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o. Tank and/or Containment Certifications: AIT could not provide tank integrity and secondary containment certifications for the Permit by Rule treatment unit at the time of the inspection. On December 29, 2000, DTSC received an update on what AIT is doing to come into compliance with tank integrity and secondary containment. (See December 22, 2000 letter to DTSC regarding Notice of Compliance Certification) p. Air Board Permits: Did not review. q. Variances: Not applicable. r. Recycling Records: Did not review. s. Other: IV. NARRATIVE OF OBSERVATIONS/DISCUSSION WITH OPERATOR On November 28, 2000, at approximately 0920 hours, Michael Kith of San Joaquin County Environmental Health and Robert Brushia, Steven Binning, and I representing DTSC arrived at the Advanced Interconnect Technologies (AIT). We were met by Mr. Chris Colbert, Anodization Engineer ll. We introduced ourselves and I explained to Mr. Colbert the purpose of our inspection. I asked for Mr. Colbert's permission to conduct the facility inspection, review records, and take photographs. Permission was granted by Mr. Colbert. We sat down in the conference room and I explained that the inspection would be conducted in two parts: (11 a facility walk through, and (2) a document review. AIT is a circuit packaging manufacturer. Hazardous waste that AIT typically generates are degreasing solvents (i.e. Ensolv), metal sludges, waste filters, corrosive liquids, and spent resins. After an overview of what goes on at the site and the hazardous waste generated, we proceeded with the facility walk through. We began our walk through at the stamping and anodization process area. Mr. Colbert mentioned that in 1999 they started using aluminum cathodes. The change from lead cathodes to aluminum cathodes has drastically reduced the lead levels in the wastewater. Mr. Colbert stated that they would not be looking at the possibility of changing to a lower tier because they are also exploring the idea of manufacturing copper components. We observed a satellite accumulation area with 55 -gallon containers for spent ensolv, waste flammable liquids, spent ensolv filters, and waste filters. The hazardous waste labels on the satellite accumulation containers were missing the hazardous waste properties and physical state of the waste (see attached SOV). The 55 -gallon container of waste filters was not closed while being stored in the accumulation area (the ring was not secured to the container). All satellite accumulation containers observed in the stamping and anodization process area were within storage time limits. We proceeded outside to the wastewater treatment unit located on the north side of the building. This treatment unit is authorized to treat corrosive and metal bearing wastewaters under Permit By Rule. The entire treatment unit area is covered by an over hang. The treatment unit appears to have secondary containment; however, Mr. Colbert could not verify if the treatment unit tanks and secondary containment met tank integrity and secondary containment requirements (see attached SOV). We observed one 55 - gallon container of absorbent waste in the treatment unit area. All labeling requirements were met except for the hazardous waste properties and physical state of the waste (see attached SOV). We also observed ion exchange resin bead columns for deionizing water in the wastewater treatment area. The caustic and corrosive solutions used for regenerating resin beads do not need authorization for neutralizing these solutions due to an exemption for this specific treatment process. We proceeded to the hazardous waste storage area located just north of the wastewater treatment unit. This area is not covered by the over hang. Though not required by statute or regulation, AIT has the hazardous waste containers sitting on a grade over secondary containment. I mentioned to Mr. Colbert that it is great that they have provided secondary containment for the hazardous waste containers. However, DTSC (3/95) Page 3 of -�,}