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i McKenna & CUM, U.. Attorneys at Law Mr. Doug Willson Supervising Manager June 6, 2000 Page 2 material as a solid waste. As always, we will share our analytical data with the Agency. FACILITY NOT MAINTAINED TO MINIMIZE THE RELEASE OF HAZARDOUS WASTE: CCR § 66265.33 During your inspection of May 10th you observed that a portion of the caliper rust arrest was dripping from the calipers into shallow catch -pans and a minor portion was missing the pans and dripping onto the floor. With all due respect to the Agency, it is unclear that 22 CCR § 66265.31 applies to QBR. Pursuant to 22 CCR § 66265.1(d) "The requirements of this chapter do not apply to ... a generator accumulating waste on-site in compliance with § 66262.34 of this division ... " Further, it is unclear to QBR that the de minimus amounts of rust arrest which missed the pans constitute a characteristic or listed hazardous waste. However, QBR agrees with the Agency that good housekeeping practices are always preferable. Therefore, QBR will by [DATE] design, build and install catchment trays intended to assure that any significant amount of rust arrest dripping from the calipers is collected in the trays rather than coming in contact with the floor. FAILED TO MAINTAIN ALL COMMUNICATIONS OR ALARM SYSTEMS, SPILL CONTROL, OR DECONTAMINATION EQUIPMENT: 22 CCR 66265.33 During your inspection, you noted that the employees who handled hazardous waste did not have communications equipment. Further, you noted that there was no decontamination equipment at the hazardous waste storage areas. For the reasons stated above it is unclear to us that 22 CCR 66265.33 is applicable to QBR as QBR is not a treatment, storage and disposal facility. The regulation provides that "All facility communication or alarm systems, fire protection equipment, spill control equipment and decontamination equipment where required, shall be tested and maintained as necessary to assure its proper operation in time of emergency. Here, employees who are handling hazardous waste are never beyond visual or auditory contact with other facility employees. QBR has characterized its wastes. They are neither corrosive nor dermally toxic. Thus, QBR questions whether alarm and decontamination equipment is truly necessary.