDCC 68.904; 68.905; 68.906, 68.907; 68.907.1 HMD1005 Emergency contact not provided or current in CERS. HSC 25508.1(f); SDCC 68.904(b) HMD1007 Highly toxic gas (TLV<10 ppm) not disclosed in CERS. SDCC 68.1113(a) 1010017 HMBP not readily available to facility personnel or the CUPA. HSC 25505(c)

HAZARDOUS WASTE REQUIREMENTS FOR SQGS ONLY
# VIOLATION DESCRIPTION
HMD0226 Did not accumulate waste in a container or tank. 22 CCR 66262.34(d)(2); 40 CFR 262.34(d)(2) 3030007 Failed to properly label/date hazardous waste container &/or tank. 22 CCR 66262.34(f) 3030010 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)(1)
3030013 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 3030015 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 3030017 Failed to properly close hazardous waste container(s). 22 CCR 66262.34(d)(2); 40 CFR 262.34(d)(2), 265.173 3030019 Failed to inspect hazardous waste storage area at least weekly. 22 CCR 66262.34(d)(2); 40 CFR 262.34(d)(2), 265.174 3030022 Failed to properly separate incompatible waste. 22 CCR 66262.34(d)(2); 40 CFR 262.34(d)(2), 265.177 3030030 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 3030036 Failed to maintain adequate aisle space. 22 CCR 66262.34(d)(2); 40 CFR 262.34(d)(4), 265.35 3010022 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)
3020001 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) 3030032 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 3030039 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) HMD0412 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)
3010030 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
HM-923 (08-21)

C O U N T Y O F S A N D I E G O

COMPLIANCE INSPECTION REPORT
Hazardous Materials and Hazardous Waste (continued)
INSPECTION DATE: 06/29/2023 PAGE 7 OF 13
RECORD ID #: DEH2011-HUPFP-214305
3030024 Failed to operate uncovered tank to ensure at least 2 ft. of freeboard 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)
3030025 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) 3030027 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)
3030028 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) 3050007 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)
HMD1612 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) HMD1614 Failed to pre-notify the CUPA in writing prior to closing a hazardous waste tank system. 22 CCR 67383.3(a)(1) HMD1615 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 LQGS

RECORD KEEPING/OPERATIONAL REQUIREMENTS
# VIOLATION DESCRIPTION
HMD0131 Unified Program Facility Permit not obtained &/or maintained for the generation of hazardous waste. SDCC 68.904; 68.905; 68.907.1 HMD0150 Failed to submit complete and accurate Facility Information in CERS. 27 CCR 15188(b-c); SDCC 68.904(b) 3030053 Failed to maintain waste analysis records, analytical records &/or waste determination results for at least 3 years. 22 CCR 66262.40(c) 3010002 Failed to obtain &/or maintain an active EPA ID Number. 22 CCR 66262.12(a) 3010008 Failed to properly complete a uniform hazardous waste manifest. 22 CCR 66262.23(a) 3010009 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) 3010010 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)
3010011 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)(1)(c)
3010013 Failed to meet the consolidated manifesting requirements for waste shipment. HSC 25160.2(b)(3) &/or (c) 3010014 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) 3030006 Failed to determine if a hazardous waste is restricted or prohibited from land disposal and has to be treated. 22 CCR 66268.7(a)(1) 3010016 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 25143.10(a), (c) &/or (d) HMD0149 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) HMD0152 Failed to report &/or update the required inventory information for hazardous waste(s) generated at the facility in CERS. SDCC 68.904(a)(2) HMD0140 Failed to have Land Disposal Restriction documentation onsite for 3 years. 22 CCR 66268.7(a)(8) 3250005 Failed to obtain a Treatment, Storage and Disposal Facility (TSDF) permit or authorization to store/treat/dispose of hazardous waste. HSC 25201(a) 3050005 Failed to properly manage a recyclable material. HSC 25143.2, 25143.9 HMD0142 Failed to notify the CUPA in CERS for onsite hazardous waste treatment/tiered permitting. HSC 25201(a) HMD0138 Manifest signed by the TSDF not available for inspection. 22 CCR 66262.40(a); HSC 25185(a)(4) 3010035 Failure to annually submit notification of generator's intent to remotely consolidate hazardous waste. HSC 25110.10(d) 3010037 Failure to notify the CUPA of aerosol can processing procedures prior to commencement of operations. HSC 25201.16(j)

DISPOSAL AND TRANSPORTATION
# VIOLATION DESCRIPTION
3010007 Failed to prepare a hazardous waste manifest for the transport of a waste for off-site transfer, treatment, storage, or disposal. HSC 25160(b)(1) or (2), 25160.2(b)(9); 22 CCR 66262.20(a)
3030005 Failed to make a proper waste determination. 22 CCR 66262.11, 66262.40(c) 3050001 Failed to use a DTSC registered hazardous waste transporter to transport hazardous waste. HSC 25163(a) 3050002 Failed to properly dispose of hazardous waste at an authorized facility. HSC 25189.5(a) HMD0308 Impermissible dilution of hazardous waste. 22 CCR 66268.3(a) HMD0305 Disposed of used oil illegally. HSC 25250.5(a), 25189.5(a) HMD0306 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
3030001 Failed to meet the management requirements when handling or storing spent lead-acid batteries. 22 CCR 66266.81(a) 3030003 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)
3030012 (RCRA LQG) Failed to properly dispose of hazardous waste within 90 days. 22 CCR 66262.34(a), (c); HSC 6.5 25123.3(b)(1) 3030004 Failure to properly manage used oil filters and/or fuel filters in accordance with the requirements. HSC 25250.22; 22 CCR 66266.130 3050004 Failure to prevent intentional contamination of used oil with other hazardous waste other than minimal amounts of vehicle fuel. HSC 25250.7(a) HMD0222 Failed to properly label Excluded Recyclable Materials (ERM) accumulated in a container or tank. HSC 25143.9(a) HMD0216 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)
HMD0217 Failed to repackage and properly label damaged/deteriorated hazardous material container within 96 hours. HSC 25124(b)(3)(B); 22 CCR 66262.34(f) HMD0219 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)

C O U N T Y O F S A N D I E G O

COMPLIANCE INSPECTION REPORT
Hazardous Materials and Hazardous Waste (continued)
INSPECTION DATE: 06/29/2023 PAGE 8 OF 13
RECORD ID #: DEH2011-HUPFP-214305
3030057 Failed to comply with hazardous waste satellite container regulation. 22 CCR 66262.34(e) 3030058 Failed to mark date on empty container larger than 5 gallons &/or properly manage it within one year. 22 CCR 66261.7 3030060 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 25200.3.1(b) and/or (c)

UNIVERSAL WASTE HANDLER REQUIREMENTS
# VIOLATION DESCRIPTION
3010004 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)
HMD0151 Failed to maintain universal waste handler training records for 3 years. 22 CCR 66273.36(c),(d) 3020003 Failed to properly train handlers of universal waste in universal waste management and response procedures. 22 CCR 66273.36(a),(b) 3030008 Failed to properly label or mark Universal Waste container, package, or pallet (excluding CESQUWG) 22 CCR 66273.34 3030011 Failed to properly dispose of Universal Waste within one year. 22 CCR 66273.35(a) &/or (b) HMD0147 Failed to keep records of offsite Universal Waste shipment(s) available for inspection for 3 years. 22 CCR 66273.39(c),(d)(2) 3030051 Failed to meet accumulation, labeling, marking, &/or containment standards for Universal Waste aerosol containers. HSC 25201.16(f) 3040004 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 HMD0307 Disposal of universal waste (UW) to an unauthorized point. HSC 25189.5(a); 22 CCR 66273.31(a), 66273.8(b) 3010005 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)
3010020 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)
3010006 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)
3110030 Failed to notify the CUPA of aerosol processing procedures prior to commencement of operations. HSC 25201.16(j)

CERTIFIED APPLIANCE RECYCLER REQUIREMENTS
# VIOLATION DESCRIPTION
3010033 Failure to obtain Certified Appliance Recycler certification (CAR) from DTSC. HSC 25211.4 3010034 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
3030055 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)

C O U N T Y O F S A N D I E G O

COMPLIANCE INSPECTION REPORT
Aboveground Petroleum Storage Act (APSA) Program
INSPECTION DATE: 06/29/2023 PAGE 9 OF 13
RECORD ID #: DEH2011-HUPFP-214305
Each violation checked below is for the section(s) of the California Health and Safety Code (HSC), California Code of Regulations (CCR), or 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 a DEH Corrective Action Form (HM-926) or other correspondence to document your return to compliance. Please call (858) 505-6880 or your Specialist if you have any questions.

GENERAL APSA FACILITY REQUIREMENT
(CHAPTER 6.67 OF DIVISION 20 OF THE HSC & SDCC)
# VIOLATION DESCRIPTION
4010001 Failed to prepare a Spill Prevention, Control, and Countermeasures (SPCC) Plan. HSC 25270.4.5(a), 40 CFR 112.3, 112.6 4030038 Failed to implement the SPCC Plan. HSC 25270.4.5(a), 40 CFR 112.3, 112.6 4010032 Failed to submit a tank facility statement or update/certify Business Plan annually. HSC 25270.6(a)(1) or (a)(2) 4010033 Failed to pay the APSA program fee or obtain Unified Program Facility Permit. HSC 25270.6(b), SDCC 68.904; 68.905; 68.907.1 4040001 Failed to immediately, upon discovery, report a one-barrel (42 gallons) or greater release of petroleum to Cal OES and the CUPA . HSC 25270.8 4010037 Failed to meet conditions of APSA exemption for oil-filled electrical equipment including containment and visual inspection. HSC 25270.2(a)(4), 25270.4.5(a)
4030043 Failed to have secondary containment and leak detection if piping connected to tank in an underground area (TIUGA) cannot be directly viewed on all sides. (Refer to HSC 6.67 for direct viewing; DOES NOT apply to: 1. Piping connected to a tank that contains new oil/used oil for lubricant or coolant in a motor engine or transmission, or oil-filled operational/manufacturing equipment. 2. Piping connected to a tank used solely in connection with a fire pump or emergency system, legally required by standby system, or optional standby system. 3. Piping connected to a petroleum hazardous waste tank that complies with hazardous waste tank standards (22 CCR Ch. 15, Art. 10) and facility has been issued a unified program facility permit pursuant to HSC 25404.2 for generation, treatment, accumulation, or storage of hazardous waste.) (24CCR Title 9 Section 5703.6.2.2.) HSC 25270.4.5(a), HSC 25270.2(o)(1)(C)(iv)
4030044 Failure of an owner/operator of an excluded tank in an underground area (TIUGA) with less than 55-gallon capacity to have secondary containment, conduct monthly inspections, and/or maintain a log of inspections. HSC 6.67 25270.2(a)(8) HMD5104 Failed to submit, and keep up to date, the APSA program element in CERS. SDCC 68.904; 27 CCR 15188(a),(b),(c),&(f) REQUIREMENTS BASED ON 40 CFR 112.1-112.6
# VIOLATION DESCRIPTION
4010035 Failed to prepare an appropriate SPCC Plan within 6 months when the facility no longer meets the Tier I or Tier II qualified criteria. 40 CFR 112.6(a)(2), 112.6(b)(2); HSC 6.67 25270.4.5 (a)
4010047 (Qualified Facility only- Tier I or II) Failed to have management, or a Professional Engineer if applicable, certify the SPCC Plan and comply with the certification requirements. (40 CFR 112.6(a)(1), 112.6(b).) HSC 25270.4.5(a) 4010048 (Qualified Facility only- Tier I) Failed to certify the SPCC Plan according to 40 CFR 112.6(a)(1) if a technical change has been made to the facility design, construction, operation, or maintenance. (40 CFR 112.6(a)(2).) HSC 25270.4.5(a) 4010052 (Qualified Facility only- Tier II) Failed to have technical amendment(s) certified by management, or a Professional Engineer if applicable. (40 CFR 112.6(b) (2), 112.6(b)(2)(i).) HSC 25270.4.5(a)
4010054 (Qualified Facility only- Tier I) Failed to include in the SPCC Plan a prediction of direction and total quantity of oil potentially discharged from the facility as a result of each type of major equipment failure. (40 CFR 112.6(a)(3)(i).) HSC 25270.4.5(a) 4030041 (Qualified Facility only- Tier I) Failed to provide bulk storage containers/tanks with adequate sized secondary containment to contain the capacity of the largest container plus freeboard for precipitation; failed to position/locate mobile or portable containers to prevent a discharge. (40 CFR 112.6(a) (3)(ii).) HSC 25270.4.5(a)
4030042 (Qualified Facility only- Tier I) Failed to provide systems or follow procedures to prevent overfills as described in the SPCC Plan; failed to routinely test overfill equipment to ensure proper operation. (40 CFR 112.6(a)(3)(iii).) HSC 25270.4.5(a) 4010003 Failed to have a Professional Engineer certify and review the SPCC Plan. (40 CFR 112.3(d).) HSC 25270.4.5(a) 4010008 Failed to maintain a complete copy of the SPCC Plan at the facility if the facility is normally attended at least four hours per day, or at the nearest field office if the facility is not so attended. (40 CFR 112.3(e)(1).) HSC 25270.4.5(a) 4010010 Failed to make SPCC Plan technical amendment(s) within six months when the facility has had a change in design, construction, operation, or maintenance which affects the facility's discharge potential; failed to implement within six months following preparation of the amendment. (40 CFR 112.5(a), 112.5(b).) HSC 25270.4.5(a)
4010009 Failed to perform and properly document a five-year review of the SPCC Plan. (40 CFR 112.5(b).) HSC 25270.4.5(a) 4010039 Failed to have technical amendments certified by a licensed Professional Engineer. (40 CFR 112.5(c).) HSC 25270.4.5(a)

GENERAL SPCC REQUIREMENTS
BASED UPON 40 CFR 112.7
# VIOLATION DESCRIPTION
4010012 Failed to prepare a written SPCC Plan in accordance with good engineering practices and any applicable more stringent State rules, regulations, and guidelines; failed to prepare a SPCC Plan that follows the sequence of rule or provides a cross-reference; failed to prepare a SPCC Plan that addresses additional procedures/methods/equipment not fully operational; failed to obtain facility management approval for implementation of the SPCC Plan . (40 CFR 112.7 and 112.7(a)(1).) HSC 25270.4.5(a) 4010014 Failed to include alternative environmental protection to SPCC requirements within SPCC Plan. (40 CFR 112.7(a)(2).) HSC 25270.4.5(a) 4010015 Failed to include in the SPCC Plan an adequate facility diagram, or no facility diagram included. The facility diagram is not required for a Tier I Qualified Facility. (40 CFR 112.7(a)(3).) HSC 25270.4.5(a)
4010016 Failed to adequately describe in the SPCC Plan the physical layout of facility, types of oil and storage capacities, tanks, containers, equipment, mobile refuelers, portable containers, transfer operations, and other required information. (40 CFR 112.7(a)(3), 112.7(a)(3)(i-vi).) HSC 25270.4.5(a) 4010017 Plan does not contain procedures for reporting a discharge, and/or a contact list and phone numbers for the facility response coordinator, National Response Center, cleanup contractors with an agreement for response, and all appropriate Federal, State, and local agencies. (40 CFR 112.7(a)(4).) HSC 25270.4.5(a)
4010018 Discharge response procedures are not adequately organized to be readily accessible in an emergency. (40 CFR 112.7(a)(5).) HSC 25270.4.5(a) 4010019 Failed to include in the SPCC Plan a prediction of the direction, rate of flow, and total quantity of oil that could be discharged for each type of major equipment failure where experience indicates a reasonable potential for equipment failure. (40 CFR 112.7(b).) HSC 25270.4.5(a) 4010020 (General Containment) Failed to provide, or include in the SPCC Plan, the appropriate containment, diversionary structures, or equipment to prevent a discharge that will not escape containment before cleanup occurs, including typical failure mode and most likely quantity of discharge. (40 CFR 112.7(c).) HSC 25270.4.5(a)
4010004 Failed to clearly explain why appropriate containment/diversionary structures are not practicable and/or SPCC Plan claiming impracticability is not certified by a licensed Professional Engineer. (40 CFR 112.7(d).) HSC 25270.4.5(a) HM-950 APSA (08-21)

C O U N T Y O F S A N D I E G O

COMPLIANCE INSPECTION REPORT
APSA Program (continued)
INSPECTION DATE: 06/29/2023 PAGE 10 OF 13
RECORD ID #: DEH2011-HUPFP-214305
4010005 Failed to prepare an Oil Spill Contingency Plan following the provisions of 40 CFR Part 109 for impracticability claim. (40 CFR 112.7(d)(1).) HSC 25270.4.5(a)
4010006 Failed to provide a written commitment of manpower, equipment, materials when claiming impracticability. (40 CFR 112.7(d)(2).) HSC 25270.4.5(a) 4010021 Failed to have record of inspections and integrity tests signed by the appropriate supervisor or inspector, keep written procedures and records of inspections and integrity tests for at least three years, and/or keep comparison records for bulk storage containers subject to 40 CFR 112.8(c)(6). (40 CFR 112.7(e), 112.8(c)(6).) HSC 25270.4.5(a)
4020002 Failure to conduct spill prevention briefing for oil-handling personnel at least once a year to assure adequate understanding of the SPCC Plan, including:

1. Known discharges or failures, 2. Malfunctioning components, 3. Any recently developed precautionary measures. 40 CFR 1 112.7(f)(3); HSC 6.67 25270.4.5(a)
4020001 Failed to train oil-handling personnel on: operation/maintenance of equipment to prevent discharges; discharge procedure protocols; applicable laws, rules, and regulations; general facility operations; and the contents of the SPCC Plan. (40 CFR 112.7(f)(1).) HSC 25270.4.5(a) 4010022 Failed to designate person accountable for discharge prevention who reports to facility management. (40 CFR 112.7(f)(2).) HSC 25270.4.5(a) 4010023 Failure to include in the SPCC Plan an adequate description of employee training. 40 CFR 1 112.7(f)(1), 40 CR 1 112.7(f)(3), HSC 6.67 25270.4.5(a) 4030001 Failed to address security and access control of the oil handling, processing, and storage areas to both prevent acts of vandalism and assist in discovery of discharges. (40 CFR 112.7(g).) HSC 25270.4.5(a)
4030002 (For loading/unloading racks) Failure of the secondary containment, and/or rack drainage to flow to a catchment basin, treatment system, or quick drainage system, and hold at least the maximum capacity of the largest single compartment of any tank car or tank truck. (40 CFR 112.7(h)(1).) HSC 25270.4.5(a)
4030003 (For loading/unloading racks) Failed to provide an interlocked warning light or physical barriers, warning signs, wheel chocks, or vehicle brake interlock system in the area adjacent to the loading/unloading rack to prevent vehicles from departing before complete disconnection of transfer lines. (40 CFR 112.7(h)(2).) HSC 25270.4.5(a)
4030016 Failed to evaluate field-constructed storage tank for brittle fracture or other catastrophe and take appropriate action. (40 CFR 112.7(i).) HSC 25270.4.5(a 4010013 Failure to discuss in the SPCC Plan conformance with SPCC requirements and other effective discharge prevention and containment procedures or any more stringent State rules, regulations and guidelines. (HSC 6.67 25270.4.5(a); 40 CFR 112.7(a)(1), 112.7(j)) 4030034 (For oil-filled operational equipment) Failed to provide general secondary containment or fulfill alternative requirements to general secondary containment. (40 CFR 112.7(k).) HSC 25270.4.5.(a)
SPCC REQUIREMENTS BASED UPON 40 CFR 112.8 & 112.20
REFER TO APSA (HSC CHAPTER 6.67) FOR DEFINITION OF "STORAGE TANK" # VIOLATION DESCRIPTION
4010027 Failed to restrain drainage from diked storage areas by valve(s) or manually activated pump/ejector to prevent discharge. (40 CFR 112.8(b)(1).) HSC 25270.4.5(a)
4030005 Failed to use valves of manual, open-and-closed design, for drainage of diked areas. (40 CFR 112.8(b)(2).) HSC 25270.4.5(a) 4030008 Facility drainage system from undiked areas not designed/equipped to retain oil or return oil to facility and/or failed to ensure catchment basin is not in an area subject to flooding. (40 CFR 112.8(b)(3), 112.8(b)(4).) HSC 25270.4.5(a) 4030009 Failed to provide at least two lift pumps and permanently install at least one pump where drainage waters are treated in more than one treatment unit and such treatment is continuous, and pump transfer is needed. (40 CFR 112.8(b)(5).) HSC 25270.4.5(a) 4030012 Storage tanks not compatible with materials stored or conditions of storage. (40 CFR 112.8(c)(1).) HSC 25270.4.5(a) 4030010 (Sized Containment) Secondary containment not sized to contain the entire capacity of the largest single storage tank plus freeboard for precipitation. (40 CFR 112.8(c)(2).) HSC 25270.4.5(a)
4030013 Failure to ensure diked areas are sufficiently impervious to contain discharged oil. (40 CFR 112.8(c)(2).) HSC 25270.4.5(a) 4030006 Failed to ensure all of the following before allowing drainage of uncontaminated rainwater from diked area: keep bypass valve normally sealed closed, inspect the retained rainwater, and open then reseal bypass valves under responsible supervision. (40 CFR 112.8(c)(3).) HSC 25270.4.5(a) 4010026 Failed to maintain adequate records (or NPDES permit records) of drainage from diked areas. (40 CFR 112.8(c)(3)(iv).) HSC 25270.4.5(a) 4030017 Failed to provide corrosion protection for partially buried storage tanks. (40 CFR 112.8(c)(5).) HSC 25270.4.5(a) 4030015 Failed to test or inspect each aboveground tank or container for integrity on a regular schedule and after material repairs. (40 CFR 112.7(e), 112.8(c)(6).) HSC 25270.4.5(a)
4030014 Failed to ensure tanks are inspected and tested by an appropriately qualified person in accordance with industry standards. (40 CFR 112.7(e), 112.8(c) (6).) HSC 25270.4.5(a)
4010028 Failed to include in the SPCC Plan procedures to test or inspect each aboveground container for integrity in accordance with industry standards on a regular schedule, after material repairs are made, by qualified personnel; failed to include the frequency and type of testing and inspections based on container size, configuration, and design. (40 CFR 112.8(c)(6).) HSC 25270.4.5(a) 4030018 Failure of steam return/exhaust of internal heating coils, which discharge into an open water course, to be monitored, passed through a settling tank, skimmer, or other separation system. (40 CFR 112.8(c)(7).) HSC25270.4.5(a) 4030019 Failed to engineer or update each container/tank installation in accordance with good engineering practice to avoid discharges and/or failed to provide at least one of the following overfill prevention devices: audible/visual high liquid level alarm, high liquid level pump cutoff devices, audible or code signal communications between tank gauge and pumping station, or fast response system for determining liquid levels, such as computers, telepulse or direct vision gauges. (40 CFR 112.8(c)(8)(i-iv).) HSC 25270.4.5(a) 4030022 Failed to regularly test liquid level sensing devices to ensure proper operation. (40 CFR 112.8(c)(8)(v).) HSC 25270.4.5(a) 4030023 Failed to observe effluent treatment facilities frequently enough to detect any potential for discharges as described in 40 CFR 112.1(b). (40 CFR 112.8(c) (9).) HSC 25270.4.5(a)
4030021 Failed to promptly correct visible discharges and/or remove any accumulations of oil in diked areas. (40 CFR 112.8(c)(10).) HSC 25270.4.5(a) 4030020 (For mobile or portable storage tanks EXCEPT mobile refuelers) Failed to position or locate mobile or portable storage container, and/or failure to provide secondary containment with sufficient capacity to contain the largest single mobile or portable container/compartment and sufficient freeboard for precipitation. (40 CFR 112.8(c)(11).) HSC 25270.4.5(a) 4030025 Failed to inspect buried piping when exposed for any reason; failed to do additional examination or take corrective action if corrosion damage is identified. (40 CFR 112.8(d)(1).) HSC 25270.4.5(a)
4030027 Failed to provide corrosion protection for buried piping. (40 CFR 112.8(d)(1).) HSC 25270.4.5(a) 4030028 Failed to cap/blank-flange piping connection at transfer point and mark its origin if not in service. (40 CFR 112.8(d)(2).) HSC 25270.4.5(a) 4030029 Failed to design pipe supports to minimize abrasion/corrosion and to allow for expansion/contraction. (40 CFR 112.8(d)(3).) HSC 25270.4.5(a) 4030026 Failed to regularly inspect aboveground valves, piping, and appurtenances. (40 CFR 112.8(d)(4).) HSC 25270.4.5(a) 4030030 Failed to conduct integrity and leak test on buried piping at installation, modification, construction, relocation or replacement. (40 CFR 112.8(d)(4).) HSC 25270.4.5(a)
4030031 Failed to adequately warn vehicles entering facility to protect piping and other transfer operations. (40 CFR 112.8(d)(5).) HSC 25270.4.5(a) HM-950 APSA (08-21)

C O U N T Y O F S A N D I E G O

COMPLIANCE INSPECTION REPORT
APSA Program (continued)
INSPECTION DATE: 06/29/2023 PAGE 11 OF 13
RECORD ID #: DEH2011-HUPFP-214305
4010044 Failed to complete and maintain at the facility the Substantial Harm Criteria certification form when owner or operator determines that the facility could not be reasonably expected to cause substantial harm to the environment. (40 CFR 112.20(e).) HSC 25270.4.5(a) 4010029 Failed to adequately discuss in the SPCC Plan all applicable bulk storage containers, including compatibility with material stored and conditions of storage, and description of sized secondary containment capable of containing the largest single container and sufficient freeboard to contain precipitation. 40 CFR 1 112.8(c )(1) & (2); HSC 6.67 25270.4.5 (a) HM-950 APSA (08-21)

C O U N T Y O F S A N D I E G O

COMPLIANCE INSPECTION REPORT
California Accidental Release Prevention (CalARP)
Program 1
INSPECTION DATE: 06/29/2023 PAGE 12 OF 13
RECORD ID #: DEH2011-HUPFP-214305
VIOLATION REPORT: Each violation checked below is for the section(s) of the California Health and Safety Code (HSC), 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) and Title 42 of the United States Code (USC) 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. Administering Agency (AA); process hazard analysis (PHA); process safety information (PSI); emergency response (ER); regulated substance (RS); stationary source (SS); threshold quantity (TQ)

GENERAL APPLICABILITY & COORDINATION
# VIOLATION DESCRIPTION
5010001 Failure to comply with CalARP provisions when having a regulated substance in a process listed in Table 1/2. 19 CCR 4.5 2735.4(a)(1) 5010002 Failure to comply with the appropriate provisions of 19 CCR 4.5 prior to the date in which a regulated substance is first present in a process above the listed threshold quantity, as listed in Table 3 of Section 2770.5. 19 CCR 4.5 2735.4(a)(2) 5010003 Failure to comply with CalARP provisions when having a regulated substance in a process listed in Table 1/2 and 3. 19 CCR 4.5 2735.4(a)(3) 5010004 Failure to closely coordinate with the CUPA to implement the CalARP requirements. 19 CCR 4.5 2735.5(a) 5030005 Failure to identify hazards that may result from releases, design and maintain a safe facility or minimize the consequences of an accidental release. HSC 25531.2(b)
5010006 Failure to ensure response actions are coordinated with local emergency planning and response agencies. 19 CCR 4.5 2735.5(d)(3) 5010120 Failure to coordinate with CUPA to ensure appropriate technical standards are applied to implement CalARP. 19 CCR 4.5 2785.1(a) 5010121 Failure to request assistance from the CUPA when necessary to address compliance/safety issues with CalARP. 19 CCR 4.5 2785.1(b)

RMP COMPONENTS AND SUBMISSION

RMP SUBMISSION
# VIOLATION DESCRIPTION
5010005 Failure to submit an RMP which includes all requirements in Section 2745.3 to 2745.5 and 2745.8 to 2745.9. 19 CCR 4.5 2735.5(b)(1), 2735.5(d), 2745.1(a)
5010016 Failure to submit the RMP information required by the USEPA to the USEPA. 19 CCR 4.5 2745.1(b)(1), 2745.1(b)(2) 5010017 Failure to submit the RMP information required by the USEPA to the CUPA. 19 CCR 4.5 2745.1(c) 5010018 Failure of a stationary source to submit a Risk Management Plan to the CUPA. HSC 6.95 25536(b) 5010019 Failure to submit an RMP to the CUPA prior to the date a RS is in a process above the TQ. 19 CCR 4.5 2745.1(d) 5010020 Failure to exclude classified information from the RMP. 19 CCR 4.5 2745.1(h)

RMP CERTIFICATION
# VIOLATION DESCRIPTION
5010021 Failure to ensure that the RMP is certified complete by a QUALIFIED PERSON and the stationary source owner or operator. 19 CCR 4.5 2745.2(a) 5010023 Failure to submit in the RMP the certification statement provided in Section 2735.5(d)(4).

RMP UPDATES
# VIOLATION DESCRIPTION
5010025 Failure to revise, update, and submit the RMP to the USEPA and CUPA per timelines in Section 2745.10(a). 19 CCR 4.5 2745.10(a) 5010026 Failure to revise, update, and submit the RMP to the CUPA per timelines in Section 2745.10(b). 5010027 Failure to submit a de-registration to the USEPA and CUPA within six months of the regulated substance removal. 19 CCR 4.5 2745.10(c) 5010028 Failure to submit a de-registration to the CUPA within six months of the regulated substance removal. 19 CCR 4.5 2745.10(d) 5010029 Failure to contact the CUPA within 30 days of a change of owner or operator to update the registration. 19 CCR 4.5 2745.10(f)

RMP CORRECTIONS
# VIOLATION DESCRIPTION
5010030 Failure to correct and submit the data required in the RMP under sections 2745.5, 2745.6(j), and 2745.7(1) (New Accident History). 19 CCR 4.5 2745.10.5(a)
5010031 Failure to correct and submit the EMERGENCY CONTACT information in the RMP within one month of any change. 19 CCR 4.5 2745.10.5(b)

COVERED PROCESS MODIFICATION
# VIOLATION DESCRIPTION
5010032 Failure to notify the CUPA in writing of the intent to modify the stationary source at least five calendar days before implementing any modifications or no later than 48 hours following the modification if prenotification is not reasonable. 19 CCR 4.5 2745.11(a)(1) 5010033 Failure to establish procedures to manage the proposed modification, which shall be substantially similar to the procedures specified in Sections 2760.6 and 2760.7, and notify the CUPA that the procedures have been established. 19 CCR 4.5 2745.11(a)(2) 5010262 Failure to revise documents as required pursuant to section 2745.11(a) at a modified stationary source. 19 CCR 4.5 2645.11(b)

CERTIFICATE OF OCCUPANCY
# VIOLATION DESCRIPTION
5010034 Failure to comply with Government Code Section 65850.2(b) prior to issuance of a certificate of occupancy. 19 CCR 4.5 2745.12

RMP REVIEW
# VIOLATION DESCRIPTION
5010022 Failure to correct deficiencies within 60 calendar days from receipt of the notification of RMP deficiencies. 19 CCR 4.5 2745.2(b)(1)

REGISTRATION
# VIOLATION DESCRIPTION
5010008 Failure to include a registration in the RMP that reflects all covered processes. 19 CCR 4.5 2735.5(b)(2) 5010012 Failure to complete the registration information and submit it with the RMP to the USEPA and the CUPA. 19 CCR 4.5 2740.1(a) 5010013 Failure to complete the REGISTRATION information and submit it with the RMP to the CUPA.

HM-972 CalARP (08-21)

C O U N T Y O F S A N D I E G O

COMPLIANCE INSPECTION REPORT
CalARP Program 1 (continued)
INSPECTION DATE: 06/29/2023 PAGE 13 OF 13
RECORD ID #: DEH2011-HUPFP-214305
5010014 Failure to submit a registration with a certification of accuracy to the CUPA prior to submittal of the RMP. 19 CCR 4.5 2740.1(c) 5010015 Failure to include the data required in Section 2740.1(d)(1) through (d)(20) in the registration. 19 CCR 4.5 2740.1(d)

HAZARD ASSESSMENT
# VIOLATION DESCRIPTION
5010035 Failure to prepare a worst-case release scenario analysis as provided in Section 2750.3. 19 CCR 4.5 2750.1 5010036 Failure to complete the five-year accident history as provided in Section 2750.9. 19 CCR 4.5 2750.1

RECORDKEEPING
# VIOLATION DESCRIPTION
5010119 Failure to maintain records supporting the implementation of CalARP for five years unless otherwise provided. 19 CCR 4.5 2775.1 HM-972 CalARP (08-21)
HM-924(01/15)

COUNTY OF SAN DIEGO

COMPLIANCE INSPECTION REPORT
FACILITY NAME: CHULA VISTA ENERGY CENTER, LLC
ADDRESS: 3497 MAIN ST
CITY/ZIP: CHULA VISTA /91911
INSPECTION DATE: 06/29/2023 PAGE 1 OF 13
RECORD ID #: DEH2011-HUPFP-214305
TIME START: 8:00 AM END: 12:30 PM
SPECIALIST: Manon Maschue
INSPECTION CONTACT:Susanna Miramontes
TITLE: EH&S Specialist
PHONE:(619) 579-9002
E-MAIL:[email protected]
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. ✖ Unified Program Facility Permit Current
✖ Hazardous Materials Business Plan Available
✖ Employee Training is Adequate
✖ Waste Disposal Records Available for Review
✖ Emergency Contacts Current Updated today
Chemical Inventory/Map Current Updated today
✖ Contingency Plan Available LQG SQG✖
✖ Employee Training Records Available
✖ Universal Waste Managed Properly
✖ Waste Containers Closed✖ Labeled✖
✖ Waste Containers in Good Condition
Permit Expires On 08/31/2023
CONSENT TO CONDUCT INSPECTION GRANTED BY: Susanna Miramontes TITLE: EH&S Specialist INTRODUCTION:

Routine Inspection

The County of San Diego Hazardous Materials Division (HMD) is a division of the Department of Environmental Health & Quality (DEHQ). DEHQ is the Certified Unified Program Agency (CUPA) for the County of San Diego. A routine CUPA facility inspection was conducted 6/29/2023 with Susana Miramontes, EH&S Specialist and Ty Cheesbrough of Wellhead Services. Belinda Velediaz, EHS III with DEHQ, participated in the inspection. Consent to inspect, sample and photograph as needed was obtained from Susana Miramontes. The inspection was conducted to assess compliance with the following Unified Program elements:

• Hazardous Materials Chemical Inventory & Business Plan (HMBP) (HSC Div 20 Ch 6.95 Art 1 & 19 CCR Div 2 Ch 4) • Aboveground Petroleum Storage Act (APSA) (CA HSC Ch 6.67 and 40 CFR Sec 112 - SPCC Plan) • Hazardous Waste Management (HSC Div 20 Ch 6.5 & 22 CCR Div 4.5 Ch 10) • California Accidental Release Prevention Program (CalARP) (HSC Div 20 Ch 6.95 Art 2 & 19 CCR Div 2 Ch 4.5)

The Chula Vista Energy Center (CVEC) is a 35 megawatt (nominal) natural gas-fired power plant that is typically not staffed.

Typically the plant runs less than 100 hours per year. The plant is operated at this time by Wellhead Services. CVEC uses 19% aqueous ammonia for reducing air pollution (oxides of nitrogen (NOx)) produced from generating electricity. The process of NOx reduction is called selective catalytic reduction (SCR). SCR is a permitted air pollution control system.

INSPECTION REMARKS:

Hazardous Materials Business Plan (HMBP) Remarks:

CERS ID: 10359508

The most recent HMBP/CERS submittal was made on 7/5/2023 for the following elements:
• Facility Information (Owner Operator & Business Activities) • Chemical Inventory & Site Map
• APSA Element

This submittal included minor technical edits to the site map including having all of the labels face the same direction as provided in the CUPA's sit map instructions.

The last submittal for the "Plans" CERS element was made on 5/26/2023.

HM-924(01/15)

COUNTY OF SAN DIEGO

SUPPLEMENTAL COMPLIANCE

INSPECTION REPORT
INSPECTION DATE: 06/29/2023 PAGE 2 OF 13
RECORD ID #: DEH2011-HUPFP-214305

Remember to review and resubmit the following three required CERS elements at least annually even if there are no changes:
• Facility Information (Owner Operator & Business Activities) • Chemical Inventory & Site Map
• Plans Element (Emergency Response and Training Plans)

Training for HMBP including HAZCOM, Release Reporting, RMP and SPCC was last conducted 5/4/2023. The training program includes IIPP, PPE, Fire Prevention/Action Plan, Contractor & Visitor Control, HMBP and First Responder Awareness, among others.

Incompatible Chemical Storage Corrected during the inspection:
o One half gallon bottle of sodium hypochlorite (5%) (household bleach) was observed inside the flammable cabinet and was removed to safer storage during the inspection.

Fire System Suppression Chemicals exempted from Chemical Inventory Reporting:
o There is on site compressed Nitrogen used for fire fighting. It provides pressure to sprinklers. This fire suppression system is not in CERS due to a local exemption.
o FM200 is used for fire suppression for the control room. This is also not reported in CERS due to fire suppression system exemption.
o No CO2 observed on site during this inspection.

*****

APSA/SPCC Remarks:

Chula Vista Energy Center has a Federal SPCC plan on site describing over 5,500 gallons of petroleum stored mostly in oil-filled electrical equipment, most of which are exempt from APSA-regulation by definition in HSC 25270.2.

"Aboveground storage tank" in the California APSA regulation does not include oil-filled electrical equipment, including, but not limited to, transformers, circuit breakers, or capacitors, when the equipment contains less than 10,000 gallons of dielectric fluid, is in secondary containment and is inspected routinely. There are other exclusions in the law, but this is the one that applies for this facility.

At this time, based on observations made at the facility and discussions with Ty Cheesebrough and Susana Miramontes, this facility stores, at the most, about 1,128 gallons of petroleum which is subject to APSA. Included in the 1,128 gallons, there is on site one 750 gallon Tank in and Underground Area (TIUGA). Due to the existence of this TIUGA, Chula Vista Energy Center is subject to APSA.

An APSA CERS submittal was made during this inspection on 7/5/2023.

Training/Spill Prevention briefings are conducted and documented. Last SPCC Training was conducted 5/4/2023.

The SPCC is P.E. Certified. The SPCC Plan was last reviewed for changes 5/11/2021.

*****

Hazardous Waste Management Remarks:

CalEPA ID CAL 000 346 986

Based on a visit to the facility, discussions with Susanna Miramontes and a review of the hazardous waste manifests for the last three years, this facility appears to be, at this time, a small quantity generator (SQG) of hazardous wastes.

HM-924(01/15)

COUNTY OF SAN DIEGO

SUPPLEMENTAL COMPLIANCE

INSPECTION REPORT
INSPECTION DATE: 06/29/2023 PAGE 3 OF 13
RECORD ID #: DEH2011-HUPFP-214305
Hazardous wastes routinely generated on site include: oily absorbent, oily water, used oil filters and universal wastes (in small quantities). Universal wastes are consolidated at the El Cajon facility.

There are also non-hazardous waste manifests for oily water (<10% oil) which is generated from the "wash down tank." Spill kits were observed on site today.

Hazardous Waste Management Training was last conducted 3/8/2022.

*****

CalARP Remarks:

Covered Process & Program: The facility stores 10,200 gallons of aqueous ammonia in a 12,000 gallon tank. Tank is said to be maximum 85% full. The ammonia is reported as 19% concentration.

Aqueous ammonia is used at this facility in an air pollution control application known as selective catalytic reduction (SCR).

CVEC has submitted a Program 1 RMP for this process. The Off-site Consequences Analysis (OCA) uses the program SCREEN3 which describes a toxic endpoint traveling to 12 feet. This end point distance considers that the ammonia will "instantaneously" flow beneath the covered containment. Two long "slat" openings and an estimated "greatly reduced evaporation rate" from being below the covered containment were considered in the Off-site Consequences Analysis (OCA). The area of concern keeps the plume of ammonia on the CVEC property according to the worst case scenario they submitted to the CUPA. The Hazard Assessment indicates there will be no off-site impacts from a worst case release of all contents of the ammonium hydroxide tank.

Be advised that the CUPA is reviewing the OCA for all Program 1 Facilities to verify facilities fall into the correct program level. A request to revisit the worst-case OCA will come in writing.

***
RMP Submittal: Chula Vista Energy Center (CVEC) submitted a Program 1 RMP update to the CUPA dated 10/2019.

***
RMP Certification Statement: This RMP contains the proper certification statement found in 19 CCR Section 2735.5(d)(4).

***
RMP Updates: Every 5 years this facility is required to submit an RMP Update to the CUPA to include an updated Hazard Assessment and 5-year accident history.

At this time, CalARP-specific information is not submitted through CERS. When changes in personnel occur that affect the CalARP Program, submit any CalARP responsible party, CalARP Qualified Person, certification or other modifications in writing within 30 days from the change directly to the CUPA (using mail, courier or e-mail), not through CERS.

***
Five (5)-year Accident History & Incident Investigations: There have been no releases of ammonia in the last 5-years per statements by Susanna Miramontes.

***
HM-924(01/15)

COUNTY OF SAN DIEGO

SUPPLEMENTAL COMPLIANCE

INSPECTION REPORT
INSPECTION DATE: 06/29/2023 PAGE 4 OF 13
RECORD ID #: DEH2011-HUPFP-214305
Emergency Response: CVEC is a non-responding CalARP facility. Per statements from Susanna Miramontes and Ty Cheesbrough, in the event of an ammonia release, staff will size-up, isolate and deny entry and call for a response from local FD and a clean up contractor if needed.

Safety equipment such as emergency eyewash/showers were working and well-identified today. The ammonia tank sits inside a properly sized secondary containment. The ammonia tank fill area is contained in a secondary containment. Delivery's of ammonia are witnessed and verified by facility staff. Process piping has labels which indicate the name of the contained material and flow direction of the contained material.

A windsock was visible during the inspection.

***
General Duty Clause: Be advised that the CUPA regulates California Health and Safety Code 25531.2. (b) which states:
...Owners and operators of stationary sources producing, processing, handling, or storing hazardous materials have a general duty, in the same manner and to the same extent as is required by Section 654 of Title 29 of the United States Code, to identify hazards that may result from releases using appropriate hazard assessment techniques, to design and maintain a safe facility taking those steps as are necessary to prevent releases, and to minimize the consequences of accidental releases that do occur.

29 U.S.C. § 654, 5(a)1, (the "General Duty Clause") requires the following: “Each employer shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees."

**********

This report was reviwed with the Facility Contact below and was submitted into eForms unsigned on 7/7/2023.

A copy of the signed report was requested and, when received, will be submitted to Acella.

**********

DIRECT QUESTIONS AND/OR CORRESPONDENCE REGARDING THIS REPORT TO:

Manon Maschue, REHS, EHS III
County of San Diego, DEHQ, Hazardous Materials Division PO Box 129261
San Diego, CA 92112-9261
858-518-7390 | [email protected]

**********

Helpful Websites:
• For guidance documents on hazardous materials-related topics, go to: https://www.sandiegocounty.gov/content/sdc/deh/hazmat/hmd_publications.html • For information on the California Environmental Reporting System (CERS), go to: https://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: https://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 HM-924(01/15)

COUNTY OF SAN DIEGO

SUPPLEMENTAL COMPLIANCE

INSPECTION REPORT
INSPECTION DATE: 06/29/2023 PAGE 5 OF 13
RECORD ID #: DEH2011-HUPFP-214305
If you have any questions regarding this inspection, please contact , Manon Maschue , 858.518.7390 [email protected]

INSPECTION PHOTOS
None

INSPECTION ATTACHMENTS
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:
https://www.sandiegocounty.gov/deh/hazmat/hmd_cers.html

PRINTED NAME OF FACILITY REPRESENTATIVE
Susanna Miramontes

TITLE OF FACILITY REPRESENTATIVE
EH&S Specialist

SIGNATURE
Signature Not Obtained

DATE SIGNED
Department of Environmental Health and Quality, Hazardous Materials Division, P.O. Box 129261, San Diego, CA 92112-9261 Phone: (858) 505-6880 http://www.sdcdehq.org

C O U N T Y O F S A N D I E G O

COMPLIANCE INSPECTION REPORT
Handlers of Hazardous Materials and Small and Large
Quantity Generators of Hazardous Waste
INSPECTION DATE: 06/29/2023 PAGE 6 OF 13
RECORD ID #: DEH2011-HUPFP-214305
FACILITY NAME: *CHULA VISTA ENERGY CENTER, LLC
ADDRESS: * 3497 MAIN ST CITY/ZIP: *CHULA VISTA 91911
Each violation checked below is for the section(s) of the California Health and Safety Code (HSC), 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

HAZARDOUS MATERIALS REQUIREMENTS
# VIOLATION DESCRIPTION
1010001 Failed to establish and implement a HMBP. HSC 25505(a) and 25507(a) 1010002 HMBP not submitted in CERS within the required timeframe. HSC 25508(a)(1); 27 CCR 15188(a),(b),(d) 1010003 Business activities &/or Business Owner/Operator page not complete or accurate in CERS. 19 CCR 2652(a)(1); SDCC 68.904(b); HSC 25508(a)(1), 25508(a) (3)
1010004 Chemical inventory incomplete or not submitted in CERS. HSC 25505(a)(1); 25507(a); 25508.1(a-b); 19 CCR 2654 (a) or (d) 1010005 Site map not submitted in CERS or not sufficient. HSC 25505(a)(2); 25508.1(f); 19 CCR 2652(a)(3) 1010006 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 25508.1(a-f); 19 CCR 2654(d); SDCC 68.904(c)(6)
1010008 HMBP not certified as complete and accurate in CERS by the required due date. HSC 25508.2, 19 CCR 2654(b) 1010010 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)(1), 25508(a)(3); 19 CCR 2658
1010011 Failure to notify property owner in writing that the business is subject to the HMBP program. HSC 25505.1 1010012 Failure to provide a copy of HMBP to the property owner within five working days upon request from property owner. HSC 25505.1 1010014 Failure to submit emergency response plan in CERS, when not meeting agricultural handler exemption. HSC 25507.1(a) and 25508(a)(1); 19 CCR 2670, 2671
1010015 Failure to submit employee training plan in CERS, when not meeting agricultural handler exemption. HSC 25507.1(a), 25508(a)(1), 19 CCR 2670, 2671 1010016 HMBP not established or submitted in CERS, when not meeting the remote site exemption. HSC 25507.2 and 25508(a)(1) 1020001 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)(1), 25508(a)(3); 19 CCR 2659(a) 1030001 (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 25507.1(a)(2); 19 CCR 2670, 2671 1020002 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) 1040001 Hazardous materials release or threatened release not immediately reported to the CUPA and OES upon discovery. HSC 25510(a); 19 CCR 2631(a) HMD1001 Unified Program Facility permit not obtained for hazardous materials. SDCC 68.904; 68.905; 68.906, 68.907; 68.907.1 HMD1005 Emergency contact not provided or current in CERS. HSC 25508.1(f); SDCC 68.904(b) HMD1007 Highly toxic gas (TLV<10 ppm) not disclosed in CERS. SDCC 68.1113(a) 1010017 HMBP not readily available to facility personnel or the CUPA. HSC 25505(c)

HAZARDOUS WASTE REQUIREMENTS FOR SQGS ONLY
# VIOLATION DESCRIPTION
HMD0226 Did not accumulate waste in a container or tank. 22 CCR 66262.34(d)(2); 40 CFR 262.34(d)(2) 3030007 Failed to properly label/date hazardous waste container &/or tank. 22 CCR 66262.34(f) 3030010 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)(1)
3030013 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 3030015 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 3030017 Failed to properly close hazardous waste container(s). 22 CCR 66262.34(d)(2); 40 CFR 262.34(d)(2), 265.173 3030019 Failed to inspect hazardous waste storage area at least weekly. 22 CCR 66262.34(d)(2); 40 CFR 262.34(d)(2), 265.174 3030022 Failed to properly separate incompatible waste. 22 CCR 66262.34(d)(2); 40 CFR 262.34(d)(2), 265.177 3030030 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 3030036 Failed to maintain adequate aisle space. 22 CCR 66262.34(d)(2); 40 CFR 262.34(d)(4), 265.35 3010022 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)
3020001 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) 3030032 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 3030039 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) HMD0412 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)
3010030 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
HM-923 (08-21)

C O U N T Y O F S A N D I E G O

COMPLIANCE INSPECTION REPORT
Hazardous Materials and Hazardous Waste (continued)
INSPECTION DATE: 06/29/2023 PAGE 7 OF 13
RECORD ID #: DEH2011-HUPFP-214305
3030024 Failed to operate uncovered tank to ensure at least 2 ft. of freeboard 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)
3030025 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) 3030027 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)
3030028 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) 3050007 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)
HMD1612 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) HMD1614 Failed to pre-notify the CUPA in writing prior to closing a hazardous waste tank system. 22 CCR 67383.3(a)(1) HMD1615 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 LQGS

RECORD KEEPING/OPERATIONAL REQUIREMENTS
# VIOLATION DESCRIPTION
HMD0131 Unified Program Facility Permit not obtained &/or maintained for the generation of hazardous waste. SDCC 68.904; 68.905; 68.907.1 HMD0150 Failed to submit complete and accurate Facility Information in CERS. 27 CCR 15188(b-c); SDCC 68.904(b) 3030053 Failed to maintain waste analysis records, analytical records &/or waste determination results for at least 3 years. 22 CCR 66262.40(c) 3010002 Failed to obtain &/or maintain an active EPA ID Number. 22 CCR 66262.12(a) 3010008 Failed to properly complete a uniform hazardous waste manifest. 22 CCR 66262.23(a) 3010009 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) 3010010 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)
3010011 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)(1)(c)
3010013 Failed to meet the consolidated manifesting requirements for waste shipment. HSC 25160.2(b)(3) &/or (c) 3010014 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) 3030006 Failed to determine if a hazardous waste is restricted or prohibited from land disposal and has to be treated. 22 CCR 66268.7(a)(1) 3010016 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 25143.10(a), (c) &/or (d) HMD0149 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) HMD0152 Failed to report &/or update the required inventory information for hazardous waste(s) generated at the facility in CERS. SDCC 68.904(a)(2) HMD0140 Failed to have Land Disposal Restriction documentation onsite for 3 years. 22 CCR 66268.7(a)(8) 3250005 Failed to obtain a Treatment, Storage and Disposal Facility (TSDF) permit or authorization to store/treat/dispose of hazardous waste. HSC 25201(a) 3050005 Failed to properly manage a recyclable material. HSC 25143.2, 25143.9 HMD0142 Failed to notify the CUPA in CERS for onsite hazardous waste treatment/tiered permitting. HSC 25201(a) HMD0138 Manifest signed by the TSDF not available for inspection. 22 CCR 66262.40(a); HSC 25185(a)(4) 3010035 Failure to annually submit notification of generator's intent to remotely consolidate hazardous waste. HSC 25110.10(d) 3010037 Failure to notify the CUPA of aerosol can processing procedures prior to commencement of operations. HSC 25201.16(j)

DISPOSAL AND TRANSPORTATION
# VIOLATION DESCRIPTION
3010007 Failed to prepare a hazardous waste manifest for the transport of a waste for off-site transfer, treatment, storage, or disposal. HSC 25160(b)(1) or (2), 25160.2(b)(9); 22 CCR 66262.20(a)
3030005 Failed to make a proper waste determination. 22 CCR 66262.11, 66262.40(c) 3050001 Failed to use a DTSC registered hazardous waste transporter to transport hazardous waste. HSC 25163(a) 3050002 Failed to properly dispose of hazardous waste at an authorized facility. HSC 25189.5(a) HMD0308 Impermissible dilution of hazardous waste. 22 CCR 66268.3(a) HMD0305 Disposed of used oil illegally. HSC 25250.5(a), 25189.5(a) HMD0306 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
3030001 Failed to meet the management requirements when handling or storing spent lead-acid batteries. 22 CCR 66266.81(a) 3030003 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)
3030012 (RCRA LQG) Failed to properly dispose of hazardous waste within 90 days. 22 CCR 66262.34(a), (c); HSC 6.5 25123.3(b)(1) 3030004 Failure to properly manage used oil filters and/or fuel filters in accordance with the requirements. HSC 25250.22; 22 CCR 66266.130 3050004 Failure to prevent intentional contamination of used oil with other hazardous waste other than minimal amounts of vehicle fuel. HSC 25250.7(a) HMD0222 Failed to properly label Excluded Recyclable Materials (ERM) accumulated in a container or tank. HSC 25143.9(a) HMD0216 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)
HMD0217 Failed to repackage and properly label damaged/deteriorated hazardous material container within 96 hours. HSC 25124(b)(3)(B); 22 CCR 66262.34(f) HMD0219 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)

C O U N T Y O F S A N D I E G O

COMPLIANCE INSPECTION REPORT
Hazardous Materials and Hazardous Waste (continued)
INSPECTION DATE: 06/29/2023 PAGE 8 OF 13
RECORD ID #: DEH2011-HUPFP-214305
3030057 Failed to comply with hazardous waste satellite container regulation. 22 CCR 66262.34(e) 3030058 Failed to mark date on empty container larger than 5 gallons &/or properly manage it within one year. 22 CCR 66261.7 3030060 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 25200.3.1(b) and/or (c)

UNIVERSAL WASTE HANDLER REQUIREMENTS
# VIOLATION DESCRIPTION
3010004 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)
HMD0151 Failed to maintain universal waste handler training records for 3 years. 22 CCR 66273.36(c),(d) 3020003 Failed to properly train handlers of universal waste in universal waste management and response procedures. 22 CCR 66273.36(a),(b) 3030008 Failed to properly label or mark Universal Waste container, package, or pallet (excluding CESQUWG) 22 CCR 66273.34 3030011 Failed to properly dispose of Universal Waste within one year. 22 CCR 66273.35(a) &/or (b) HMD0147 Failed to keep records of offsite Universal Waste shipment(s) available for inspection for 3 years. 22 CCR 66273.39(c),(d)(2) 3030051 Failed to meet accumulation, labeling, marking, &/or containment standards for Universal Waste aerosol containers. HSC 25201.16(f) 3040004 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 HMD0307 Disposal of universal waste (UW) to an unauthorized point. HSC 25189.5(a); 22 CCR 66273.31(a), 66273.8(b) 3010005 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)
3010020 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)
3010006 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)
3110030 Failed to notify the CUPA of aerosol processing procedures prior to commencement of operations. HSC 25201.16(j)

CERTIFIED APPLIANCE RECYCLER REQUIREMENTS
# VIOLATION DESCRIPTION
3010033 Failure to obtain Certified Appliance Recycler certification (CAR) from DTSC. HSC 25211.4 3010034 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
3030055 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)

C O U N T Y O F S A N D I E G O

COMPLIANCE INSPECTION REPORT
Aboveground Petroleum Storage Act (APSA) Program
INSPECTION DATE: 06/29/2023 PAGE 9 OF 13
RECORD ID #: DEH2011-HUPFP-214305
Each violation checked below is for the section(s) of the California Health and Safety Code (HSC), California Code of Regulations (CCR), or 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 a DEH Corrective Action Form (HM-926) or other correspondence to document your return to compliance. Please call (858) 505-6880 or your Specialist if you have any questions.

GENERAL APSA FACILITY REQUIREMENT
(CHAPTER 6.67 OF DIVISION 20 OF THE HSC & SDCC)
# VIOLATION DESCRIPTION
4010001 Failed to prepare a Spill Prevention, Control, and Countermeasures (SPCC) Plan. HSC 25270.4.5(a), 40 CFR 112.3, 112.6 4030038 Failed to implement the SPCC Plan. HSC 25270.4.5(a), 40 CFR 112.3, 112.6 4010032 Failed to submit a tank facility statement or update/certify Business Plan annually. HSC 25270.6(a)(1) or (a)(2) 4010033 Failed to pay the APSA program fee or obtain Unified Program Facility Permit. HSC 25270.6(b), SDCC 68.904; 68.905; 68.907.1 4040001 Failed to immediately, upon discovery, report a one-barrel (42 gallons) or greater release of petroleum to Cal OES and the CUPA . HSC 25270.8 4010037 Failed to meet conditions of APSA exemption for oil-filled electrical equipment including containment and visual inspection. HSC 25270.2(a)(4), 25270.4.5(a)
4030043 Failed to have secondary containment and leak detection if piping connected to tank in an underground area (TIUGA) cannot be directly viewed on all sides. (Refer to HSC 6.67 for direct viewing; DOES NOT apply to: 1. Piping connected to a tank that contains new oil/used oil for lubricant or coolant in a motor engine or transmission, or oil-filled operational/manufacturing equipment. 2. Piping connected to a tank used solely in connection with a fire pump or emergency system, legally required by standby system, or optional standby system. 3. Piping connected to a petroleum hazardous waste tank that complies with hazardous waste tank standards (22 CCR Ch. 15, Art. 10) and facility has been issued a unified program facility permit pursuant to HSC 25404.2 for generation, treatment, accumulation, or storage of hazardous waste.) (24CCR Title 9 Section 5703.6.2.2.) HSC 25270.4.5(a), HSC 25270.2(o)(1)(C)(iv)
4030044 Failure of an owner/operator of an excluded tank in an underground area (TIUGA) with less than 55-gallon capacity to have secondary containment, conduct monthly inspections, and/or maintain a log of inspections. HSC 6.67 25270.2(a)(8) HMD5104 Failed to submit, and keep up to date, the APSA program element in CERS. SDCC 68.904; 27 CCR 15188(a),(b),(c),&(f) REQUIREMENTS BASED ON 40 CFR 112.1-112.6
# VIOLATION DESCRIPTION
4010035 Failed to prepare an appropriate SPCC Plan within 6 months when the facility no longer meets the Tier I or Tier II qualified criteria. 40 CFR 112.6(a)(2), 112.6(b)(2); HSC 6.67 25270.4.5 (a)
4010047 (Qualified Facility only- Tier I or II) Failed to have management, or a Professional Engineer if applicable, certify the SPCC Plan and comply with the certification requirements. (40 CFR 112.6(a)(1), 112.6(b).) HSC 25270.4.5(a) 4010048 (Qualified Facility only- Tier I) Failed to certify the SPCC Plan according to 40 CFR 112.6(a)(1) if a technical change has been made to the facility design, construction, operation, or maintenance. (40 CFR 112.6(a)(2).) HSC 25270.4.5(a) 4010052 (Qualified Facility only- Tier II) Failed to have technical amendment(s) certified by management, or a Professional Engineer if applicable. (40 CFR 112.6(b) (2), 112.6(b)(2)(i).) HSC 25270.4.5(a)
4010054 (Qualified Facility only- Tier I) Failed to include in the SPCC Plan a prediction of direction and total quantity of oil potentially discharged from the facility as a result of each type of major equipment failure. (40 CFR 112.6(a)(3)(i).) HSC 25270.4.5(a) 4030041 (Qualified Facility only- Tier I) Failed to provide bulk storage containers/tanks with adequate sized secondary containment to contain the capacity of the largest container plus freeboard for precipitation; failed to position/locate mobile or portable containers to prevent a discharge. (40 CFR 112.6(a) (3)(ii).) HSC 25270.4.5(a)
4030042 (Qualified Facility only- Tier I) Failed to provide systems or follow procedures to prevent overfills as described in the SPCC Plan; failed to routinely test overfill equipment to ensure proper operation. (40 CFR 112.6(a)(3)(iii).) HSC 25270.4.5(a) 4010003 Failed to have a Professional Engineer certify and review the SPCC Plan. (40 CFR 112.3(d).) HSC 25270.4.5(a) 4010008 Failed to maintain a complete copy of the SPCC Plan at the facility if the facility is normally attended at least four hours per day, or at the nearest field office if the facility is not so attended. (40 CFR 112.3(e)(1).) HSC 25270.4.5(a) 4010010 Failed to make SPCC Plan technical amendment(s) within six months when the facility has had a change in design, construction, operation, or maintenance which affects the facility's discharge potential; failed to implement within six months following preparation of the amendment. (40 CFR 112.5(a), 112.5(b).) HSC 25270.4.5(a)
4010009 Failed to perform and properly document a five-year review of the SPCC Plan. (40 CFR 112.5(b).) HSC 25270.4.5(a) 4010039 Failed to have technical amendments certified by a licensed Professional Engineer. (40 CFR 112.5(c).) HSC 25270.4.5(a)

GENERAL SPCC REQUIREMENTS
BASED UPON 40 CFR 112.7
# VIOLATION DESCRIPTION
4010012 Failed to prepare a written SPCC Plan in accordance with good engineering practices and any applicable more stringent State rules, regulations, and guidelines; failed to prepare a SPCC Plan that follows the sequence of rule or provides a cross-reference; failed to prepare a SPCC Plan that addresses additional procedures/methods/equipment not fully operational; failed to obtain facility management approval for implementation of the SPCC Plan . (40 CFR 112.7 and 112.7(a)(1).) HSC 25270.4.5(a) 4010014 Failed to include alternative environmental protection to SPCC requirements within SPCC Plan. (40 CFR 112.7(a)(2).) HSC 25270.4.5(a) 4010015 Failed to include in the SPCC Plan an adequate facility diagram, or no facility diagram included. The facility diagram is not required for a Tier I Qualified Facility. (40 CFR 112.7(a)(3).) HSC 25270.4.5(a)
4010016 Failed to adequately describe in the SPCC Plan the physical layout of facility, types of oil and storage capacities, tanks, containers, equipment, mobile refuelers, portable containers, transfer operations, and other required information. (40 CFR 112.7(a)(3), 112.7(a)(3)(i-vi).) HSC 25270.4.5(a) 4010017 Plan does not contain procedures for reporting a discharge, and/or a contact list and phone numbers for the facility response coordinator, National Response Center, cleanup contractors with an agreement for response, and all appropriate Federal, State, and local agencies. (40 CFR 112.7(a)(4).) HSC 25270.4.5(a)
4010018 Discharge response procedures are not adequately organized to be readily accessible in an emergency. (40 CFR 112.7(a)(5).) HSC 25270.4.5(a) 4010019 Failed to include in the SPCC Plan a prediction of the direction, rate of flow, and total quantity of oil that could be discharged for each type of major equipment failure where experience indicates a reasonable potential for equipment failure. (40 CFR 112.7(b).) HSC 25270.4.5(a) 4010020 (General Containment) Failed to provide, or include in the SPCC Plan, the appropriate containment, diversionary structures, or equipment to prevent a discharge that will not escape containment before cleanup occurs, including typical failure mode and most likely quantity of discharge. (40 CFR 112.7(c).) HSC 25270.4.5(a)
4010004 Failed to clearly explain why appropriate containment/diversionary structures are not practicable and/or SPCC Plan claiming impracticability is not certified by a licensed Professional Engineer. (40 CFR 112.7(d).) HSC 25270.4.5(a) HM-950 APSA (08-21)

C O U N T Y O F S A N D I E G O

COMPLIANCE INSPECTION REPORT
APSA Program (continued)
INSPECTION DATE: 06/29/2023 PAGE 10 OF 13
RECORD ID #: DEH2011-HUPFP-214305
4010005 Failed to prepare an Oil Spill Contingency Plan following the provisions of 40 CFR Part 109 for impracticability claim. (40 CFR 112.7(d)(1).) HSC 25270.4.5(a)
4010006 Failed to provide a written commitment of manpower, equipment, materials when claiming impracticability. (40 CFR 112.7(d)(2).) HSC 25270.4.5(a) 4010021 Failed to have record of inspections and integrity tests signed by the appropriate supervisor or inspector, keep written procedures and records of inspections and integrity tests for at least three years, and/or keep comparison records for bulk storage containers subject to 40 CFR 112.8(c)(6). (40 CFR 112.7(e), 112.8(c)(6).) HSC 25270.4.5(a)
4020002 Failure to conduct spill prevention briefing for oil-handling personnel at least once a year to assure adequate understanding of the SPCC Plan, including:

1. Known discharges or failures, 2. Malfunctioning components, 3. Any recently developed precautionary measures. 40 CFR 1 112.7(f)(3); HSC 6.67 25270.4.5(a)
4020001 Failed to train oil-handling personnel on: operation/maintenance of equipment to prevent discharges; discharge procedure protocols; applicable laws, rules, and regulations; general facility operations; and the contents of the SPCC Plan. (40 CFR 112.7(f)(1).) HSC 25270.4.5(a) 4010022 Failed to designate person accountable for discharge prevention who reports to facility management. (40 CFR 112.7(f)(2).) HSC 25270.4.5(a) 4010023 Failure to include in the SPCC Plan an adequate description of employee training. 40 CFR 1 112.7(f)(1), 40 CR 1 112.7(f)(3), HSC 6.67 25270.4.5(a) 4030001 Failed to address security and access control of the oil handling, processing, and storage areas to both prevent acts of vandalism and assist in discovery of discharges. (40 CFR 112.7(g).) HSC 25270.4.5(a)
4030002 (For loading/unloading racks) Failure of the secondary containment, and/or rack drainage to flow to a catchment basin, treatment system, or quick drainage system, and hold at least the maximum capacity of the largest single compartment of any tank car or tank truck. (40 CFR 112.7(h)(1).) HSC 25270.4.5(a)
4030003 (For loading/unloading racks) Failed to provide an interlocked warning light or physical barriers, warning signs, wheel chocks, or vehicle brake interlock system in the area adjacent to the loading/unloading rack to prevent vehicles from departing before complete disconnection of transfer lines. (40 CFR 112.7(h)(2).) HSC 25270.4.5(a)
4030016 Failed to evaluate field-constructed storage tank for brittle fracture or other catastrophe and take appropriate action. (40 CFR 112.7(i).) HSC 25270.4.5(a 4010013 Failure to discuss in the SPCC Plan conformance with SPCC requirements and other effective discharge prevention and containment procedures or any more stringent State rules, regulations and guidelines. (HSC 6.67 25270.4.5(a); 40 CFR 112.7(a)(1), 112.7(j)) 4030034 (For oil-filled operational equipment) Failed to provide general secondary containment or fulfill alternative requirements to general secondary containment. (40 CFR 112.7(k).) HSC 25270.4.5.(a)
SPCC REQUIREMENTS BASED UPON 40 CFR 112.8 & 112.20
REFER TO APSA (HSC CHAPTER 6.67) FOR DEFINITION OF "STORAGE TANK" # VIOLATION DESCRIPTION
4010027 Failed to restrain drainage from diked storage areas by valve(s) or manually activated pump/ejector to prevent discharge. (40 CFR 112.8(b)(1).) HSC 25270.4.5(a)
4030005 Failed to use valves of manual, open-and-closed design, for drainage of diked areas. (40 CFR 112.8(b)(2).) HSC 25270.4.5(a) 4030008 Facility drainage system from undiked areas not designed/equipped to retain oil or return oil to facility and/or failed to ensure catchment basin is not in an area subject to flooding. (40 CFR 112.8(b)(3), 112.8(b)(4).) HSC 25270.4.5(a) 4030009 Failed to provide at least two lift pumps and permanently install at least one pump where drainage waters are treated in more than one treatment unit and such treatment is continuous, and pump transfer is needed. (40 CFR 112.8(b)(5).) HSC 25270.4.5(a) 4030012 Storage tanks not compatible with materials stored or conditions of storage. (40 CFR 112.8(c)(1).) HSC 25270.4.5(a) 4030010 (Sized Containment) Secondary containment not sized to contain the entire capacity of the largest single storage tank plus freeboard for precipitation. (40 CFR 112.8(c)(2).) HSC 25270.4.5(a)
4030013 Failure to ensure diked areas are sufficiently impervious to contain discharged oil. (40 CFR 112.8(c)(2).) HSC 25270.4.5(a) 4030006 Failed to ensure all of the following before allowing drainage of uncontaminated rainwater from diked area: keep bypass valve normally sealed closed, inspect the retained rainwater, and open then reseal bypass valves under responsible supervision. (40 CFR 112.8(c)(3).) HSC 25270.4.5(a) 4010026 Failed to maintain adequate records (or NPDES permit records) of drainage from diked areas. (40 CFR 112.8(c)(3)(iv).) HSC 25270.4.5(a) 4030017 Failed to provide corrosion protection for partially buried storage tanks. (40 CFR 112.8(c)(5).) HSC 25270.4.5(a) 4030015 Failed to test or inspect each aboveground tank or container for integrity on a regular schedule and after material repairs. (40 CFR 112.7(e), 112.8(c)(6).) HSC 25270.4.5(a)
4030014 Failed to ensure tanks are inspected and tested by an appropriately qualified person in accordance with industry standards. (40 CFR 112.7(e), 112.8(c) (6).) HSC 25270.4.5(a)
4010028 Failed to include in the SPCC Plan procedures to test or inspect each aboveground container for integrity in accordance with industry standards on a regular schedule, after material repairs are made, by qualified personnel; failed to include the frequency and type of testing and inspections based on container size, configuration, and design. (40 CFR 112.8(c)(6).) HSC 25270.4.5(a) 4030018 Failure of steam return/exhaust of internal heating coils, which discharge into an open water course, to be monitored, passed through a settling tank, skimmer, or other separation system. (40 CFR 112.8(c)(7).) HSC25270.4.5(a) 4030019 Failed to engineer or update each container/tank installation in accordance with good engineering practice to avoid discharges and/or failed to provide at least one of the following overfill prevention devices: audible/visual high liquid level alarm, high liquid level pump cutoff devices, audible or code signal communications between tank gauge and pumping station, or fast response system for determining liquid levels, such as computers, telepulse or direct vision gauges. (40 CFR 112.8(c)(8)(i-iv).) HSC 25270.4.5(a) 4030022 Failed to regularly test liquid level sensing devices to ensure proper operation. (40 CFR 112.8(c)(8)(v).) HSC 25270.4.5(a) 4030023 Failed to observe effluent treatment facilities frequently enough to detect any potential for discharges as described in 40 CFR 112.1(b). (40 CFR 112.8(c) (9).) HSC 25270.4.5(a)
4030021 Failed to promptly correct visible discharges and/or remove any accumulations of oil in diked areas. (40 CFR 112.8(c)(10).) HSC 25270.4.5(a) 4030020 (For mobile or portable storage tanks EXCEPT mobile refuelers) Failed to position or locate mobile or portable storage container, and/or failure to provide secondary containment with sufficient capacity to contain the largest single mobile or portable container/compartment and sufficient freeboard for precipitation. (40 CFR 112.8(c)(11).) HSC 25270.4.5(a) 4030025 Failed to inspect buried piping when exposed for any reason; failed to do additional examination or take corrective action if corrosion damage is identified. (40 CFR 112.8(d)(1).) HSC 25270.4.5(a)
4030027 Failed to provide corrosion protection for buried piping. (40 CFR 112.8(d)(1).) HSC 25270.4.5(a) 4030028 Failed to cap/blank-flange piping connection at transfer point and mark its origin if not in service. (40 CFR 112.8(d)(2).) HSC 25270.4.5(a) 4030029 Failed to design pipe supports to minimize abrasion/corrosion and to allow for expansion/contraction. (40 CFR 112.8(d)(3).) HSC 25270.4.5(a) 4030026 Failed to regularly inspect aboveground valves, piping, and appurtenances. (40 CFR 112.8(d)(4).) HSC 25270.4.5(a) 4030030 Failed to conduct integrity and leak test on buried piping at installation, modification, construction, relocation or replacement. (40 CFR 112.8(d)(4).) HSC 25270.4.5(a)
4030031 Failed to adequately warn vehicles entering facility to protect piping and other transfer operations. (40 CFR 112.8(d)(5).) HSC 25270.4.5(a) HM-950 APSA (08-21)

C O U N T Y O F S A N D I E G O

COMPLIANCE INSPECTION REPORT
APSA Program (continued)
INSPECTION DATE: 06/29/2023 PAGE 11 OF 13
RECORD ID #: DEH2011-HUPFP-214305
4010044 Failed to complete and maintain at the facility the Substantial Harm Criteria certification form when owner or operator determines that the facility could not be reasonably expected to cause substantial harm to the environment. (40 CFR 112.20(e).) HSC 25270.4.5(a) 4010029 Failed to adequately discuss in the SPCC Plan all applicable bulk storage containers, including compatibility with material stored and conditions of storage, and description of sized secondary containment capable of containing the largest single container and sufficient freeboard to contain precipitation. 40 CFR 1 112.8(c )(1) & (2); HSC 6.67 25270.4.5 (a) HM-950 APSA (08-21)

C O U N T Y O F S A N D I E G O

COMPLIANCE INSPECTION REPORT
California Accidental Release Prevention (CalARP)
Program 1
INSPECTION DATE: 06/29/2023 PAGE 12 OF 13
RECORD ID #: DEH2011-HUPFP-214305
VIOLATION REPORT: Each violation checked below is for the section(s) of the California Health and Safety Code (HSC), 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) and Title 42 of the United States Code (USC) 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. Administering Agency (AA); process hazard analysis (PHA); process safety information (PSI); emergency response (ER); regulated substance (RS); stationary source (SS); threshold quantity (TQ)

GENERAL APPLICABILITY & COORDINATION
# VIOLATION DESCRIPTION
5010001 Failure to comply with CalARP provisions when having a regulated substance in a process listed in Table 1/2. 19 CCR 4.5 2735.4(a)(1) 5010002 Failure to comply with the appropriate provisions of 19 CCR 4.5 prior to the date in which a regulated substance is first present in a process above the listed threshold quantity, as listed in Table 3 of Section 2770.5. 19 CCR 4.5 2735.4(a)(2) 5010003 Failure to comply with CalARP provisions when having a regulated substance in a process listed in Table 1/2 and 3. 19 CCR 4.5 2735.4(a)(3) 5010004 Failure to closely coordinate with the CUPA to implement the CalARP requirements. 19 CCR 4.5 2735.5(a) 5030005 Failure to identify hazards that may result from releases, design and maintain a safe facility or minimize the consequences of an accidental release. HSC 25531.2(b)
5010006 Failure to ensure response actions are coordinated with local emergency planning and response agencies. 19 CCR 4.5 2735.5(d)(3) 5010120 Failure to coordinate with CUPA to ensure appropriate technical standards are applied to implement CalARP. 19 CCR 4.5 2785.1(a) 5010121 Failure to request assistance from the CUPA when necessary to address compliance/safety issues with CalARP. 19 CCR 4.5 2785.1(b)

RMP COMPONENTS AND SUBMISSION

RMP SUBMISSION
# VIOLATION DESCRIPTION
5010005 Failure to submit an RMP which includes all requirements in Section 2745.3 to 2745.5 and 2745.8 to 2745.9. 19 CCR 4.5 2735.5(b)(1), 2735.5(d), 2745.1(a)
5010016 Failure to submit the RMP information required by the USEPA to the USEPA. 19 CCR 4.5 2745.1(b)(1), 2745.1(b)(2) 5010017 Failure to submit the RMP information required by the USEPA to the CUPA. 19 CCR 4.5 2745.1(c) 5010018 Failure of a stationary source to submit a Risk Management Plan to the CUPA. HSC 6.95 25536(b) 5010019 Failure to submit an RMP to the CUPA prior to the date a RS is in a process above the TQ. 19 CCR 4.5 2745.1(d) 5010020 Failure to exclude classified information from the RMP. 19 CCR 4.5 2745.1(h)

RMP CERTIFICATION
# VIOLATION DESCRIPTION
5010021 Failure to ensure that the RMP is certified complete by a QUALIFIED PERSON and the stationary source owner or operator. 19 CCR 4.5 2745.2(a) 5010023 Failure to submit in the RMP the certification statement provided in Section 2735.5(d)(4).

RMP UPDATES
# VIOLATION DESCRIPTION
5010025 Failure to revise, update, and submit the RMP to the USEPA and CUPA per timelines in Section 2745.10(a). 19 CCR 4.5 2745.10(a) 5010026 Failure to revise, update, and submit the RMP to the CUPA per timelines in Section 2745.10(b). 5010027 Failure to submit a de-registration to the USEPA and CUPA within six months of the regulated substance removal. 19 CCR 4.5 2745.10(c) 5010028 Failure to submit a de-registration to the CUPA within six months of the regulated substance removal. 19 CCR 4.5 2745.10(d) 5010029 Failure to contact the CUPA within 30 days of a change of owner or operator to update the registration. 19 CCR 4.5 2745.10(f)

RMP CORRECTIONS
# VIOLATION DESCRIPTION
5010030 Failure to correct and submit the data required in the RMP under sections 2745.5, 2745.6(j), and 2745.7(1) (New Accident History). 19 CCR 4.5 2745.10.5(a)
5010031 Failure to correct and submit the EMERGENCY CONTACT information in the RMP within one month of any change. 19 CCR 4.5 2745.10.5(b)

COVERED PROCESS MODIFICATION
# VIOLATION DESCRIPTION
5010032 Failure to notify the CUPA in writing of the intent to modify the stationary source at least five calendar days before implementing any modifications or no later than 48 hours following the modification if prenotification is not reasonable. 19 CCR 4.5 2745.11(a)(1) 5010033 Failure to establish procedures to manage the proposed modification, which shall be substantially similar to the procedures specified in Sections 2760.6 and 2760.7, and notify the CUPA that the procedures have been established. 19 CCR 4.5 2745.11(a)(2) 5010262 Failure to revise documents as required pursuant to section 2745.11(a) at a modified stationary source. 19 CCR 4.5 2645.11(b)

CERTIFICATE OF OCCUPANCY
# VIOLATION DESCRIPTION
5010034 Failure to comply with Government Code Section 65850.2(b) prior to issuance of a certificate of occupancy. 19 CCR 4.5 2745.12

RMP REVIEW
# VIOLATION DESCRIPTION
5010022 Failure to correct deficiencies within 60 calendar days from receipt of the notification of RMP deficiencies. 19 CCR 4.5 2745.2(b)(1)

REGISTRATION
# VIOLATION DESCRIPTION
5010008 Failure to include a registration in the RMP that reflects all covered processes. 19 CCR 4.5 2735.5(b)(2) 5010012 Failure to complete the registration information and submit it with the RMP to the USEPA and the CUPA. 19 CCR 4.5 2740.1(a) 5010013 Failure to complete the REGISTRATION information and submit it with the RMP to the CUPA.

HM-972 CalARP (08-21)

C O U N T Y O F S A N D I E G O

COMPLIANCE INSPECTION REPORT
CalARP Program 1 (continued)
INSPECTION DATE: 06/29/2023 PAGE 13 OF 13
RECORD ID #: DEH2011-HUPFP-214305
5010014 Failure to submit a registration with a certification of accuracy to the CUPA prior to submittal of the RMP. 19 CCR 4.5 2740.1(c) 5010015 Failure to include the data required in Section 2740.1(d)(1) through (d)(20) in the registration. 19 CCR 4.5 2740.1(d)

HAZARD ASSESSMENT
# VIOLATION DESCRIPTION
5010035 Failure to prepare a worst-case release scenario analysis as provided in Section 2750.3. 19 CCR 4.5 2750.1 5010036 Failure to complete the five-year accident history as provided in Section 2750.9. 19 CCR 4.5 2750.1

RECORDKEEPING
# VIOLATION DESCRIPTION
5010119 Failure to maintain records supporting the implementation of CalARP for five years unless otherwise provided. 19 CCR 4.5 2775.1 HM-972 CalARP (08-21)
Crystal, Marisue
From:

Sent:

To:
•
Crystal, Marisue
Friday, August 27, 2004 8:39AM
'[email protected]'
•
Subject: 60-day drilling report for permit LMON 1 01784, Main Street Energy Facility @ 3497 Main St.

Chula Vista, CA
Mr. Fry,
I received the faxed revision for the volume of sealing materials used to backfill boring SB-1. It does not seem possible that 2 bags of bentonite, mixed with 7 bags (cu. ft.) of sand, could expand sufficiently to fill the available space within the borehole.

Would you please recheck your calculations? Thank you.

Marisue Crystal
Environmental Health Technician
DEH/SAM Monitoring Well Program
Ph: (619) 338-2013
FAX: (619) 338-2315
1 • •
Qlountl! of
GARY W. ERBECK

DIRECTOR DEPARTMENT OF ENVIRONMENTAL HEALTH

LAND AND WATER QUALITY DIVISION
P.O. BOX 129261, SAN DIEGO, CA 92112·9261
(619) 338·2222 FAX (619) 338·2377
1·800-253-9933

RICHARD HAAS

ASSISTANT DIRECTOR
Date:
;::r-y
WELL PERMIT# / (J /7 y'(
The Site Assessment and Mitigation Program is returning your 60-day drilling report for the above-referenced permit because the report is incomplete. Please resubmit with the following items not included with your report:

1. Submit written documentation indicating the method used to destroy the monitoring well/boring(s) the type of sealing materials, volumes used, and the date the work was started and date it was completed. cu.. FTi . _

2. Submit a site plan indicating the actual location of the monitoring well/boring(s).

3. Submit the types and/or volumes of sealing materials used to backfill the borings.

4. Submit a letter of explanation stating why the surface construction was not completed as siated in the permit.

5. Submit monitoring well/boring log(s).

6. Submit a detailed "as builf' well construction diagram with the type of casing, screened interval, screen slot size, type of filter pack, depth, location of material used, and type of seals, and volumes of materials used for each monitoring well.

7. Submit a signed 60-day drilling report that includes the signature and/or official stamp of Registered Geologist, Registered Civil Engineer, or Certified Engineering Geologist responsible for the accuracy and completeness of the logs, and accompanying data that were submitted.

8. Submit the laboratory report(s) for the soil and/or groundwater sampling that this work accompanied.

Please submit the above-requested information to this department within fourteen (14) working days by mail, fax (619) 338-2315, or e-mail •@sdcountv.ca.gov. If you have any questions regarding this letter, please contact me at (619) 338-2339.

Sincer/n f);frL
Marisue Crystal, Environmental Health Technician
Site Assessment and Mitigation Program
"Environmental and public health through leadership, partnership and science" -
'·
• ·,------------, PERMIT# LMON101784
A.P.N. # 629-062-04-00
#NON!=

COUNTY OF SAN DIEGO

DEPARTMENT OF ENVIRONMENTAL HEALTH

LAND AND WATER QUALITY DIVISION

MONITORING WELL AND BORING CONSTRUCTION AND DESTRUCTION PERMIT PERMIT APPROVAL DATE: March 4, 2004
< '//
PERMIT EXPIRES ON: July 2, 2004
/ '
f /
F/ : l
PERMFT CONDITIONS: i: : i \ \
.· I, ! \ \
I. •! . II q 1. ; 1 All borings must be destroyed in acc<iraance with Department · of\ Water 1 , Resources Bulletin 74-81 ahd 74-90. Borings must be sealed from the bottom of I/ the boring-to-gro)Jnd-sucta'ce with an Drill cuttings 'J are not acceptablelill material. ... - -- .. --- i i I; I i

2.: Placement of sealing material at a depth greater than 30 feet must be done 'l.(sing '·! the tremie method. i '
'

3. \
1 1 All and soil resulting from the activities covered by this permit be \\ managed, storedJind of as speci!Led_jQJb_e Manual in Seqt\bn 5, \· 1 E- 4. (http://WW'N:sdcountv.ca,gov/deh/lwg/sam/manual guidelines;html). In \·,addition, drill cuttings must be properly hanaled and disposed.in complia(lce with \·the Stormwater Best Management Practices of the local jurisdiction. !/ f i .I . · .!/i

4. V\fithin 60 days of completirg work, submit a well construction report, .il'fcluding all boring logs anc!Jiaboratory the Well Permit report
all items required by the SAM Manual, Section 5, 6 & 7. '\'· J'/

5. This office·,J!IUSt be given 48-hour notice of any drilling activit? on this site and advanced'·nqtification of drilling cancellation. Please <:;P_JJfaCt the Well Permit Desk at
__
---1..-
APPROVEDBY: ______ DATE: 03/04/2004
NOTI FlED:

DEH:SAM-9075 (4/03)
A.
91P , .. .. A 1 cpc\:

PERMIT AP:P!fCATION'\1°\
• GROUNDWATER l!CEIVED
AND .

VADOSE MONITORING · Arlll 16

OFFICE USE ONLY
PERMIT #W J. A-tiJJ J()/ 7f
SAM CASE f}j()/f)l/!
DATE RECEIVED: iJS'jpt/
AND EXPLORATORY OR TEST BORINGS o. E. H.

HAILROOH
RESPONSIBLE PARTY RAM CO Generating One Phone
Mailing Address _61 A venida de Orinda __ City __ Orinda State _CA __ Zip _94563 _ Contact Person Mr. Kent Ficken Phone 925-258-9829 ext. --- -- -- -.
< '.i.. '-0-··u "! 1J"f 1 U • !L• i:L11H .li :

B. SITE ASSESSMENT PROJECT IF APPLICABLE #H CH-K
964
DO f14 .
c. CONSULTING FIRi\1 TRC
Mailing Address __ 21 Technology Drive City __ Irvine State _CA __ Zip _926!8_ Registered Professiona1 __ Gil Fry Registration # __ 5678 (RG) (RG, RCE, CEG) Contact Person Camilla Khan Phone 949-727-7397
D. DRILLING COMPANY West Hazmat C57# 819548 -- -
Mailing Address 1 0 16 E. Katella A venue City Anaheim
E. CONSTRUCTION INFORMATION

TYPE OF WELLS/ MATERIALS TO BE USED

BORINGS TO BE

CONSTRUCTED CASING SEAL
#
0 Groundwater ___ _
0 Vadose
Boring 5 __ _
0 Other _____ _
NU!VffiER OF WELLS TO
BE DESTROYED#
Type __ _
Gauge __ _
Diameter __ _
0 Neat Cement
Cement & Bentonite
0 Sand-Cement
Well Screen Size __ _ 0 Bentonite
Filter Pack
(Specify)
Drilling Method
0 Mud Rotary
0 Percussion
0 Other
0 Air Rotor
0 Other
ext._
Phone - 7!4-939-6850_
State CA Zip 92805

PROPOSED CONSTRUCTION
Estimated ground water depth _30_ft
CEMENT SEAL _Q __ to __ 3 __
BENTONITE SEAL_ 4 __ to 30
FILTER PACK to __ _
PERF ORA. TION to __ _
PROPOSED DRILLING DATE l/22/04
NOTE:

For wells with multiple completion
attach a well construction diagram
I agree to comply with the requirements of the current Site Assessment and Mitigation , and with all ordinances and laws of the County of San Diego and the State of California pertaining to well/boring co wn and destruction. __
Within 60 days of completion, I will furnish the Monitoring e it Desk with a complete and accurate well/boring log. l will certify the design and construction/or destruction of the welVborings in accordance with the permit application. •

F SITE INFORMATION
I. ASSESSOR'S PARCEL NUMBER 629-062-04-00
Site Name tnA-1t0 :57. 'I F4C-IL--1 Tf-
Site Address 3497 Main Street City Chula Vista
PROPERTY OWNER John and Carol Marguez Phone
Mailing Address 3 I 0 K Street City Chula Vista

NUMBER OF WELLS TYPE OF WELLS

2. ASSESSOR'S PARCEL NUMBER
Site Name
Site Address City Zip
PROPERTY OWNER Phone --
Mailing Address City
NUJVffiER OF WELLS TYPE OF WELLS

3. ASSESSOR'S PARCEL NUMBER
Site Name
Site Address City

PROPERTY OWNER
Mailing Address City
NUJVffiER OF WELLS TYPE OF WELLS

4. ASSESSOR'S PARCEL NUMBER
Site Name
Site Address City

PROPERTY OWNER
Mailing Address City

NUMBER OF WELLS TYPE OF WELLS
DEH:SAM-9060 (Rev. 01/02) Page 2 of6
•
Zip 91911
State CA Zip 92011
NUMBER OF BORINGS 5 -
State Zip
NUJVffiER OF BORINGS
State
State
Zip
Phone
Zip
Zip
Phone
Zip
County ·of San Diego
Deparnnent of Environmental Health
G. FEES:
• •
Permit Fees In Effect for July 1, 2003 -June 30, 2004

ACTIVITY
Permit for Well Installations
Only
(Groundwater Monitoring
Wells, Vadose, Vapor
Extraction Wells)

NEW FEES
Permit for Well Maintenance
Inspection
(Valid for lhree years)
Each Additional New
Well
Permit for Borings Only
(CPT's, Hydropunch,
Geoprobes, Temporary Well
Points, etc.)
Permit for
Well Destructions Only
Permit for any Combination
of Well Installations,
Borings, & Destructions
(except UST backfill permit)
DEH:SAM-9060 (Rev. 01/02)

FEE SCHEDULE
$165.00 for the first monitoring well
$ 90.00 for first well maintenance
inspection
$140.00 for each additional well
installation
$ 30.00 for each additional well
maintenance inspection
$165.00 for the first boring
$45.00 for each additional boring
$165.00 for the first destruction
$110.00 for each additional destruction
The first activity will be $165.00.
•••• 0 ••••••••••••••••••••••••••••
Additional activities will be as follows:
$140.00 for each additional well
$ 90.00 for first well maintenance
inspection
$ 30.00 for each additional well
maintenance inspection
$ 45.00 for each additional boring
$110.00 for each well destruction

TOTAL COST OF PERMIT
' Page 3 of6
AMOUNT
__ X $165.00 =$
X $ 90.00 =$
--- X $140.00=$
X $ 30.00 =$
1 X $165.00 $ 165
4 X $ 45.00 $ 180
X $165.00 $
X $110.00$
X $165.00 $
X $140.00 $
X $ 90.00 $
X $ 30.00 $
X $ 45.00$
X $110.00 $
$ 345
County of San Diego
Department of Environmental Health
•
•
•
•
•
•
• •

PERMIT APPLICATION FOR

GROUND WATER AND VADOSE MONITORING WELLS

EXPLORATORY OR TEST BORINGS
For well destruction, complete only #l below .

Well design, logging and construction must be supervised by a Geologist, Engineering Geologist or Civil Engineer who is regtstered or certified by the State of California.

Well driller must have an active C-57 License and current $2,500 bond with the County .

Provide a plot plan giving location of property lines, existing improvements such as structures, underground tanks, underground utilities, underground piping, and the proposed monitoring and/or observation wells.

If applicable, provide a signed copy of the Property Owner Responsibility form for each property listed in Section "F".

If applicable, provide a signed copy of the Property Owner Responsibility form for each property listed in Section "F". Provide encroachment/excavation permit and/or traffic control permit for work to be done in street or public right of way.
!. If wells are to be destroyed, provide a description of method of destruction. A,_,_ ________ _

2. What is the proposed purpose of the well/boring? To collect information regarding the presence or absence of hydrocarbon-affected groundwater.

3. What procedures will be used to prevent the well/boring from providing an avenue to contamination during construction?
Fluids other than approved drilling fluids will not be allowed to enter the boring.

4. What field procedures will be utilized to determine if contamination exists? Groundwater samples will be collected from each boring and will be screened with a photo-ionization detector

5. What procedures will be used to determine whether samples will be sent for laboratory testing or archiving? Groundwater samples will be selected for laboratorv analysis based on stratigraphic position, degree of visual discoloration, PID measurements, and proximitv to the water table.

DEH:SAM-9060 (Rev. 0 1102) Page 5 of6
County of San Diego
Department of Environmental Health
'
• •

6. What constituents will be monitored and tested (Include EPA Laboratory Test Methods to be used)? Diesel- and gasoline-range hydrocarbons will be monitored and analyzed by EPA 8015M

7. How will samples be transported and preserved? Samples will be placed in a cooler and chilled to approximately 4° Celsius. Packaging will be added to the cooler to prevent sample movement.

8. What sampling methods will be used? Groundwater samples will be collected using a Hydropunch sampler.

9. Are you proposing a variation from the methods and/or procedures presented in the requirements for the construction of Vadose and Ground Water Monitoring Wells (Current SAM Manual Requirements). If yes, specify these variations.

No.

I 0. What procedures will be used to ensure no contamination will be introduced by the drilling equipment? A high-pressure water washer will be used to wash digging/drilling equipment prior to advancing each boring.

11. What methods will be used to clean sampling equipment? Sampling equipment will be washed in a Liqui-Nox solution and rinsed twice in potable water prior to sample collection.

12. What cleaning method will be used to clean casing and screen prior to installation?---------- DEH:SAM-9060 (Rev. 01/02) Page6of6
Coun·ty of San Diego
Department of Environmental Health
..
' "' ..
• •

MAIN STREET
c------$]
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I
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e )...

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I 0§
I -.I EXISTING "
STRUCTURES rJ
<:(
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LEGEND SITE PLAN
e Proposed Boring 3497 Main Street Location
Chula Vista, California
'rRC

SCALE (FEET)
FIGURE 1 0 200
f: \Uf'OpntCS V"rOj(ICCst:lytYUmOer \.o!".!f-XXX]{ \.t.!f-V.t"'.t I"'«JIC LOOO owg l
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• •
County of San D · REcEivEo
DEPARTMENT OF ENVIRONMENTAL HEAL! e Af'l 10 17 GARY W. ERBECK

DIRECTOR LAND AND WATER QUALITY DIVISION
12551MPERIAL AVE., SAN DIEGO, CA 92101-7493
P.O. BOX 129261, SAN DIEGO, CA 92112-9261
(619) 338-2222 FAX (619) 338·2377
1-800-253-9933

PROPERTY OWNER RESPONSIBILITY AGREEMENT

ASSISTANT DIBECIOR
U. t. H.

HAILROOH
Proposed Location ofBorings(s): Property Address: ___ .3497 Main Street. _________ _ See Figure I attached
___ Chula Vista, California. ________ _
___ 91911 __________ _
Dear Property Owner:

This letter is t{) infonn you of the responsibilities for the proposed drilling activities on your property. The scope of work covered by this letter will expire one year from the date you sign this fonn. Any proposed drilling activities beyond this expiration date will require a new Property Owner Responsibility Agreement.

Please place a check mark next to the activity which applies to your property:
0 Install one or more monitoring wells
0 Destroy one or more monitOfirig ·wens·
Drill one or more soil borings
The person who causes to have a monitoring well installed or an ex1stmg well destroyed on your property is defined as the "Responsible Party." Section 67.424 of San Diego County Code states that: "Monitoring wells shall be maintained to meet construction or destruction standards. If a monitoring well does not meet construction or destruction standards the Responsible Party must repair, reconstruct or destroy the monitoring well so it meets the standards. The property owner, if different than the Responsible Party, must take the necessary actions to repair, reconstruct or destroy the monitoring well so it meets the standards if the Responsible Party does not complete the necessary actions."
A soil boring is used specifically to sample soil and, because there are construction and destruction standards, is included in the definition of a monitoring well even though no maintenance is required. These standards are outlined in the County of San Diego SAM Manual and the State of California Well Standards Bulletin 74-90. · !
If you have any or would like additional infonnation, please contact the Monitoring Well Program at (619) 338-2339.

I understand the maintenance and construction/destruction responsibilities for monitoring wells and borings under the San Diego County Code.
) Property Ow r
Signature: ·
Mailing
.. 310 "K" Street
Chula 91911 ·
IJEH-SAM-9503 (REV. 12/99)
Crystal, Marisue
From:

Sent:

To:

Cc:
•
Fry, Gil [[email protected]]
Monday, August 30, 2004 3:48 PM
Crystal, Marisue
Khan, Camilla; Dowling, Jason
•
Subject: RE: 60-day drilling report for permit LMON1 01784, Main Street Energy Facility@ 3497 Main St. Chula Vista, CA
>eak - 58-1 - Boring Peak - Daily Work
Log 08-30... Report - 6-1...

Marisue - After doing some research into the issue
provides the following clarification. The former Boring Log for SB-1 incorrectly identifies the backfill material. A revised Boring Log for SB-1 is attached as well as the Daily Field Report from Test America Drilling Corporation (West Hazamat; the driller used to drill and backfill the boring)_ This-Daily Field Report shows the material actually used at the site. The backfill for Boring SB-1 consisted of four bags of bentonite grout and one bag of ready mix concrete. The concrete was used at the surface of the backfilled boring. The bentonite chips identified on the Test America Daily Work Report were used to backfill an attempted boring location which was terminated when obstructions were encountered wit,ihin the upper five feet. Thank you for your attention to this item. Please email or call with any questions. Thanks. Gil Fry (949-753-0101)
-----Original Message-----
From: Crystal, Marisue [mailto:Marisue.crystal®sdcounty.ca.gov] Sent: Friday, August 27, 2004 8:57AM
To: Fry, Gil
Subject: 60-day drilling report for permit LMON101784, Main Street Energy Facility ® 3497 Main St. Chula Vista, CA
Mr. Fry,
I received the faxed revision for the volume of sealing materials used to backfill boring SB-1. It does not seem possible that 2 bags of · bentonite, mixed with 7 bags (cu. ft.) of sand, could expand sufficiently to fill the available space within the borehole.

Would you please recheck your calculations? Thank you.

Marisue Crystal
Environmental Health Technician
DEH/SAM Monitoring Well Program
Ph: (619) 338-2013
FAX: (619) 338-2315
1 you raised, TRC
• • TRC
, ...
'1 .

Customer-Focused Solutions RECEIVED
July 19, 2004 AUG 9 API 9 53
D. E. H.

Site Assessment and Mitigation Program (SAM)
San Diego County Department of Environmental Health
P.O. Box 129261
San Diego, CA 92112-9261
ATTN:

SITE:

RE:

MARISUE CRYSTAL

MAIN STREET ENERGY FACILITY
3497 MAIN STREET

CHULA VISTA, CALIFORNIA
PERMIT NO. LMON I 01784
60-DA Y BORING COMPLETION REPORT
Dear Ms. Crystal:
,.

HAILROOH
...... = = ..c:
= = :J: C?
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fT1
0- ::0 < o=- :::3 fT1
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0 The boring log and site plan are enclosed for one temporary soil boring SB-1. The boring was installed under well permit LMON I 01784 on June 10, 2004. The boring is located at 3497 Main Street, Chula Vista, A.P.N. 629-062-04-00. A groundwater sample was submitted to a state-certified laboratory for analysis. Analytical results and the boring log are attached. The boring was sealed from the bottom of the boring to ground surface with a bentonite slurry. The boring was installed under the direction of Mr. John G. Fry, California Registered Geologist 5678.

Please call us at (858) 505-8881 if you need any other information regarding this boring.

Sincerely,
TRC
!J,y Jason D. Dowling
Senior Staff Hydrogeologist
John G. Fry, RG
Principal Geologist
N:Projects/PG&E/Chula Vista/Main Street Energy Boring Notification Letter.doc 21 Technology prive • Irvine, California 9261 8
Telephone 949.727-9336 • Fox 949-727-7399
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lEGEND SITE PLAN
SB-1 E9 Approximate Sail
Boring Location 3497 Main Street
Chula Vista, California
.,..c

SCALE (FEET)
FIGURE 2
0 150
" ,. ·eo< ' ,. •.awg v/ v/ ra'
•
PROJECT NO.: 290242 OA TE DRILLED: June 10, 2004
LOCATION: Peak Load LOGGED BY: J. Dowling
3497 Main Street APPROVED BY: G Fry, RG
Chula Vista, California DRILLING CO./RIG: Test America Drilling Co.LCME-75 i DRILLING METHOD: 8-inch Diameter Air Rotary
(!)
0 "' "'
....1

BOREHOLE
"'V> ">' • SAMPLER TYPE: NA (.)
a...., E 0
I BACKFILL Q. ;; TOTAL DEPTH: 32.0 feet DEPTH TO WATER: 26 feet Q. j!:.C (/) 0. DETAIL 0.. (.) <( 0 "' o..< (/)
"'
....J
a: O!i "-'.! DESCRIPTION ::> (!) ID<O
l--0 Hole Cleared by Air Vac and Hand Auger to 5-feet.

Concrete
r- -,;
1--
- vvv
- -Bentonite
1-- _ Grout
r- -
vvv
l--5 5- vvv
vvv
r- -
1-- -
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r- - vvv
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1='"1 0 1G-: vvv
vvv
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vvv
r- -::: YV vvv
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vvv
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- APPROXIMATE MATERIALS USED: \ -
:._35 4 BAGS OF BENTONITE GROUT= 12 CUBIC FEET (_/ 35_:
-
1 BAG OF CONCRETE = 0.5 CUBIC FEET 0 . --:
::- -
- --: - -
:._40 4o-=
'rRC LOG OF EXPLORATORY BORING SB-1
PAGE 1 OF 1
29-0242 Boring Logs B/6/04 cmo
.·:.· .·:,._·c·.· ,, .... _,_._.., .. :.;"' ''···'• .. ,_, .... '· .. .--' ........ :; .. _: ... :·.:

DAILY WORK REPORT
Anaheim, CA 92805 . Kur1Z S1. (714) 939-6850 D1ego, CA 92110 , 819) 686-5800 I JOB LOCATION: v.... ... . .L L I> f c;nr-, f' F "- '
OESCRIFnONOFWOOK '
aasons For All Down Tim a and Stand-By Tme START STOP ExplainR '. 15:?0
1 AM.SHOPTIME
lllio "JI'?cJ I TRAVEL TO JOB SITE
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1700
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American Environmental Testing Laboratory Inc.
2834 North Naomi Street Burbank, CA 91504 • DOHS NO: 1541, LACSD NO: 10!81 Tel: (888) 288-AETL • (818) 845-8200 • Fax: (818) 845-8840 • www.aetlab.com

ANALYTICAL RESULTS
Site
Telephone: (949)753-0101
Attn: Camilla K11an
Page: 22
ID: 29024202 TA04
Project Name: Main Street Energy . 06/14/2004 TRC
----- .. ·.: ···- ·--·'····-' ..

American Environmental Testing Laboratory Inc.
2834 North Naomi Street Burbank, CA 91504 • DOHS NO: 1541, LACSD NO: 10181 Tel: (888) 288-AETL• (818) 845-8200 • Fax: (818) 845-8840 • www.aetlab.com

ANALYTICAL RESULTS
Site
Attn: Camilla Khan
Page: 23
Project!D: 29024202 TA04
Project Name: Main Street Energy
Ordered By
American Environmental Testing Laboratory Inc.
2834 North Naomi Street Burbank, CA 91504 • DOHS NO: 1541. LACSD NO: 10181 Tel: (888) 288-AE'IL • (818) 845-8200 • Fax: (818) 845-8840 • www.aetlab.com

ANALYTICAL RESULTS
Site
Telephone: (949)753-0101
Attn: Camilla Khan
Page: 24
Project ID: 29024202 TA04
Project Name: Main Street Energy
Ordered By
•
American Environmental Testing Laboratory Inc.
2834 North Naonti Slreet Burbank, CA 91504 • OOHS NO: 1541, LACSD NO: 10181 Tel: (888) 288-AETL • (818) 845-8200 • Fax: (818) 845-8840 • www.aetlab.com

ANALYTICAL RESULTS
Site
Telephone: (949)753-0101
Attn: Camilla Khan
Page:

Project ID:

Project Name:
25 29024202 TA04
Main Street Energy
Method: 601 0/7000CAM, CAM Title 22 Metals (SW-846)
QC Batch No: 061704
Ordered By
American Environmental Testing Laboratory Inc .
. 2834 Nonh Naomi Street Burbank, CA 91504 • DOHS NO: 1541, LACSD NO: 10!81 Tel: (888) 288-AETL • (818) 845-8200 • Fax: (818) 845-8840 • www.aetlab.com

ANALYTICAL RESULTS
Site
Telephone: (949)753-0101
Attn: Camilla Khan
Page: 26
Project ID:

Project Name:
29024202 TA04
Main Street Energy 29404 06/14/2004 TRC
QC Prepared: 06/16/2004 QC Analyzed: 06/18/2004

MS MS MS DUP MS DUP MS DUP RPD MS/MSD MS RPD
QC Prepared: 06/16/2004 QC Analyzed: 06/18/2004
Page:

Project ID:

Project Name:
27 • • ••••• •
American Environmental Testing Laboratory Inc.
2834 North Naomi Street Burbank, CA 91504 • DOHS NO: 1541. LACSD NO: 10181 Tel: (888) 288-AETL • (818) 845-8200 • Fax: (818) 845-8840 • www.aetlab.com

ANALYTICAL RESULTS
29024202 TA04
Main
Method:

QC Analyzed: 06/18/2004
• -······
American Environmental Testing Laboratory Inc.
2834NorthNaomiStreetBmbank,CA91504 • DOHSNO: 154l.LACSDNO: 10181 Tel: (888) 288-AETL • (818) 845-8200 • Fax: (818) 845-8840 • www.aetlab.com

ANALYTICAL RESULTS
Site
Telephone: (949)753-0 I 0 I
Attn: Camilla Khan
Page: 28
Project ID: 29024202 TA04
Project Name: Main Street Energy
QC Analyzed: 06/16/2004

MS DUP MS DUP RPD MS/MSD MS RPD
American Environmental Testing Laboratory Inc.
2834NorthNaomiStreetBurbank,CA91504 • DOHSNO: 154l,LACSDNO: 10181 Tel: (888) 288-AETI. • (818) 845-8200 • Fax: (818) 845-8840 • www.aetlab.com

ANALYTICAL RESULTS
Site
Telephone: (949)753-0101
Attn: Camilla Khan
Page:

Project ID:

Project Name:
29 29024202 TA04
,,;.:;o
Main Street Energy 29404 06/14/2004 TRC
Method: (8310), Polynuclear Aromatic Hydrocarbons (SW-846)

QUALITY CONTROL REPORT
QC Batch No: 061504 Sample Spiked: 29412.05 QC Prepared: 06/15/2004 QC Analyzed: 06/16/2004

MS MS MS MS DUP MS DUP MS DUP RPD MS/MSD MS RPD
QC Prepared: 06/15/2004 QC Analyzed: 06/16/2004
Ordered By·
•
American Environmental Testing Laboratory Inc.
2834 North Naomi Street Burbank, CA 91504 • OOHS NO: 154l,LACSD NO: 10181 Tel: (888) 288-AETL • (818) 845-8200 • Fax: (818) 845-8840 • www.aetlab.com

ANALYTICAL RESULTS
Site
Telephone: (949)753-01 0 I
Attn: Camilla Khan
Page: 30
Project!D: 29024202 TA04
Project Name:

Method: (M8015D),
ili'
29404 06/14/2004 TRC
Diesel and Heavy Hydrocarbons Using GC/FID

CONTROL REPORT
06/16/2004 QC Analyzed: 06/16/2004
• •
American Environmental Testing Laboratory Inc.
2834 North Naomi Street Burbank. CA 91504 • DOHS NO: !541, LACSD NO: 10181 Tel: (888) 288-AETL • (818) 845-8200 • Fax: (818) 845-8840 • www.aetlab.corn

ANALYTICAL RESULTS
Site
Telephone: (949)753-0101
Attn: Camilla Khan
Page:

Project ID:

Project Name:
31 29024202 TA04
Main Street Energy
Method: (M8015D), TPH as Diesel and Heavy Hydrocarbons Using GC/FID

QUALITY CONTROL REPORT
QC Batch No: 062104 Sample Spiked: 062104 QC Prepared: 06/2112004 QC Analyzed: 06/21/2004

MS MS MS MS DUP MS OUP MS OUP RPO MS/MSD MS RPD
QC Prepared: 06/21/2004 QC Analyzed: 06/21/2004
•••• •
American Environmental Testing Laboratory Inc.
2834 North Naomi StreetBwbank, CA 91504 • DOHS NO: 1541, LACSD NO: 10181 Tel: (888) 288-AETL • (818) 845·8200 • Fax: (818) 845-8840 • www.aet1ab.com

ANALYTICAL RESULTS
Site
Telephone: (949)753-0101
Attn: Camilla Khan
Page: 32
Project ID: 29024202 TA04
Project Name: Main Street Energy 29404 06/14/2004 THC
Gasoline and Light Hydrocarbons Using GC/FID

CONTROL REPORT
QC Analyzed: 06/1512004

MS DUP RPD MSIMSD MS RPD
Ordered By
··············-······ •
American Environmental Testing Laboratory Inc.
2834 North Naomi Street Burbank, CA 91504 • OOHS NO: 1541. LACSDNO: 10181 Tel: (888) 288-AETL • (818) 845-8200 • Fax: (818) 845-8840 • www.aetlah.com

ANALYTICAL RESULTS
Site
Telephone: (949)753-0101
Attn: Camilla Khan
Page: 33
Project ID: 29024202 TA04
Project Name: Main Street Energy
Method: 601
QC Batch No: 061704 Sample Spiked: 29412.12 QC Prepared: 06/17/2004 QC Analyzed: 06/21/2004

LCS LCS LCS
MS RPD
Page:

Project ID:

Project Name:
34 • •
American Environmental Testing Laboratory Inc.
2834 North Naomi Street Burbank. CA 91504 • DOHS NO: 1541, LACSD NO: 10181 Tel: (888) 288-AETL• (818) 845-8200 • Fax: (818) 845-8840 • www.aetlab.com

ANALYTICAL RESULTS
29024202 TA04
Main Street Energy
0611712004 QC Analyzed: 0612112004
Ordered
•
American Environmental Testing Laboratory Inc.
2834 North Naomi Street Burbank, CA 91504 • OOHS NO: 1541, LACSD NO: 10181 Tel: (888) 288-AETL • (818) 845-8200 • Fax: (818) 845-8840 • www.aetlab.com

ANALYTICAL RESULTS
Site
Telephone: (949)753-0 I 0 I
Attn: Camilla Khan
Page:

Project ID:

Project Name:
35 29024202 TA04
Main Street
Method:
' ... ·
BTEX Compounds by GC/MS (SW846)

CONTROL REPORT
QC Analyzed: 06/17/2004

MS DUP MS DUP RPD MS/MSD MS RPD
QC Prepared: 06/17/2004 QC Analyzed: 06/17/2004
• •
American Environmental Testing Laboratory Inc.
2834 North Naomi Street Burbank, CA 91504 • DOHS NO: 1541. LACSD NO: 10181 Tel: (888) 288-AEIL • (818) 845-8200 • Fax: (818) 845-8840 • www.aetlab.com

ANALYTICAL RESULTS
Site
Telephone: (949)753-0101
Attn: Camilla Khan
Page: 36
Project ID:
· Project Name:
29024202 TA04
Main Street Energy
QC Analyzed: 06/18/2004

MS DUP MS DUP RPD MSIMSD MS RPD
Ordered By
• •
American Environmental Testing Laboratory Inc.
2834 North Naomi Street Burbank, CA 91504 • DOHS NO: 1541. LACSD NO: 10181 Tel: (888) 288-AE'IL • (818) 845-8200 • Fax: (818) 845-8840 • www.aetlab.com

ANALYTICAL RESULTS
Site
Telephone: (949)753-0 I 0 I
Attn: Camilla Khan
Page: 37
Project ID: 29024202 TA04
Project Name: Main Street Energy
QC Balch No: 061404 Sample Spiked: 06/1412004 QC Analyzed: 06/14/2004 Sample MS MS DUP MS DUP MS DUP RPD MS/MSD MS RPD
Result Concen Concan Recov % REC % % Limit % Limit

0.0 0.50 0 92 6.3 75-125 <20
QC Batch No: 061404 Sample Spiked: 061404 QC Prepared: 06/1412004 QC Analyzed: 06/14/2004

LCS LCS LCS
Concen Recov % REC % Limit

0.50 0.48
Data Qualifier:
..

B:

D:

E:

H:

J:

M:

S6:

S8:

X:

Definition:
%Limi:
%REC:

Con.L:

Conce:

LCS:

MDL:

MS:

MSDU:
• •
American Environmental Testing Laboratory Inc.
2834 Nonh Naomi Street Burbank, CA 91504 • OOHS NO: 1541, LACSD NO: 10181 Tel: (888) 288-AETI..• (818) 845-8200 • Fax: (818) 845-8840 • www.aetlab.com Data Qualifiers and Descriptors
In the QC section, sample results have been taken directly from the ICP reading. No preparation factor has been applied.
· Analyte was present in the Method Blank.

Result is from a diluted analysis.

Result is beyond calibration limits and is estimated.

Analysis was performed over the allowed holding time due to circumstances which were beyond laboratory contro1.

Analyte was detected . However, the analyte concentration is an estimated value, which is between the Method Detection Limit (MDL) and the Practical Quantitation Limit (PQL).

Matrix spike recovery is outside control limits due to matrix interference. Laboratory Control Sample recovery was acceptable.

Surrogate recovery is outside control limits due to matrix interference.

The analysis of the sample required a dilution such that the surrogate concentration was diluted below the method acceptance criteria.

Results represent LCS and LCSD data.

Percent acceptable limits.

Percent recovery.

Acceptable Control Limits
Added concentration to the sample.

Laboratory Control Sample
Method Detection Limit is a statistically derived number which is specific for each instrument, each method, and each compound. It indicates a distinctively detectable quantity with 99% probability ..

Matrix Spike
Matrix Spike Duplicate
ND:

PQL:

Recov:

RPD:.

American Environmental Testing Laboratory Inc.
2834 North Naomi Street Burbank, CA 91504 • DOHS NO: 1541, LACSD NO: 10181 Tel: (888) 288-AETL • (818) 845-8200 • Fax: (818) 845-8840 • www.aetlab.com Data Qualifiers and Descriptors
Analyte was not detected in the sample at or above MDL.

Practical Quantitation Limit or ML (Minimum Level as per RWQCB) is the minimum concentration that can be quantified with more than 99% confidence. Taking into account all aspects of the entire analytical instrumentation and practice.

Recovered concentration in the sample.

Relative Percent Difference
• •
@ountt! of JElicgn
GARY W. ERBECK

DIRECTOR
December 1, 2006
Ninyo & Moore

DEPARTMENT OF ENVIRONMENTAL HEALTH

LAND AND WATER QUALITY DIVISION

MONITORING WELL PROGRAM
P.O. BOX 129261, -SAN DIEGO, CA 92112·9281
619·338·2222/F AX 819·338-2315/1·800·2 53·9933
www.sdcounty.ca.gov/deMwq
Attn: Jonathan Goodmacher
5710 Ruffin Rd.

San Diego CA 92123
Dear Mr. Goodmacher:

MONITORING WELL PERMIT #LMON104313 A.P.N. #629-062-04

CHULA VISTA ENERGY PLANT
3497 MAIN ST. (S. SIDE OF MAIN ST & W. OF ALBANY AV), CHULA VISTA, CA 92154 The monitoring well permit referenced-above was issued for two geotechnical soil borings.

A review of the log report, dated November 28, 2006, which you submitted in compliance with the permit conditions, indicates that four borings were drilled. · The permit did not cover the two additional borings. Our records indicate that we did not receive notification at the time of drilling for additional work nor were the required additional fees submitted within 48 hours of the drilling. Therefore the two additional borings were done without a permit.

A 1 00% investigative fee is due under County of San Diego Ordinance (Section 65.1 07 .f) for work, which requires a permit that is done without a permit, or for work that is not in compliance with the permit conditions.

The fees fora permit which would have included the two additional borings, is $100.00. The 100% Investigative fee due is $100.00. You have already submitted fees of $100.00. Therefore an additional $100.00 is due. Submit the fees by December 15,2006.

Please call me at (619) 338-2497 if you have any questions regarding this letter.

Sincerely,
·Amelia n · nmental Health Technician
Monitoring Well gram/Site Assessment and Mitigation Program cc: Tony Sawyer, SAM Internal Enforcement Committee
Karl Miller, MMC Energy
"Environmental and public health through leadership, partnership, and science" •
IT #LMON104313
A.P.N. # 629-062-04-00
EST#NONE

COUNTY OF SAN DIEGO

DEPARTMENT OF ENVIRONMENTAL HEALTH

LAND AND WATER QUALITY DIVISION

MONITORING WELL PROGRAM

GEOTECHNICAL BORING CONSTRUCTION PERMIT
SITE NAME: CHULA VISTA ENERGY PLANT
SITE ADDRESS: 3497 MAIN STREET (S SIDE ·aF MAIN-ST. & W OF ALBANY AV) SAN DIEGO, . _,.-""-- -..........' ' -. CA 92154 / /./ . . I //, . . ,/ /"\•\ \, p "-.... "·-,
PERMIT FOR: TWOGEOTECHt:lltAL SOIL BORINGS/// /;0 "-, .. ' PERMIT APPRov'AL 11, 2oo6 ....... / >< >_.
/ " I v "'-...\/ ---- F • I / . '-./// / i / / " .

PERMIT EXI?IREs:oN: ·a. 2oo7 ; >;./ "<· .. · 'i_J1 ·\ · I (/':'/ / '" ..... ,,_/ /
MMC ENERGY . ', '\ (__ _· ·_ \ \
.( '.I / \ \ .___.,- _/
· .... ·, / \ 0/'. -.. \
! /
PERMIT CONDITIONS: /
\
• I •
'l \; /'-.._/

1. 2.

3. 4.

5. 6.

I \ 'J ..-----.
'Note that direct push borings· are not from MWP to submit a detaifedllog for each boring as described-in the SAM manual ;_AIL borings must be_ sealed from the bottom· of the ,boring to thJ with an ( appro_vE!ct sealing materi?JI as spEl_cified in _California Well. Standards. Bulletin 74-90, Part Ill, ' Drill cuttings are not an acceptable fill j . j .
\All borings .. e.properly destroyed in hours of drilling.,/ . -- / · I ' • . ' . . . - . ') '
R.lacement of imy sealing _at a 'depth greater be/ done using the tremie : ; : ;\ i \ j.
· / ' ' . I · t ' · l ,- "-
This. work.is not connected to any known· unauthorized release'of·hazardous substances. Any contaminatiOn foGnd in.the course of drilling 'and sampling rilGst .. be reported to DEH. All water and soil resultiniJ> from the activities• covered by this permit must 'be; managed, stored and disposed, ot< .. as/ ·specified-. 'in : ihe: !sAM_- Manuali in'·' Section 5, II, E- 4. (http://WwW.sdcountv.ca:gov/dehllwg/sam/manual guidelines.html). In addition, drill cuttings must··be properly-handled- and disposed in compliance with the Stormwater Best Management Practices of thetlocal jurisdiction. ! / ·
""'-,,_ _,_.. I '-. _..,) ,
, -... __, '- I --·"'- .· .

Within 60 days of completing work, su_bmlt a .well/boring construction report, including all well and/or boring logs and laboratory data to the Well Permit Desk. This report must include all items required by the SAM Manual, Section 5, Pages 6 & 7.

7. This office must be given 48-hour notice of any drilling activity on this site and advanced notification of drilling cancellation. Please contact the Well Permit Desk at 619) 338-2339. .
./ • fw--1,
PERMIT APPLICATION TJ{p

GROUNDWATER

AND VADOSE MONITORING WELLS

AND EXPLORATORY OR TEST BORINGS
//Olf.313
A. RESPONSIBLE PARTY

OFFICE USE ONLY
PERMITLMON # I C>lf-313
SAM CASE Ylfb# tvt>.tJ&::.

DATE RECEIVED: IJ/CJ?qfp/p
FEE PAID: -4/> ;;223 • Fb
CHECK# I m> 7 53
Phone ..l..J1A11 D4
(The person, persons, or company responsible for the construction, maintenance, and destruction of the proposed borings and/or wells.) Mailing Address 1<P qo1 Zip__l_!®.4-
Contact WI Phone .1Jl.:fl11 Dt!Ob Ext. /

15. SITE ASSESSMENT PROJECT NUMBER- IF APPLICABLE# .J::li.!.

C. CONSULTING FIRM _!illLI.jO ArJb I-\Obil6
Mailing Address 5110 JitLIPf"lt-1 tt;> City SI\N I>IEI5l> State _QA Zip Registered \111\fJ frtlDl>Wl 'Z-13(, Cfftr"
Contact Person __ 1"!-1 ttJA Ak Phone __ B1/, lo«5Exi. lz:Pil Fax 8513 67(, t}(,Ob D. DRILLING COMPANY Ji:ru&tHN, fAHAtJ /(h{)(J. C57# (p GZ.8(;, Z Contact Name __fb_C+I a Ci>U.Yltf(?je.

Mailing Address N. L6J.IDN Si 4 !56l16 City State f.}. Zip qz_g{p1 Phone 1.!A::JiD 6tj 11 Fax _1!±_UO
E. CONSTRUCTION INFORMATION

TYPE OF WELLS/ MATERIALS TO BE USED PROPOSED CONSTRUCTION BORINGS TO BE Estimated groundwater depth: ..1!.._ CASING SEAUBORING CONSTRUCTED BACKFILL Estimated depth of boring I CTb ft . ./ # Not Applicable _!__ Cement D Groundwater Concrete Q
- Type __ Cement & Bentonite
0Vadose Gauge __ D Sand-Cement surface seal
- Diameter -- D Bentonite Annular seal --to ---
_I
Well Screen Size 0 Other Bentonite _3_ to -lbtzaiM
1/..MJ:. -- ...£___/ transition seal
·iii ER OF WELLS Filter Pack -- Borehole diameter
TO BE DESTROYED Filter Pack __ to_
tJlt>r
Drilling Method Perforation to
D 0Auger @Air Rotary -- --
0 Mud Rotary Other NOTE:

D Percussion Attach a well construction diagram
for wells with multiple completions
I agree to comply with the requirements of the current Site Assessment and Mitigation Manual, and with all ordinances and laws of the County of San Diego and the State of California pertaining to well/boring construction and destruction.

DRILLER'S SIGNATURE DATE o4lu{oli
//
/
Within 60 days of completion, I will furnish the Monitoring Well Permit Desk with a complete and accurate well/boring log. I will certify the design and construction or destruction of the well/borings in accordance with the permit application.

I RG/RCE/CEG SIGNATU j{JV \.. DATE q Z 9-. C>L
I \
1/._24 Nfr VPJ61· fh .. c./. T-- fP/2,4- IV'PT v 1\/a . .t DEH:SAM-9060 (Rev. 07/06) Page 1 of4 /1/eH.) ?111<- Y County of San Diego u
f>fra:f . Department of Environmental Health
/
• PERMIT APPLICATION
·GROUNDWATER

AND VADOSE MONITORING WELLS

AND EXPLORATORY OR TEST BORINGS
SAM CASE Y/N # ----­
DATE RECEIVED:-----­
FEE PAID:--------
CHECK# ___________ _
A. RESPONSIBLE PARTY __M.M_ (, Phone UZ. till 0 t1 lfO
(The person, persons, or company responsible for the construction, maintenance, and destruction of the proposed borings and/or wells.) MailingAddress tlOl City tJew Zip 1Dml4-
Contact Phone 'UZ.!j11 OC/Db Ext._____!::__ Fax_____!::__ B. SITE ASSESSMENT PROJECT NUMBER- IF APPLICABLE# _iliA C. CONSULTING FIRM
MailingAddress 6110 W City .SAN l>ltbD Statefl.t.r Zip
Registered ProfeCJfnal JDtJA 1111\N bm>l>IYI #
Contact Person JZ __ (, 101x:> I till®
D. DRILLING COMPANY TRI-COUNTY DRILLING. INC. C57# 547737 Contact Name Tim Duddie
Mailing Address 9631 Candida Street City San Diego State CA Zip 92126- Phone 858-271-0099 Fax 858-271-0233
E. CONSTRUCTION INFORMATION
. TYPE OF WELLS/ MATERIALS TO BE USED PROPOSED CONSTRUCTION BORINGS TO BE CASING SEAUBORING Estimated groundwater depth: 1.,o ft.

CONSTRUCTED
Not Applicable ./
BACKFILL Estimated depth of boring _A:Q_ ft. # Cement
D Groundwater Concrete Q
- Type __ Cement & Bentonite
Gauge __ D Sand-Cement surface seal
-
Boring ..L Diameter -- D Bentonite Annular seal --to -- D Other Well Screen Size D Other Bentonite _2_ to -
£1 -- transition seal -- Filter Pack Borehole diameter NUMBER OF WELLS -- TO BE DESTROYED Filter Pack --to --
Drilling Method .

Perforation
tJlli
to
D D Air Rotary -- --
D Mud Rotary D Other NOTE:

D Percussion Attach a well construction diagram
for wells with multiple completions
1 agree to comply with the requirements of the current Site Assessment and Mitigation Manual, and with all ordinances and laws of the County of San Diego and the State of California pertaining to well/boring construction and destruction.

DRilLER'S DATE 061\U /cr1a
Within 60 days of completion, I will furnish the Monitoring Well Permit Desk with a complete and accurate well/boring log. I will certify the design and construction or destruction of the well/borings in accordance with the permit application.

PG/RCE DATE us ok.
-"\ ......