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Alleged Violations <br />Compliance <br />Updates and Clarifications <br />Re uested By County <br />102 <br />CCR <br />Failed to <br />Once a material becomes a waste — meaning it is no <br />66262.11 <br />determine if a <br />longer used in the production process — the facility <br />waste is a <br />makes the proper waste determination. <br />County requested precise date that <br />hazardous waste <br />production stopped. <br />The wastes are properly containerized, labeled, and <br />managed for disposal by a DTSC licensed hazardous <br />Production ended on October 18, 2016. <br />waste hauler. (See Exhibit J - Photos of Hazardous <br />Waste Container and Management Area). <br />County wants details on how waste <br />determinations were made for each <br />Many of the "waste streams" identified in this <br />waste stream. <br />inspection report were from the production area and <br />had not yet become wastes. <br />' <br />During normal production time, these materials would <br />Boretech_WasteMa <br />n ifest Matrix-04191f <br />be swept up and reused. <br />Several of the waste streams identified are not <br />Attached spreadsheet and manifest <br />hazardous waste, such as the white detergent powder <br />documents provide the requested <br />as it has a pH less than 12.5, the tubiwet and the Pure <br />chlor and absorbent, the waste oil with metals, the <br />details. <br />I e <br />sludge from process area 2 and the wastewater filter <br />Exhibit 102 Wastes Exhibit 102 Wastes <br />press filter cake/gray sludge. <br />2 and 3_[SDs]-[SDS]10 and 11_[SDS]-C <br />I a <br />The oil solids and absorbents, the tubiwash are <br />hazardous wastes once their role in production is over. <br />Exhibit 102_Wastes Exhibit 102_Wastes <br />4 and 5_[SDS]-[SDS]6, 8 and 9_Borete. <br />All future wastes will be properly managed at the time <br />19 a <br />of generation. As applicable, generator knowledge of <br />Exhibit 102 Wastes Exhibit <br />waste will be applied to satisfy hazardous waste <br />12-14_(BORETECH) C102_manifests_0171• <br />profile requirements. If generator knowledge cannot <br />be accurately applied to a waste, then analytical <br />