Laserfiche WebLink
McKenna & CuneO, LL. <br />Attorneys at Law <br />Mr. Doug Willson <br />Supervising Manager <br />June 6, 2000 <br />Page 3 <br />However, again in an abundance of caution, QBR has determined to take the <br />following actions: <br />a. An airhorn will be provided at each hazardous waste storage area with <br />directions indicating that in the eventofan emergency the airhorn may be blown to <br />^o-Trmunic3te with designated resr;onder'' and <br />b. QBR will by July 15, 2000 install two emergency showers for <br />decontamination purposes. <br />FAILED TO PROPERLY LABEL CONTAINERS OF <br />HAZARDOUS WASTE: 22 CCR 66262.34 <br />During your inspection of May 10, 2000, you observed that QBR was <br />using home made labels rather than the commercially available self -sticking labels. <br />While we believe that the home made labels fully comply with 22 CCR 66262.34, <br />QBR understands the Agency's preference for commercially available self -sticking <br />labels, and will use commercially available self -sticking labels in the future. <br />MANIFEST NOT PROPERLY COMPLETED, <br />SIGNED OR DATED: 22 CCR 66262.23(a)(1) <br />In reviewing QBR's manifests, you identified several of these that Ms. <br />Daggett had executed on behalf of QBR. QBR has engaged Ms. Daggett as a <br />consultant for her expertise in environmental health and safety matters. QBR is <br />not aware of any regulation that prohibits Ms. Daggett acting on behalf of QBR as <br />its agent from signing the manifest. <br />However, QBR agrees with the Agency that having an employee of QBR <br />execute these documents creates a greater sense of awareness, ownership and <br />responsibility by the company and its staff. Thus in the future, an employee will <br />execute all manifests on behalf of QBR thereof. <br />FAILED TO DETERMINE STATUS OF HAZARDOUS WASTE WHEN <br />MANIFEST COPY NOT RECEIVED: 22 CCR 66262.42(a) <br />In reviewing QBR's manifest records, you identified three manifests for which <br />QBR had not determined the status of the hazardous waste when the manifest copy <br />