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VI. HAZARDOUS WASTE ACTIVITY DESCRIPTION: LMT generates two waste streams from its rack finishing process (Conveyorized Paint with Water Curtain Operation). It is during the finishing process that waste water and paint sludge are generated. The paint sludge and water are separated in two ways: 1) By on line micro separator and 2)by using 5 Q ti ene tank located below the wash booth. During the Conveyorized Paint with Water Curtain Operation the clean racks are hooked onto a conveyor belt which passes in front of the water curtain. As the rack passes in front of the water curtain,a workman sprays the rack with paint. Next the rack travels into an oven to achieve the baked on finish. The excess paint from spraying is caught in the water curtain and is separated from the on-line-separator in operation. The waste water is discharged to the city sewer; under the City of Lodi Permit. Next the sludge is mixed with an absorbent material to dewater,then placed in fifty-five (55)gallon drums,and shipped as hazardous waste. In 1989,LMT generated 35.6 tons of paint sludge waste. This waste was hauled by B.O.R. Industries, (P.O. Box 86) 2505 Rice Avenue, West Sacramento, California to Beatty, Nevada. LMT generates 1,1,1, Trichloroethane from the painting of metal supports for portable school buildings. The 1,1,1, Trichloroethane is a paint ingredient, used as paint thinner, and as a cleaning solvent for spray nozzles. LMT generated 3.25 tons of paint dust in 1989. This dust was hauled by B.O.R. Industries to Beatty, Nevada as hazardous waste. The liquid solvent waste of.2 tons was hauled by B.O.R. Industries to Omega Recovery Service of Whittier, California for recycling. LMT also generates waste oil from repair and operation of equipment. The oil is hauled for recycling by All American Oil, P.O. Box 625, Pleasanton, California 94566. VII. VIOLATIONS: Violations will be addressed in the "Report of Violations and Schedule of Corrections". VIII. OBSERVATIONS: Mr. Hunt and I arrived at LMT at approximately 11:00 a.m. We identified ourselves and asked to speak to the appropriate hazardous waste management person. Mr. Hunt and I were escorted to the office of the plant supervisor, Dalton Beitz. Mr. Hunt and I introduced ourselves to Mr. Beitz and explained the nature of our inspection. Mr. Beitz identified himself by card and started to explain the operation of LMT. Mr. Beitz was very interested in hazardous waste minimization. Mr. Beitz told Mr. Hunt and I that LMT planned to evaluate its paint waste stream to determine it's hazardous characteristics. Mr.Beitz stated LMT had already modified their standard rack finish to use a less hazardous water based paint. Mr.Beitz informed Mr. Hunt and I that he had installed a micro separator in 1989 giving him an on- line process for separating waste water and paint sludge during the standard rack finish process. Mr. Hunt and I advised Mr. Beitz that a variance would be needed for on site treatment. 3