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• 0 <br />catalyst in the soldering of the circuits on the circuit <br />board. <br />VII. REPORT OF VIOLATIONS: <br />1. Unlabeled hazardous waste containers and incomplete <br />labels on hazardous waste containers. <br />2. A communications system was not available for providing <br />emergency instruction to personnel at the hazardous waste <br />storage area. <br />3. The fiber bag (super sack) containing hazardous sludge <br />was open to the environment and unlabeled. <br />4. Absorbent soaked with used oil is being disposed of as <br />solid (non hazardous) waste to a landfill. <br />5. A hazardous waste manifest requiring a L.D.R.(Land <br />Disposal Restriction) notification form did not have one <br />attached. <br />5. The chemical spill contingency plan did not include <br />accurate information on the alternate emergency <br />coordinator, and did not include day and night addresses <br />(including phone numbers) for the emergency coordinators. <br />7. Hazardous waste treatment is occurring on site without a <br />variance granted by CAL -EPA DTSC. <br />VIII.OBSERVATIONS: <br />Alan Ito, Eric Trevena and I began our inspection with an <br />introduction to Roy Mora, Hazardous Waste Operations <br />Manager, Sean Howard, Hazardous Materials Manager and Barry <br />Nicholson, Safety Engineering Manager. We exchanged cards <br />with the Circuit Works representatives. I informed these <br />gentlemen from CWI that we were here to complete a routine, <br />annual hazardous waste generator inspection. We were granted <br />permission by Mr. Mora to do the inspection. <br />our inspection began at a conference table in the CWI <br />facility. At the conference room table, Mr. Mora described <br />the types of waste generated at this site. Mr. Mora also told <br />us how these wastes are generated, processed, and stored. <br />After Mr. Mora described the waste streams, he provided each <br />of us a facility map to aid us in our facility inspection. <br />Sean Howard directed our tour through the warehouse. No <br />hazardous wastes were located in this area. <br />9 <br />