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2. <br />n <br />LJ <br />Page 2 -10/11/99 Alleged Notices of Violation (ContinueM <br />Lubricating Oil - The small quantity of lubricating oil noted inside the <br />auxiliary building was completely contained within the confines of the <br />building. Floor drains provided within this building likewise drain to the <br />oily water separator. <br />Neither the oil nor the TEG constituted a significant fire or explosion <br />hazard in the small quantities identified. Furthermore, de minimis leaks do <br />occur from operating equipment such as the glycol package reboiler and <br />air compressor equipment for which adequate engineering and <br />administrative controls are provided. The secondary containment is an <br />example of an engineering control and prescribed periodic walkdowns of <br />the facility by operations and maintenance personnel is an example of an <br />administrative control employed to minimize the possibility of a fire, <br />explosion or release. <br />No Hazardous Waste Manifest for unbroken spent fluorescent tubes <br />andspentdry-cell • <br />Lighting Wastes - Unbroken fluorescent lights are permitted to be shipped <br />via bill of lading to a qualified recycling facility. Please refer to the DTSC <br />guidance information provided in Attachment B. <br />Spent alkaline batteries - Spent dry cell batteries limitations) been <br />excluded from hazardous waste regulations as of January 1, 1999. The <br />new provisions are contained in Health and Safety Code Section 25216.3. <br />PG&E ships dry cell batteries from this facility by bill of lading to an <br />authorized recycling facility which exceeds the statutory handling and <br />disposal requirements contained in section 25216.3. <br />Page 2 of 6 <br />