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4 .. <br /> IV. BACKGROUND: <br /> On March 2, 1988, PHS-EHD signed a Memorandum of Understanding with the Department of <br /> Health Services, authorizing PHS-EHD to perform hazardous waste generator inspections in San <br /> Joaquin County. <br /> LMT was identified as a hazardous waste generator in 1986. LMT was inspected by DHS,Joe Franz, <br /> on June 5, 1986. During the inspection five violations of the California Code of Regulations, (CCR) <br /> were listed as follows: <br /> 1. Section 25191 (d),(2), Division 20, Chapter 6.5, of the Health and Safety Code. <br /> Lodi Metal Tech Corporation is operating a clarifier and a paint sludge treatment operation <br /> without a permit or variance from the Department. <br /> 2. Section 66480 (a), California Administrative Code. <br /> Lodi Metal Tech Corporation disposed of waste solvent through a company called Ultra <br /> Chem. This solvent was not manifested. <br /> 3. Section 66508, California Administrative Code. <br /> Lodi Metal Tech Corporation had approximately 30, Fifty-five gallon drums of waste paint <br /> sludge and approximately 6, fifty-five gallon drums of waste solvent that had not been <br /> properly labeled. <br /> 4. Section 67105 (d), California Administrative Code. <br /> The facility does not have any training records for employees who handle hazardous waste. <br /> 5. Section 67140 (a), California Administrative Code. <br /> The facility does not have a contingency plan. <br /> A "Report of Violations" (ROV) dated July 28, 1986, was sent to LMT, Dalton Beitz, Plant <br /> Superintendent replied to the ROV in a letter dated November 12, 1986,indicating corrective actions <br /> which had been taken. <br /> At the time of the inspection (January 19, 1990) LMT was continuing in violation of items #3 and <br /> #4 as listed above. LMT applied for a variance for paint sludge neutralization on July 10, 1986. <br /> (Violation #1). LM7s contingency plan is incomplete (Violation #5). <br /> LMT permits include a waste water discharge permit from the City of Lodi and an Air Pollution <br /> permit from San Joaquin County Air Pollution Control District. <br /> V. GENERAL DESCRIPTION OF FACILITY: <br /> LMT has been located on a 12.5 acre site covering the east and west sides of south Kelly Street in <br /> Lodi since 1970. LMT designs,produces,welds and finishes steel storage systems. A second product <br /> is metal supports for portable school buildings. <br /> LM7s standard rack finish is an oven baked gloss enamel applied over an iron phosphate coating to <br /> a fully degreased,washed,and clean base metal. This process is performed on a fully integrated paint <br /> line system. <br /> 2 <br />