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IV. BACKGROUND: <br /> On March 2, 1988, PHS-EHD signed a Memorandum of Understanding with the <br /> Department of Health Services (DHS), authorizing PHS-EHD to perform <br /> hazardous waste generator inspections in San Joaquin County. <br /> LMT was identified as a hazardous waste generator in 1986. LMT was <br /> inspected by DHS, Joe Franz, on June 5, 1986. During the inspection, five <br /> violations of the California Health & Safety Code and the California Code of <br /> Regulations, (CCR, Title 22) were listed as follows: <br /> 1. Section 25191 (d),(2), Division 20, Chapter 6.5, of the Health and Safety <br /> Code: <br /> LMT operated a clarifier and a paint sludge treatment operation without a <br /> permit or variance from the Department. <br /> 2. Section 66480 (a), CAC, Title 22: <br /> LMT disposed of waste solvent through a company called Ultra Chem. <br /> The solvent was not manifested. <br /> 3. Section 66508, CAC, Title 22: <br /> LMT had approximately 30-Fifty five gallon drums of waste paint sludge <br /> and approximately 6-fifty five gallon drums of waste solvent that had not <br /> been properly labeled. <br /> 4. Section 67105 (d), CAC, Title 22: <br /> LMT did not have any training records for employees who handle <br /> hazardous waste. <br /> 5. Section 67140 (a), CAC, Title 22: <br /> The facility did not have a contingency plan. <br /> A "Report of Violations" (ROV) dated July 28, 1986, was sent to LMT. Dalton <br /> Beitz, Plant Superintendent, replied to the ROV in a letter dated November 12, <br /> 1986, indicating corrective actions which had been taken. <br /> At the time of the January 19, 1990 inspection, LMT was continuing in violation <br /> of items #3 and #4 as listed above. LMT applied for a variance with DHS for <br /> paint sludge neutralization on July 10, 1986. (Violation #1). LMT's contingency <br /> plan was incomplete (Violation #5). On the April 27, 1992 inspection, LMT's <br /> violation of an uncovered, unlabeled, hazardous waste drum was documented <br /> (Item #3 above). <br /> 2 <br />