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Mv <br /> NOV 2 6 2008 <br /> To: Muniappa Naidu ENVIRONMENT HEALTH <br /> Subject: Response to 10-23-2008 visit <br /> PERMIT/SERVICES <br /> Hello Muni, here is our response to your visit last month I trust these responses <br /> will be satisfactory, please let me know if you need additional input or if you have <br /> any other questions or concerns, Thanks <br /> #1. (#16 on your audit form) liquid was present in all three of the secondary <br /> containers used to contain spills from the 55 gallon drums that we store oils and <br /> hazardous waste in. <br /> Corrective Action Status: The three containers have been cleaned, please see <br /> attached photos. <br /> #2. (#20. on your audit form) A drum containing used oil lacked the proper label <br /> for hazardous waste. The labels should have the following information: The word <br /> Hazardous waste, the name and address of the generator (Amtex), the content, <br /> physical state, Hazardous properties and the accumulation start date. <br /> Corrective Action Status: Proper Hazardous waste labels have been placed.on <br /> each barrel and the correct or appropriate information has been recorded. <br /> #3. (#21. on your audit form) The facility had a 55 gallon drum filled with used <br /> absorbent pads, according to CCR regulations the container must be left closed <br /> at all times except when adding or removing hazardous waste from it. <br /> Corrective Action Status: Temporary signs were placed on the disposal barrels <br /> and the lids were placed on the barrels, the long term action is to revise & control <br /> disposal procedures and posts a laminated copy in the storage area and conduct <br /> departmental training for the maintenance technicians. See attached photos. <br /> #4. (#22 on your audit form) A box of used fluorescent tubes was dated <br /> 09/20/2007 and has been stored for longer than one year, You requested that <br /> this waste be disposed of and a receipt submitted by 11/23/2008. See attached <br /> Clearwater Environmental Invoice. <br /> Corrective Action Status: A waste Hauler was contacted and picked up this <br /> waste on 11/06/2008 at that time received a new disposal container and like item <br /> #3. above the procedures were revised and posted and the weekly <br /> environmental audit will be modified to require specific check points for labeling <br /> and storing universal waste. <br /> #5. ( #90. on your audit form) The facility lacked an emergency Coordinator, <br /> You wanted to see specific names on an emergency contact list and you <br /> provided me with a copy of a form. <br /> Corrective Action Status: I made small 4" X 4" laminated cards with the <br /> information that you requested and we posted them next to the various <br /> telephones located on the production floor. I basically copied the form that you <br /> supplied us. See the attached copy. <br />