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McKenna & Cum, U.,. <br />Attorneys at Law <br />Mr. Doug Willson <br />Supervising Manager <br />June 6, 2000 <br />Page 4 <br />was not received pursuant to this regulation. I understand that QBR corrected this <br />oversight to your satisfaction. <br />CONTINGENCY PLAN WAS INCOMPLETE: 22 CCR 66265.52 <br />In reviewing QBR's documents you concluded that the Facility's Emergency <br />Contingency Plan did not include all the information listed in 22 CCR 66265.52 and <br />66265.56. As discussed above, QBR questions whether Chapter 15: Interim Status <br />Standards for Owners and Operators of Hazardous Waste Transfer, Treatment, <br />Storage and Disposal Facilities, is applicable. However, QBR agrees with the <br />Agency that there is value in developing and maintaining an up-to-date Emergency <br />Contingency Plan. Thus, within 30 days of the date of this letter, QBR will submit <br />to the Agency an Emergency Contingency Plan as part of its Hazardous Materials <br />Management Plan. <br />PERSONAL TRAINING RECORDS INCOMPLETE: 22 CCR 66265.16 <br />At the time of your inspection on May 10th QBR was unable to provide for <br />your inspection an organized set of employee training records and requirements. <br />While QBR disagrees that 22 CCR 66265.16 is applicable to its facility, it concurs <br />with the Agency that the development and maintenance of an adequate employee <br />training program benefits all concerned. Thus, within 30 days of the date of this <br />letter, QBR will provide to the Agency a complete description of its employee <br />training program and implementation plan. As always, QBR invites the Agency to <br />inspect those records at its convenience. <br />FAILURE TO INSPECT CONTAINERS AT <br />LEAST WEEKLY: 22 CCR 66265.174 <br />At the time of your inspection, you indicated that the inability to inspect fully <br />each container on all sides was of concern to the Agency. While QBR concurs that <br />adequate inspections are important, it questions the applicability of 22 CCR <br />66265.174 to its facility (see 22 CCR 66165.170). Further, it believes that its <br />current inspection procedures are adequate. <br />On a weekly basis, QBR employees inspect each drum and the containment <br />pan below them. If there is any moisture in the containment pan QBR removes the <br />drums from the rack and inspects them individually. QBR believes that this <br />