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Department of Toxic Substances Control <br />700 Heinz Avenue <br />Berkeley, California 94710-2721 <br />SUMMARY OF VIOLATIONS <br />Facility Name: ECS Refining in Stockton Date: May 7 and 8 2012 <br />SECTION I: NON - MINOR VIOLATIONS AND REQUIRED CORRECTIVE <br />ACTION (Violations not considered Minor Violations) <br />You must correct the following violation(s) within the specked time frame for each violation. . <br />Class II Violations: <br />1. ECS Refining violated California Code of Regulations (Cal. Code Regs), title 22, section <br />66273.34 (a) and (d), (f) or (g), in that on or about and prior to May 7, 2012, ECS Refining <br />failed to do the following: a) label or mark pallets and/or containers in or on which the <br />batteries are contained, with the phrase: "Universal Waste -Batteries"; b) label a box holding <br />CRT glass with the phrase " Universal Waste- CRT Glass", c) label or mark pallets and/or <br />containers in or on which the laptop computers and flat screens are contained, with the <br />phrase: "Universal Waste- Electronic Devices", or clearly label the demarcated boundaries of <br />a designated area with the phrase: "Universal Waste -Electronic Device(s)". <br />At least two pallets holding batteries, two boxes of lap top, computers, two boxes holding <br />computer flat screens, one pallet of monitors, one drum holding keyboards and calculators <br />and one box of CRT glass were not labeled. ECS also incorrectly labeled about 16 boxes of <br />computer monitors as "UW/CRT Devices" and 28 pallets of plasma screens as "mixed <br />breakage". The monitors and Plasma screens should be labeled "Universal Waste - <br />Electronic Devices". <br />Corrective Action: <br />ECS Refining shall immediately label all batteries with the phrase "Universal Waste -Batteries" <br />and electronic devices or a designated /demarcated area for electronic devices with the <br />phrase "Universal Waste -Electronic Devices)". Within twenty-one (21) calendar days of the <br />date of this SOV, ECS Refining shall submit legible photographs showing examples -of the <br />correctly labeled electronic devices, CRT glass and batteries. <br />2. ECS Refining violated Cal. Code Regs., title 22, section 66273.33(b) (1), in that on or <br />about and prior to May 7, 2012, ECS Refining failed to contain lamps in a closed container. <br />A Gaylord box containing smaller boxes of lamps were not closed. The lamps in the boxes <br />were extended out and unprotected. <br />Corrective Action: ECS Refining shall contain any lamp in a container or package that <br />OTSC (NOVEMBER 2007) page 2 4f - <br />