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Summary of list Violations and Responses <br /> Upon reviewing the inspection report from the Environmental Health Department's inspection <br /> on October 4, 2013, STI has noted that we needed to improve our hazardous waste disposal <br /> tracking and record keeping. <br /> STI has taken the following steps to assure that all disposal of hazardous waste, consolidated <br /> waste and recycled universal waste are consistently tracked and records kept readily available <br /> onsite for three years: <br /> 1. STI has contracted with Evergreen Oil Inc to assist in our proper disposal of hazardous and <br /> universal waste. <br /> 2. STI has developed a team of employees who are assigned to manage and track in a <br /> centralized location hazardous waste disposal manifests and universal waste and recycled <br /> universal waste bills of ladings for consistent waste disposal tracking ready availability for <br /> review. <br /> 3. STI has contacted with a WGR Southwest Inc to assist STI's team with developing its <br /> hazardous waste management program. <br /> 4. STI developed a SPCC plan (see enclosed) as part of its hazardous materials management. <br /> 5. The Plant Manger, Maintenance Supervisor, and assigned employee have attended the <br /> County's CUPA Hazardous Waste Management class on October 23, 2013 to better <br /> understand proper hazardous waste management. <br /> The following items are STI's response to the violations listed on the report for the <br /> Environmental Health Department's inspection on October 4, 2013: <br /> 108. (Repeat) Sandblast waste from the outdoor sandblaster unit, which had been previously <br /> observed in 2011 Routine inspection, still requires hazardous waste determination. A sample has <br /> been collected by the EHD during this inspection and a split sample offered to generator. <br /> Generator shall make hazardous waste determination of the waste and manage the waste <br /> accordingly. Immediately make a hazardous waste determination of the above wastes and <br /> manage each accordingly, or dispose of the waste as hazardous waste in accordance to California <br /> Code of Regulations (CCR) Title 22. In addition, hazardous waste properties and size of metal <br /> particles must be determined before they can be recycled as scrap metal. Hazardous metal <br /> particles 100 microns or smaller cannot be recycled but must be handled as hazardous waste. If <br /> the waste is determined to be a non-hazardous, please submit evidence (i.e. third party laboratory <br /> testing results) supporting such a determination to EHD. Submit a statement and supporting <br /> documentation explaining how this waste was managed by 11 /4/2013. <br /> Thank you for confirming during your telephone conversation with our WGR Southwest Inc <br /> consultant Aaron Ortiz on Thursday October 31, 2013 at 11:15 am that while STI's sandblast <br /> waste has been determined by the County to be non-hazardous, there may still be disposal <br /> concerns. We appreciate your assistance by looking into any disposal concerns the County Solid <br /> Waste Division may have and letting us know your recommended appropriate disposal options. <br /> We also greatly appreciate and look forward to receiving your sandblast waste analytical <br /> laboratory report you agreed to send us. <br /> 122 & 125. (Repeat) Copies of hazardous waste disposal records for 2011 were not found on site. <br /> Hazardous waste generators shall retain copies of all manifests signed off by the disposal facility <br /> and all receipts used in a consolidated manifesting procedure on site for three years and have <br /> Page 2 of 4 <br />