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manufacturing process, we produced Zinc Phosphate Filter Cake, that was <br /> classified as a NON-RCRA Hazardous Waste, and we shipped that off to be <br /> recycled or properly disposed of, using an Uniform Hazardous Waste Manifest, <br /> which we retain copies of to this date. Please see response to item(#19)below. <br /> 3. (#12) 66265.31 (CCR) Facility not maintained to minimize the release of <br /> hazardous waste. <br /> # 1 —Oil spills on asphalt were noted near the Air Compressor and Product Oil <br /> Storage area. <br /> # 2—Air Compressor secondary containment is full and over flowing. <br /> Surrounding asphalt is deteriorating. Maintain to prevent release to the ground. <br /> Absorbent was deposited in the oil stain areas, and the oil/water condensate was <br /> vacuumed and deposited in an approved,properly labeled barrel within minutes of <br /> observation. In addition, we are now in the process of deciding on whether to use <br /> absorbent only, steam clean and vacuum the oil stains or to replace the asphalt <br /> with concrete to aid in wiping up subsequent oil drops or overfills. The <br /> deterioration observed is on the surface only, and does not penetrate the asphalt. <br /> 4. (#17) 66265.34(CCR)No immediate access to emergency communication and/or <br /> alarm system during hazardous waste handling. <br /> # 1 —After you learned there was an alarm on the machine, and a telephone with <br /> public address and 911 capabilities approximately 15 feet away in the testing <br /> room, you indicated"OK" on your Notice to Comply. I believe no action is <br /> required by Sumiden Wire. <br /> 5. (#19)25201 (a)(HSC) Stored hazardous waste on site longer than 90 days <br /> without a permit or authorization. <br /> # 1 —Filter Cake in filter press hopper. <br /> # 2—Used oil is only being shipped off site once per year(1997— 1998). Used oil <br /> must be transported off site at least every 90 days. <br /> The materials that were in the hopper under the filter press was not filter cake as it <br /> may appear, although it may be a hazardous material. Our system had not been <br /> used for several years. We had decided to try to clairify some water from a <br /> nearby cooling tower,but found the clairifier system plugged from non-use. In an <br /> attempt to clean out the clairifier that was plugged, our Maintenance Operators <br /> cut a hole in the side of the clairifier, and manually removed the blockage, which <br /> seemed to be a combination of drawing compounds, debris etc.,and put it along <br /> with the absorbent used as cleanup materials into the hopper to dryout. I pointed <br /> this out to you and your trainees, and you and Mr. Sasson witnessed the new <br /> window that was installed on the backside of the clairifier. At the time, the hopper <br /> was not stickered, and I could not verify how long the material had been in the <br /> 2 <br />