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• 0 <br /> E. Section 25201 (a), Division 20, California Health and Safety Code. At the time of inspection, <br /> Circuit Works did not have a Treatment, Storage and Disposal (TSD) permit from Department of <br /> Health Services for batch treating their hazardous liquid waste stream prior to discharge into the <br /> public sewer. <br /> VIII. OBSERVATIONS <br /> Kasey Foley and I arrived at the Circuit Works facility at approximately 10:30 a.m. We identified <br /> ourselves to the receptionist, and asked to speak with the person responsible for monitoring their <br /> hazardous waste. <br /> Ms. Foley and I were then introduced to Dr. Luther Vaaler who is the wet processing engineer for the site. <br /> Dr. Vaaler, Ms. Foley and myself began the inspection in a conference room. Dr. Vaaler began by <br /> explaining how the circuit boards are manufactured, and how the different waste streams are derived from <br /> the different manufacturing processes. (See Section VI, Hazardous Waste Activity Description). <br /> Dr. Vaaler explained the waste water treatment systems as follows: The waste utilized in the industrial <br /> processes are separated into: metal bearing and nonmetal bearing wastes. The metal bearing liquid waste <br /> is treated through a "batch treatment process". Mr. Vaaler stated that a metal bearing sludge is generated <br /> in this treatment process. The metal bearing sludge generated is manifested offsite as hazardous waste. <br /> The nonmetal bearing waste water or "continuous side waste" is also treated through: chemical <br /> precipitation, clarification, filtration, and pH adjustment before being allowed to flow into the sewer. Dr. <br /> Vaaler stated that these waste treatment systems were permitted by DHS. <br /> Dr. Vaaler then introduced us to Randy Rodriguez, facility operations manager, who gave Ms. Foley and I <br /> a tour through the site. We began the tour in the shipping and receiving storage area (warehouse). This <br /> warehouse contained materials used in the manufacturing of the circuit boards. No hazardous waste was <br /> found to be stored in the warehouse. <br /> We then went to the maintenance shop,where a small parts cleaner solvent tank was observed. Mr. <br /> Rodriguez explained that the waste water from the maintenance area did pass through their "continuous <br /> side waste" treatment system before being discharged to the sewer. <br /> Mr. Rodriguez then took Ms. Foley and I through the following areas on site: print room, developing <br /> area, lamination room, drilling room,wet processing area, solder cleaning room, wet processing area, <br /> quality control room, hazardous waste storage area, and waste water treatment area. <br /> The developing room (where the photographic image on the circuit board is developed and treated) <br /> contains a 1,000 gallon aboveground plastic tank containing Na2CO3 (sodium carbonate). Mr. Rodriguez <br /> indicated this liquid is used to remove the organic coating which protects the copper circuit board. The <br /> liquid waste generated in this area passes through circuit works treatment system before being discharged <br /> to the sewer. <br /> The next area we toured was the drilling room, where we observed the drilling of the circuit boards. In <br /> this area a X-ray machine is used for quality control to scan the circuit boards for defects. The staff using <br /> the X-ray machines were observed not wearing personal monitors. <br /> 4 <br />