Laserfiche WebLink
Violation#4 <br /> As mentioned in the same document, "Cleaning agents and cleaning tools used to <br /> manage oily material are properly managed and disposed as used oil or oily debris". <br /> Please explain what "properly managed" means. It is not clear if it means that the <br /> facility is handling the waste as hazardous waste. Also, explain labeling the mixture of <br /> hazardous waste (cleaning agent,fuel and oil) as "used oil". <br /> "Properly Managed"means handling and disposal of hazardous waste per State and <br /> Federal guidelines as per"Title 22 Hazardous Waste Guidelines"as stated in your <br /> summary of violations. Example; as stated in your Summary of Violations dated 6/13/08 <br /> "An oily mop and oil containers were found left to dry after being washed at the wash <br /> area". Mops are no longer used to cleanup oil, absorbent is used and that absorbent is <br /> disposed of as hazardous waste "oily debris". Oil containers are wiped out with rags or <br /> absorbent is used,those oily rags if not saturated are collected in approved metal <br /> container designed for this purpose and routinely emptied. Rags that have cleaning agents <br /> (detergent, degreasers)are also included in this container. The rags are sent to an <br /> industrial laundry facility in order to clean the rags for reuse,the laundry facility picks up <br /> weekly. Saturated oily rags are disposed of as hazardous waste "oily debris". Cleaning <br /> tools consist of rags,towels or scrapers. Rags are managed as stated above, scrapers are <br /> wiped clean with towels and oily towels are disposed of with the oily debris. 'There is no <br /> mixing of hazardous waste therefore there is no "mixture of hazardous waste". All <br /> accumulated hazardous wastes are containerized, labeled, stored, transported and <br /> disposed of per state and federal regulations. <br /> Violation#12 <br /> The area where acid is loaded onto truck is not a secondarily contained area. The <br /> pavement is sealed, cracks in that area allow acid to migrate into the soil and possibly <br /> the ground water. <br /> Although the EHD agrees that the sand blast waste was not a hazardous waste, it must <br /> still be handled and disposed of properly. The proper disposal of solid waste is regulated <br /> by the EHD. This waste can not be disposed of in a Class III landfill. Please provide <br /> documentation of proper disposal to a Class II or Class I landfill. <br /> As stated in the JR Simplot(JRS)response dated 7/30/2008, the acid truck load out area <br /> is designed to industry standards for this type of system. The area consists of specially <br /> designed acid brick with an acid resistant liner under the brick. The area is graded and <br /> sloped to a sump that is piped back to the plant for reuse. During truck loading operations <br /> if a spill were to occur or if there is wash residue from the truck load out,that liquid <br /> would be directed to the sump and sent back to the plant. There are some minor cracks in <br /> the paved area as stated by the EHD. Those cracks are outside of the designated, <br /> contained load out area. <br />