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