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Photograph 14: <br /> 0, a <br /> OBSERVATION NO. 12:Abandoned/discarded paint, aerosol, and solvent containers <br /> observed in Paint/Coatings Storage area. Re u�ry Area of Concern:A waste generator must <br /> determine if the waste generated is hazardous waste. 22 CCR§66262.11 [40 CFR 262.11]. <br /> RESPONSE: The Company disputes that the observed paint cans and solvent containers were <br /> abandoned or discarded. To the contrary, the paint and solvent was still in use and being stored <br /> in a flammable cabinet, and therefore was not waste. With regard to aerosols, as stated in the <br /> Response to Observation No. 4, the facility's HWMP has been updated to address storage and <br /> disposal of both empty and non-empty aerosol cans. <br /> OBSERVATION NO. 13: Universal waste-lamps within the Hazardous Wastes/Universal <br /> Waste accumulation area not stored in closed, labeled containers. Additionally, lamps being <br /> managed in manner that could cause breakage. Regulatory Area of Concern: Lamps (including <br /> M003 wastes that contain lamps).A universal waste handler shall manage lamps in a way that <br /> prevents releases of any universal waste or component of a universal waste to the environment, <br /> asfollows: (1)A universal waste handler shall contain any lamp in a container or package that <br /> is structurally sound, adequate to prevent breakage, and compatible with the contents of the <br /> lamp. Such a container or package shall remain closed and shall lack evidence of leakage, <br /> spillage or damage that could cause leakage under reasonably foreseeable conditions. 22 CCR§ <br /> 66273.33(b)(1) [40 CFR§273.14(d)(1)]. Lamps (including M003 wastes that contain lamps) <br /> (i.e., each lamp), or a container or package in which the lamps are contained, shall be labeled or <br /> marked clearly with the following phrase: "Universal Waste-Lamp(s). "22 CCR§66273.34(c) <br /> [40 CFR§273.14(e)]. <br /> RESPONSE: The facility had a designated receptacle in which the waste lamps were to be <br /> placed, and employees were trained to place waste lamps in this receptacle, which was within the <br /> hazardous waste storage area. In accordance with policy,the receptacle did in fact contain waste <br /> lamps. However, despite training, it appears that one or more employees did not follow proper <br /> Company procedures. As a result of U.S. EPA's observation,the facility has retrained all <br /> employees on proper storage of waste lamps and other waste streams. Specifically, Sierra <br /> 13 <br /> 26731756v.9 <br />