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CUPA Findings 4� < tten Response 119. According to Mr. Mooring, hazardous waste aerosol cans and hazardous waste metals have been placed in the oily absorbent and debris hazardous waste drums. These drums have been disposed of as oily solids on the uniform hazardous waste manifests. A generator who transports, or offers for transportation, hazardous waste, shall prepare a manifest in accordance with Title 22 regulations, including the correct DOT description and the correct waste codes. Immediately make all necessary corrections and notifications with DTSC to ensure that all wastes are properly identified under the correct descriptions and waste codes. An email has been sent to the entire plant communicating that aerosols must be collected in the Universal Waste Drum in the accumulation area. Title 22 Hazardous waste training is scheduled for all employees which addresses containerizing each stream separately hence manifest line items will start to appear on future manifests as they are generated, within the accumulation time guidelines. 605. Two 55 gallon black steel drums, one containing oily solids and one containing used oil, were observed in the hazardous waste storage area with no hazardous property listed. All hazardous waste containers shall be marked with the following information: 1. the words "Hazardous Waste" 2. name and address of generator 3. hazardous properties (ignitable, corrosive, reactive. toxic) 4, physical state (liquid, solid) ,5. composition (contents) 6. accumulation start date The labels were corrected at the time of inspection. Ensure that all hazardous waste containers are marked with all the required information. Hazardous waste containers are inspected weekly and the check for hazardous properties is now listed as a reminder in the comments section in the inspection form. i R 'CRV D AUG 14 2014 ENVIRONMENTAL HEALTF9 DEPARTMENT