COMPLIANCE INFO_2021 - Laserfiche WebLink

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RCRA Large Quantity Generator Inspection: 1. Violation 102 — Submit a hazardous waste determination for the following wastes: a. Seven unlabeled drums of waste observed in the hazardous waste storage area i. Response: Manifest # 016134872 FILE —attached b. A 55 -gallon waste drum storing what appeared to be liquid and city water treatment resin (beads) and labeled as "Rinse Water Filters" and "Non-RCRA Hazardous Waste, Solid (Aluminum)" observed in the hazardous waste storage area i. Response: These wastes also were sent out under Manifest # 016134872 FILE c. A trash container of black -colored solids observed in the treatment system secondary containment i. Response: These solids were common trash, they were not hazardous waste. The container should not have been left in the secondary containment area. ii. Response: IES has since instructed that no items that are not hazardous waste or chemical inventory should be storage / left in secondary containment areas. 2. Violation 112 — Submit a corrective action statement addressing the failure to prepare a hazardous waste manifest for transportation of the hazardous waste from the facility to Forward Landfill. a. Response: As submitted in the corrective action statement, the drums and containers that were mistakenly sent to the landfill contained residual product in them. b. Response: The material is these containers were not a hazardous waste, it was residual product that was reused in the facility's process line. c. Response: A manifest is not required for non -hazardous waste. 3. Violation 114 — Submit proof that the facility mailed the listed manifests to DTSC. a. Response: Picture show the manifest being sent to DTSC — attached pictures in attachments. 4. Violation 115 — Submit a copy of the following manifests signed by the designated facility: a. Manifest 016133604 FILE (7/16/2021) i. Response: - attached copy of Manifest 016133604 FILE in attachments. b. Manifest(s) for the clean out of the processing line baths 2, 5 and 8 within the previous two months from the date of inspection, 7/20/21, as stated by Chad Yelm. i. Response: Manifest #014649293FLE in attachments —attached. 5. Violation 116 — Submit a copy of manifest 014649293FLE (4/12/2021) signed by the designated facility. If the manifest can't be located, submit an exception report to DTSC and SJC EHD. a. Response: Manifest 014649293FLE in attachments. —attached. 6. Violation 118 — Re-train employees on hazardous waste management and emergency response procedures and submit complete training records. A training record template was previously provided that can be used. Training documentation requirements are listed on the inspection report under this violation. a. Response: Copies of completed to date Training records for supervisors Chad Yelm and Jason Torres, and Wastewater Treatment System Operator Travis Bates — attached. b. Response: Training schedule of SJC-EHD sponsored CUPA Classes presented by NES, INC. and classes schedule for Chad, Jason and Travis to attend — attached. 7. Violation 201— Submit a corrective action statement addressing the failure to use a DTSC registered transporter to transport hazardous waste from the facility to Forward Landfill. a. Response: As identified by Rob Ashe in our August 23, 2021 conversation, the residual material in the containers that was taken to the landfill was identified and used as chemical additives and utilized in the process. The operations of bringing the residual