COMPLIANCE INFO 2008-2010 - Laserfiche WebLink

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Statement of Corrected Actions Violation #4- Disposal or caused disposal of HW at an unauthorized point. An oily mop and oil containers were found left to dry after being washed at the wash area. A puddle in front of the wash area with an oil sheen was also observed. This procedure was changed the day of the inspection. Wash racks are only used for washing equipment that has fertilizer product residue. Any oil, grease or fuel is cleaned before wash down. Cleaning agents and cleaning tools used to manage oily materials are properly managed and disposed as used oil or oily debris. Violation #10- Failed to determine if waste is a hazardous waste. Facility is throwing metal grindings and fine metal powders generated in the electrical (ENI) shop into garbage without make determination of its hazardous properties. Also sand blast waste disposed onto the field of the paint shop. The metal grindings were sampled shortly after the inspection and according to the results they are non-RCRA hazardous waste. See attached results. Due to particle size they cannot be recycled with scrap metal as past practice. Grindings are now containerized and disposed of properly. Personnel working with this material have been trained on new procedure and instructed to not throw grindings in garbage or scrap bin. The spent sandblast abrasive was characterized as non-hazardous with testing and analytical received on February 21, 2008. See attached results. This portion of violation #10 is being disputed due to the fact that a waste determination had been performed on the spent sand blast abrasive prior to this inspection. Copies of the analytical were provided to the inspectors in order to show that a determination had been completed and the waste was deemed non-hazardous. Violation #12- Facility not maintained to minimize the release of a HW. A wet area where acids are loaded onto the trucks has a very low pH (test performed using pH paper-chart showed very low pH), Sand blast waste is spread on the ground in the paint shop area. At the time of inspection there was a small puddle at the inlet to the sump at the sulfuric acid truck load out area. The puddle was outside of the truck traffic area and well inside the acid brick containment area as designed. There was no potential of release to the environment outside of the designed containment and there was no threat to human health as stated by this violation. Consistent with industry standards and practices, this area is maintained as a secondary containment for the truck load out. In the event of a spill or leak during loading operations the secondary containment prevents a release to the environment. By maintaining a secondary containment system, the facility minimizes the potential for a release of hazardous materials to the environment.