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VIII. OBSERVATIONS: <br /> Ms. Foley and I arrived on site at approximately 9:30 a.m. We met Scott <br /> Granneman, Environmental Coordinator, and were led to his office in the <br /> southwest corner of the facility near the foam production line. We first reviewed <br /> the facility records which included the contingency plan, hazardous waste <br /> manifests, and emergency plan. No hazardous waste personnel training records <br /> were available. Mr. Granneman is currently compiling a hazardous waste training <br /> program which will comply with Title 22, California Code of Regulations, Chapter <br /> 15, Article 2, Section 66265.16. We noted the training violation and also noted <br /> that an agreement of contract with an environmental cleanup company was not <br /> included in the contingency plan. When we were reviewing hazardous waste <br /> manifest, it was noted that four manifests did not have Land Ban certificates <br /> attached. We also discovered that the U listing for methylene chloride was <br /> incorrect; the number should be listed as U080. After reviewing the hazardous <br /> waste manifests, we asked to inspect the waste oil, waste oil filters (if not <br /> recycled), and safety clean disposal recycling receipts. These records were <br /> unavailable for inspection. <br /> We then proceeded on the site tour. First, we inspected the foam production, <br /> storage, and cutting areas. A drum used to store methylene chloride waste at the <br /> point of generation was not closed. We then proceeded to the maintenance shop <br /> in the middle of the complex. Hazardous waste is stored at this point of <br /> generation, but no decontamination equipment is readily available. <br /> We continued through the storage and foam recycling area to the hazardous waste <br /> storage area where we found two unlabeled drums containing hazardous waste. <br /> The chemical storage areas and truck maintenance shop were next on our <br /> inspection. Four drums of waste oil were unlabeled. Receipts of recent pickups <br /> by Refinery Services could not be inspected so accumulation start dates could not <br /> be verified. The drums were also found to be open. Behind the maintenance <br /> shop, a barrel of paint/solvent waste was open and unlabeled. A small amount of <br /> paint had been spilled on the ground. <br /> We concluded the site inspection with an inspection of the underground tank. An <br /> underground storage tank inspection report was sent under separate cover. <br /> We noted that the past violation from the PHS-EHD (August 22, 1990)inspection <br /> (manifest copies were not sent to CAL EPA Department of Toxic Substance <br /> Control) had been corrected. Another violation noted in 1989 was the lacking <br /> waste oil receipts. This continues to be a problem, but Mr. Granneman assured <br /> me that the waste oil is disposed of properly by Refinery Services. <br /> �4 <br />