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IX. <br />reports. The following items were observed: <br />1. A total of 549 tons of hazardous waste was generated in <br />the calendar year of 1990. <br />2. Mr. Mora showed me a letter written to DHS requesting a <br />variance for the treatment of hazardous waste on site. <br />The letter was dated August 11, 1987. The variance <br />requested by Circuit Works was unavailable. <br />3. I observed at least one manifest (manifest #88329765 for <br />an F-001 waste) which did not have a land disposal <br />restriction (L.D.R.) notification attached. After Mr. <br />Nicholson looked through several of the 1990 manifests he <br />said that several manifests requiring L.D.R. <br />notifications were lacking. Mr. Nicholson asked Mr. Ito <br />how to resolve this issue. Mr. Ito told Mr. Nicholson to <br />send a letter to CAL EPA informing them of the manifests <br />which they had where L.D.R. notifications were not sent. <br />Mr. Ito also informed Mr. Nicholson to obtain L.D.R. <br />notification copies where waste was manifested off site <br />with L.D.R. notifications but the L.D.R. notification <br />copy was not maintained on site. <br />4. Mr. Ito reviewed the contingency plan and noted that the <br />day time and night time addresses did not include the <br />emergency coordinator. Mr. Mora also stated that the <br />alternate emergency coordinator was no longer working <br />with CWI. <br />DISCUSSION WITH MANAGEMENT: <br />Regarding hazardous waste minimization, I had Mr. Mora compare <br />their Board of Equalization hazardous waste quarterly report <br />for the second quarter of 1990 to the second quarter of 1991. <br />Mr.Mora stated that sales were lower for the second quarter of <br />1991 than during the second quarter of 1990. Mr. Howard, <br />after listening to this comparison, stated that he believed <br />that the higher tonnage manifested off site during the second <br />quarter of 1991 was due to the higher water content in the <br />filter cake this year. <br />Mr. Ito informed Mr. Mora, Mr. Howard and Mr. Nicholson that <br />waste minimization requirements would be required by law <br />beginning next year sometime. Mr. Mora told us that CWI was <br />working toward waste minimization through changing the plating <br />technologies, and treatment strategies, but that it was <br />difficult. Mr. Mora stated that the major difficulty with <br />streamlining the processing and treatment strategies was <br />employee turn over. <br />I then told Mr.Mora, Mr. Howard, and Mr. Nicholson of the <br />8 <br />