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After leaving the drilling area we entered the wet processing area, containing over SO vats of differing <br /> liquids used in the cleaning, etching, stripping and enhancing of the circuit boards. Each circuit board is <br /> dipped from vat to vat. There was considerable spillage of liquids noted, as these circuit boards are <br /> transferred from one vat to another. The spilled material passes through the spaces between the planks on <br /> the floor to a subfloor which according to Mr. Rodriguez is resistant to the liquids it contains. Mr. <br /> Rodriguez stated that the liquids passing to the subfloor flows to a pipe traveling directly to the liquid <br /> treatment system just outside the building. <br /> After leaving the wet processing area we went outside to the waste treatment area. The waste treatment <br /> area has a complex system of tanks, pipes and filtration systems surrounded by an 18"cement berm. <br /> Next to the waste water treatment system was the hazardous waste storage area containing numerous <br /> drums on pallets, directly above the asphalt surface. This area had a surrounding 10" asphalt berm. This <br /> berm allows the drainage of any spilled liquids in the hazardous waste storage area to flow into a sump. <br /> Mr. Rodriguez stated that this sump,when filled,would trigger the pumping of the liquids back into the <br /> water treatment system. <br /> Several of the barrels in the hazardous materials storage area containing hazardous waste lacked waste <br /> accumulation start dates. Other than a few unlabeled barrels, most containers containing product and <br /> wastes were segregated. Barrels were categorized and identified with labels indicating contents, and the <br /> date barrels were filled. <br /> After Ms. Foley, Mr. Rodriguez, and I toured the hazardous materials storage area, we quickly toured the <br /> quality control areas where finished circuit boards were tested and inspected. <br /> IX. DISCUSSION WITH MANAGEMENT: <br /> We then returned to the administrative office to take a look at Circuit Works permits and training logs <br /> relating to the storage, treatment and handling of hazardous waste. Circuit works has a current permit <br /> with the City of Stockton Municipal Utilities Department (expires 12/31/90). This permit regulates specific <br /> waste water discharge limitations (See Attachment I). This permit also regulates the discharge of waste <br /> waters from the pre-treatment system used by Circuit Works. <br /> Circuit Works does not have a treatment, storage or disposal (TSD) permit with the State of California, or <br /> a variance from the State of California for the treatment of their liquid waste stream. <br /> I asked Dr. Vaaler about the submittal of a biennial report to the State of California regarding Circuit <br /> Works hazardous waste generation activities. Dr. Vaaler was unaware of any biennial report filing. <br /> Mr. Rodriguez addressed the issue of staff training for employees dealing with hazardous wastes. He <br /> stated that all employees received training specific for their jobs as it related to the management and <br /> handling of hazardous waste. However, documentation of a formal training program did not exist. <br /> After reviewing the permits and hazardous waste records, I asked Mr. Rodriquez and Dr. Vaalar if they <br /> had any questions. I told Mr. Rodriquez that our office would mail him the inspection report and if he <br /> had any questions to call me. At this time we completed our inspection and left the facility. <br /> DH/CH:kf <br /> 5 <br />