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Inspection Report <br /> spilled chemicals must be cleaned up and managed as a hazardous waste. I documented failure to <br /> remove hazardous spilled chemicals from the plating area floor as a violation of California Code of <br /> Regulations, title 22, section 66265.31 in the SOV issued to LC on December 22, 3003. 1 informed <br /> Mr. Mason that this violation is a repeat violation, since Mr. Catanyag with the local CUPA had <br /> documented the same violation in an inspection report dated March 11, 2003 (see attachment 2) and <br /> had instructed LC to clean up the spilled chemicals, and LC failed to clean up the spilled chemicals <br /> as directed. I informed Mr. Mason that it did not appear that LC had ever cleaned up the plating bath <br /> residues, as directed by the local CUPA in March 2003. 1 informed Mr. Mason that repeat or chronic <br /> violations are considered more serious than minor violations. <br /> In the plating area I observed a polishing/grinding wheel shown in the following photograph. (Note <br /> that this polishing wheel is also visible in photograph 2): <br /> r- <br /> � .- - Photograph 7-Polishing/grinding <br /> wheel. Note accumulation of <br /> polishing dust on the ground <br /> f surrounding the polishing wheel (see <br /> arrows). <br /> Mr. Mason stated that the polishing/grinding wheel (shown in photographs 2 and 7) is used to polish <br /> chrome parts. I asked Mr. Mason to describe how the polishing dust is managed. Mr. Mason stated <br /> "We (LC)just throw that stuff in the garbage". I asked Mr. Mason if LC had ever determined whether <br /> or not the dust is hazardous. Mr. Mason answered "No, why, do you think it is hazardous?". I <br /> informed Mr. Mason that, based on my experience, chrome polishing dust may be hazardous waste. <br /> I explained to Mr. Mason that, pursuant to Calfornia Code of Regulations, title 22, section 66261.24, <br /> if the polishing dust contains chrome in "fine powder form" (i.e., particles of chrome less than 100 <br /> micrometers in diameter), and if the waste is analyzed by STLC and it is determined that the waste <br /> contains more than 5 mg/L, in Table II in California Code of Regulations, title 22, section <br /> 66261.24(a), the polishing dust waste is a hazardous waste. I informed Mr. Mason that pursuant to <br /> California Code of Regulations, title 22, section 66262.11 a generator must make a determination <br /> whether or not any potentially hazardous material is a hazardous waste. I suggested to Mr. Mason <br /> that LC should have a State-certified laboratory determine if the chrome polishing dust is hazardous. <br /> I also informed Mr. Mason that, if it is determined that the polishing dust is hazardous, it would result <br />