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0 HOLZ <br /> RINI6ER COMPANY,INC. <br /> To: John Brock, Environmental Engineer, E.P.A. February AEIVED <br /> John Schofield, Enforcement Officer, E.P.A. <br /> Aris Cacapit, Environmental Health Specialist,SJCEHD <br /> Subject: Review of Inspection Items January 9, 2014 FEB 0 5 2014 <br /> ENVIRONMENTAL <br /> Gentlemen, HEALTH DEPARTMENT <br /> Following is a review of the progress and forward plans that Holz Rubber Co. Inc. has made concerning the <br /> items of discussion as a result of the inspection at our facility on January 9, 2014. <br /> Waste Determination <br /> --We are in the process of developing a disposal procedure for "non-empty" aerosol spray cans. This program <br /> will include the use of a suitable container for any of our on-site storage and an appropriate training program <br /> for all of our employees.The training program will cover the storage requirements of non-empty aerosol cans <br /> in Flammable Storage Cabinets only, not on wooden shelving, when not in use; the definition of an empty <br /> container; and other appropriate items for Universal Waste handling. <br /> --Flammable Storage Cabinets...for ease of identification, each cabinet in our facility will be numbered <br /> according to its location and a general inventory list posted on each cabinet. Appropriate signs will also be <br /> attached to each cabinet as a reminder to employees that storage of material on top of a FSC is not allowed <br /> (Ref. Picture "FSCSign"). All material presently stored in each of our FSCs is being verified for appropriate <br /> labeling. We are also reviewing all materials to identify any obsolete items; any of these found will be disposed <br /> of properly. <br /> Open Hazardous Waste Container <br /> The collection drum for our Hazardous Waste, Flammable Liquid, has been properly labeled as before but the <br /> label is now visible. Additionally, a new funnel, to replace the funnel that would not seal properly, has been <br /> installed (Ref. Picture "Waste Drum Funnel"). There is also a posting in the area to remind employees that the <br /> lid of the funnel is to remain closed and latched at all times when not in use. <br /> Grinder Waste Labels <br /> All containers containing Hazardous Waste grinder dust have now been properly labeled, adding the "Solid" <br /> and "Toxic" check boxes to those that previously did not contain that language. We will also begin using labels <br /> as supplied to us by Safety Kleen to insure that proper language is contained on all Hazardous Waste <br /> containers on site. <br /> Universal Waste <br /> --The used battery container has been labeled properly as"Universal Waste". <br /> --The fluorescent light fixtures that were located in the Supply Room were not waste, but rather, spare parts. <br /> The tubes have been removed from the fixtures to eliminate a potential breakage issue; the metal <br /> fixtures/ballasts that remain continue to be stored in the same area with signage as shown in Picture <br /> "LightFixtures", noting that fluorescent tubes are no longer allowed to be stored in the area. <br /> Waste Oil <br /> --Our Waste Oil accumulation area has been cleaned and organized, including the containment pallet. <br /> Additionally, the Waste Oil drum in the area has been properly labeled (Ref. Picture "WasteOilDrum"). <br />