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CUPA Findings V"" tten Response 504. The facility diagram did not include the contents for each tank. The second red-dye diesel tank stored in the tank farm was not included in the facility map. The Plan shall include a facility diagram which must mark the location and contents of each fixed storage container and the storage area where mobile or portable containers are located. It must identify the location of and mark as "exempt' underground tanks. It must also include all transfer stations and connecting pipes, including intra-facility gathering lines. Immediately update the facility diagram to include all of the required information. Submit a legible copy of the updated facility diagram to the EHD. See Appendix D to see the addition of tank 8A the second diesel tank which has been added to the facility. 505. The inventory listed in the SPCC Plan does not include the second red-dye diesel tank observed in the tank farm, and includes inaccurate capacities for one or more of the fuel tanks in the tank farm. The SPCC Plan must include the correct type of oil and storage capacity of each fixed storage container, and either the type of oil and storage capacity of each portable container or an estimate of the potential number of portable containers, types of oil, and anticipated storage capacities. Immediately update the inventory in the SPCC Plan to accurately represent the petroleum storage at the facility. See Appendix E (Table 1 Hazardous Material Storage Tank List) Figure Numbers 8 and 9 have been updated to reflect the correct volumes and 8A is the added diesel fuel tank with its correct volumes. Hazardous Waste 108. Bead blast waste is being taken back by the manufacturer during routine bead blaster maintenance without first determining hazardous properties. No hazardous waste determination has been made for the wastes generated in the laboratory, including COD waste, HPLC waste, IC waste, and the overflow/spillage from the chemicals stored in the hood. Any person who generates a waste shall determine if the waste is a hazardous waste. Immediately stop disposal of these wastes as nonhazardous, make a hazardous waste determination for the bead blast waste and lab wastes, and manage them according the Title 22 hazardous waste regulations. Metal particles 100 microns or smaller must be handled as hazardous waste if the metal is determined to be a hazardous waste. Submit a statement and supporting documentation explaining how this waste was managed by August 16, 2014. In the past the vendor for the bead blast machine took the waste beads back. The bead blast unit was empty at the time of the inspection has not been operated since. I instructed the Maintenance Lead to inform the bead blaster company representative see the EHS Manager when he/she comes back on site, and to not take back bead blast waste unless it is determined that the waste is non-hazardous. As soon as waste is generated a sample will be taken and tested for CAM 17, since it is used solely for cleaning metal parts. IC waste is hazardous and may be pH adjusted without a permit in California per the relief granted for laboratories. This waste will be returned to the process. HPLC Waste has been determined as non-hazardous so the byproduct is returned to the process. The COD waste is hazardous and is shipped as Hazardous Waste the vendor is scheduled to pick this waste stream up in the next two weeks. The hood in the lab was cleaned and the debris is collected as hazardous waste to be shipped in 4-5 months. DECEIVED AUG 14 2014 ENViRnmUlZ n a o ,_. .